EPA/600/R-94/171
September 1994
NASA LANGLEY RESEARCH CENTER
AND THE
TIDEWATER INTERAGENCY POLLUTION PREVENTION PROGRAM
by
Science Applications International Corporation
Hampton, Virginia 23666
EPA Contract No. 68-D3-0030, WA-017
SAIC Project No. 01-0824-03-5618-000
EPA Project Officer
Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
NASA Project Officer
John W. Lee
Office of Environmental Engineering
NASA Langley Research Center
Hampton, Virginia 23681-0001
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
Qfi 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 (EPA) under Contract 68-D3-0030 to Science Applications International
Corporation. 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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ABSTRACT
National Aeronautics and Space Administration (NASA)'s Langley Research Center (LaRC) is an
807-acre research center devoted to aeronautics and space research. LaRC has initiated a broad-based
pollution prevention program guided by a Pollution Prevention Program Plan and implemented through
specific projects. Developed under an interagency agreement with EPA's Risk Reduction Engineering
Laboratory, the Program Plan contains an environmental baseline, opportunities for pollution prevention,
and establishes a framework to plan, implement and monitor specific prioritized pollution prevention
projects.
Over twenty specific source reduction or recycling projects have been initiated since 1991.
Recycling activities and use of conservation measures have reduced the use of various freon
chlorofluorocarbons, ozone depleting substances (ODCs), by 84 percent in 1993 compared with 1990
figures. In addition, improved silver recovery procedures reduced the amount of photographic laboratory
waste by 70 percent, or 11,982 pounds, during 1993. Total hazardous waste, excluding abrasive blasting
debris generated by specific remediation projects, has been reduced by 25 percent, or about 50,000
pounds, in 1993 compared to 1992.
By implementing their pollution prevention program, NASA LaRC is contributing to the success of
the Tidewater Interagency Pollution Prevention Program (TIPPP). TIPPP is a pollution prevention
demonstration program designed to integrate pollution prevention concepts and practices at Federal
installations in the Tidewater, Virginia area. Other participants include Langley Air Force Base, the U.S.
Army Transportation Center at Fort Eustis, Naval Base Norfolk, and the Environmental Protection Agency.
In addition to featuring NASA LaRC's Pollution Prevention Program, this report describes the pollution
prevention and recycling accomplishments of TIPPP participants.
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CONTENTS
Disclaimer jj
Abstract iii
Tables v
Figures v
Acknowledgements vj
Chapter 1. Introduction 1
NASA Langley Research Center 1
The Tidewater Interagency Pollution Prevention Program 1
Chapter 2. NASA Langley Research Center 4
The LaRC Pollution Prevention Program 6
NASA LaRC Pollution Prevention Activities 7
Chapter 3. Fort Eustis/Fort Story 20
Accomplishments 20
Chapter 4. Langley Air Force Base 23
Accomplishments 23
Chapter 5. Naval Base Norfolk 25
Accomplishments 25
Chapter 6. EPA Risk Reduction Engineering Laboratory 28
The Pollution Prevention Research Branch 28
The Waste Reduction Evaluation at Federal Sites Program 28
Chapter 7. Conclusions 30
Appendix A - TIPPP Pollution Prevention Opportunity Assessment Reports 32
Appendix B - Pollution Prevention Fact Sheets 179
IV
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TABLES
1 Waste Oil and Hazardous Waste Disposal 1993 4
2 Air Emissions from NASA Langley Research Center 5
3 Pollution Prevention Opportunity for Photoprocessing Activities 14
FIGURES
Page
NASA LaRC Hazardous Waste Disposal 1990-1993 6
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ACKNOWLEDGEMENTS
The authors wish to acknowledge the help and cooperation provided by Robert Brown of NASA
LaRC. Other LaRC employees were also very helpful and cooperative. Additionally, the authors would like
to thank Helen Turner of Fort Eustis, Steve Olson of Naval Base Norfolk, and Captain Brian Ince of Langley
Air Force Base for information on pollution prevention activities at their installations.
This report was prepared for EPA's Pollution Prevention Research Branch by John Houlahan and
Kelly Binkley of Science Applications International Corporation under Contract No. 68-D3-0030.
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CHAPTER 1
INTRODUCTION
NASA LANGLEY RESEARCH CENTER
National Aeronautics and Space Administration (NASA) Langley Research Center (LaRC) has
emerged as a leader in multi-media pollution prevention. LaRC staff have developed and are implementing
a comprehensive pollution prevention program to minimize the environmental impacts associated with their
primary mission of aeronautical and space research. This program demonstrates a commitment to preserve
and protect the environment by moving away from a strictly compliance-oriented environmental program
to a more proactive pollution prevention-oriented approach.
LaRC has been undertaking pollution prevention projects for years. Earlier projects, such as
redesigning the electroplating tanks, set the stage for a more comprehensive Center-wide pollution
prevention effort by demonstrating the benefits and feasibility of pollution prevention technologies. LaRC's
Pollution Prevention Program was officially initiated in September, 1992. This date marks the completion
of the Center's comprehensive Pollution Prevention Program Plan. The Plan is the comer stone in LaRC's
Pollution Prevention Program. Individual projects and initiatives are planned and implemented within the
framework provided by the Program Plan.
TIPPP is a pollution prevention demonstration program that focuses on Federal installations in the
Tidewater, Virginia area. TIPPP is designed to integrate pollution prevention concepts and practices into
the operational activities and processes of these installations. LaRC is continuing to accomplish aoals set
forth by the TIPPP. K y
THE TIDEWATER INTERAGENCY POLLUTION PREVENTION PROGRAM
TIPPP is an innovative Federal cooperative effort that began in 1990. In April 1990, EPA and
Department of Defense (DoD) signed a Cooperative Agreement to promote environmental compliance at
military facilities in the Chesapeake Bay watershed. This agreement, in support of efforts related to the
restoration of the Chesapeake Bay, committed the two agencies to incorporate pollution prevention into
programs and activities at bay installations. LAFB, Fort Eustis, and Naval Base Norfolk were then selected
to participate in this demonstration program. Following the initial agreement, NASA joined the effort by
including the LaRC.
In addition, EPA's Office of Federal Facilities Enforcement (OFFE), Risk Reduction Engineering
Laboratory, and Region III, along with the Commonwealth of Virginia and DoD's Office of the Deputy
Assistant Secretary of Defense (Environment) work together to implement pollution prevention projects at
these installations. The Air Force Air Combat Command is the lead Federal agency in TIPPP and plays the
role of the Coordinator.
On August 6, 1992, EPA, DoD, NASA, Air Force, Army, and Navy signed an additional agreement
the Memorandum of Understanding (MOU) that established TIPPP as a cooperative demonstration program
designed! to support various pollution prevention efforts to:
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• Reduce solid and hazardous wastes generated at the participating facilities;
• Improve the energy efficiency of the installations;
• Test the use of alternate, environmentally protective materials that still meet research and military
specifications; '
• Improve procurement practices and inventory controls; and
• Reduce nonpoint source environmental problems.
TIPPP is intended to augment existing pollution prevention efforts, as well as to initiate new projects
and promote information transfer at each participating installation. Under TIPPP, the participating
installations develop and implement pollution prevention practices to reduce the wastes, emissions and
adverse environmental impacts of their facilities. Each installation will develop a customized pollution
prevention program to address its specific problems and support its individual needs. These program plans
will target processes within four sectors: (1) energy production/usage, (2) industrial processes, (3) residential
wastes, and (4) natural resource conservation and land management.
TIPPP is comprised of five components, which are performed by installation personnel and
supported by EPA, DoD, and NASA.
• Planning • Develop the TIPPP program plan, which is based on two levels of planning: (1) a
comprehensive community-wide pollution prevention program plan, and (2) four installation-specific
program plans. Each installation has developed their own site-specific plan, with support from EPA.
The purpose of both the community-wide plans and the installation-specific plans is to provide a 3- to
5-year strategy for identifying, implementing, and institutionalizing pollution prevention techniques.
• Opportunity Assessments - Conduct pollution prevention opportunity assessments (PPOAs) for
operations that produce wastes and/or adversely affect the environment. EPA assisted TIPPP members
by conducting the initial nine PPOAs. The results of these PPOAs are included in Appendix A.
• Outreach - Educate the communities on pollution prevention and recycling concepts. All participants
are developing training and outreach programs for their constituents.
• Research and Development - Provide DoD and NASA with a demonstration program for various
prevention concepts, techniques, and strategies. EPA, DoD, and NASA will identify research efforts and
demonstration projects that might be presented at a participating installation. In addition, as research
topics are identified through installation assessments, they plan to support specific research and
implementation projects.
• Technical Transfer - Provide documentation of test cases for pollution prevention that can be
transferred to other faculties through such mechanisms as EPA's Pollution Prevention Information
Clearinghouse (PPiC) and the Federal Agency Mini-Exchange (FAME). Under this program, the
participants will develop case studies and document all results for specific projects so that they may
be transferred to other Federal facilities and communities. Nine pollution prevention fact sheets were
completed during the initial PPOAs. These fact sheets have been distributed to other Federal
installation and are available in Appendix B of this report.
Since its inception, TIPPP has made significant strides in achieving its pollution prevention goals
through the efforts of the participating installations. In fact, TIPPP is taking the lead in pollution prevention
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by demonstrating ways to integrate pollution prevention into the activities of a community. Each participant
has contributed to the success of TIPPP through its own accomplishments.
This document focuses on the accomplishments of the NASA LaRC Pollution Prevention Program.
Chapter 2 describes the NASA LaRC pollution prevention program and highlights specific program initiatives
and projects. Progress in pollution prevention by the other TIPPP installations include Fort Eustis-Fort Story,
Langley Air Force Base (LAFB), Naval Base Norfolk and EPA's Risk Reduction Engineering Laboratory
(RREL) is the subject of the remaining chapters.
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CHAPTER 2
NASA LANGLEY RESEARCH CENTER
LaRC is an 807-acre research center located in Hampton, Virginia. At LaRC, a facility dedicated to
aeronautical and space research, NASA conducts innovative research programs to advance our knowledge
further the state-of-the-art in aircraft design, and to develop advanced transportation systems and space
station technologies. Approximately 60 percent of the research performed at LaRC is in aeronautics
Aeronautical research is conducted to improve today's aircraft as well as developing new technology for the
future. LaRC performs aeronautical research using a variety of wind tunnels, which operate under various
atmospheric conditions, test media, temperatures, and Mach speeds. About 6,000 people are employed at
LaRC, of which 3,100 are civil servants and 2,900 are contractor and university personnel.
Activities at LaRC with potential to adversely impact the environment and generate wastes include
large-scale physics and chemistry research, engineering and design testing programs and the upkeep
operation, and maintenance of the Center's equipment and facilities. Center activities involve the use of
approximately 6,000 different chemicals and materials. An overview of estimated waste quantities requiring
disposal for 1993 is presented in Table 1. Estimated atmospheric emissions for 1992 are presented in
Table 2.
TABLE 1. WASTE OIL AND HAZARDOUS WASTE DISPOSAL 1993
... . Quantity Percent
J5SS5 (Ibs) of Total
Used Oils 76,000 42
Metallic Hydroxide Sludge and Liquid Waste from Printed Circuit Board Mfg. 36,777 20
Solvent 30^895 17
Contaminated Oil 9172 5
Aqueous Cleaning Solution/Sludge 3i349 5
Photoprocessing Chemical Solution Waste 5^93 3
Contaminated Aircraft Fuel 5 544 3
Mixed Hazardous Waste or Chem Waste 3)463 2
Out-of-date Chemicals 2 837 1 R
Batteries 1529 ai
Metal bearing waste from Laboratory Research 167
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TABLE 2. AIR EMISSIONS FROM NASA LANG LEY RESEARCH CENTER
Constituent Emissions (tons/year)
Total Hazardous Air Pollutants 6.21
Total VOC 22.28
Total ODC 36.32
Carbon Monoxide 10.9
Lead 0.01
Nitrogen Oxides (as NO2) 62.03
Sulfur Oxides (as S02) 31.18
Ozone 0.031
Pm10 6.02
Source: Air Emissions Inventory, Ebasco, Services Inc. 1993
In recent years, LaRC has initiated large-scale, proactive environmental protection programs.
Recognizing the far-reaching benefits of pollution prevention, LaRC has emerged as a leader in using
pollution prevention projects to minimize waste, reduce costs, and limit potential liabilities. LaRC's pollution
prevention program emphasizes source reduction and recycling and recognizes that the elimination of
pollutants at the source is generally less risky and more cost effective than waste treatment and disposal.
The program will also assist the Center in meeting the requirements of Executive Order 12856 (Federal
Compliance With Right-To-Know and Pollution Prevention Requirements). Executive Order 12856 subjects
each Federal agency to the reporting requirements established by the Emergency Planning and Community
Right-to-Know Act. Additionally, each Federal agency is required to plan for and implement pollution
prevention in order to reduce the generation of toxic chemical emissions and wastes by 50 percent by 1999
based on a baseline year of 1994.
LaRC has conducted several notable pollution prevention activities. For instance, LaRC's continued
recycling activities and use of conservation measures have reduced the use of chlorofluorocarbon, an ozone
depleting substance, by 44 percent or 19,305 pounds in 1992 compared with 1989 figures. In addition,
improved silver recovery procedures reduced the amount of photographic laboratory waste by 28 percent,
or 6,141 pounds, during 1992. Total hazardous waste, excluding abrasive blasting debris generated by
specific projects, has been reduced by 23 percent, or about 60,000 pounds, in 1992 compared to 1990.
The Center is also installing a natural gas-fired boiler to reduce the use of inefficient oil-fired units and lower
air emissions. When the oil-fired units are operating, a low sulfur fuel (£0.5 percent sulfur) will be used,
lessening the emission of SOX. The central focus of LaRC's pollution prevention activities since September
1992, however, is its Center-wide Pollution Prevention Program.
In addition to pollution prevention successes, activities at the Center vary from year to year causing
fluctuations in waste generation patterns. Overall, the amount of hazardous waste the Center must dispose
of each year is on a general downward trend as shown in Figure 1. Because of this fluctuation, it is
important for the Center's programs to focus on long-term benefits of its pollution prevention program.
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Figure 1. NASA LaRC hazardous waste disposal (1990-1993).
200 -
S 150 -
100 -
1992
1993
* Hazardous waste disposed excluding non-recurring remediation wastes.
Source: NASA LaRC Office of Environmental Engineering, March 1994
THE LaRC POLLUTION PREVENTION PROGRAM
The LaRC Pollution Prevention Program is comprised of a Program Plan implemented through
individual projects and support initiatives under the direction of the Office of Environmental Engineering of
the Safety, Environment and Mission Assurance Office.
Through its Pollution Prevention Program, LaRC is committed to proactive environmental
stewardship in the course of meeting its mission. Specific Program goals are to:
• Systematically reduce and eliminate the use of hazardous materials, and the generation of
hazardous and solid waste and other emissions to the environment.
• Adopt a comprehensive approach to environmental management that considers ail environmental
media collectively.
• Integrate pollution prevention into environmental compliance programs.
• Develop pollution prevention partnerships with other Federal facilities and organizations.
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• Instill a pollution prevention ethic throughout the entire Center community and all mission areas.
• Acquire world-class pollution prevention technologies for distribution throughout NASA.
As a first step toward meeting the overall goals, LaRC developed a comprehensive pollution
prevention program plan. Completed in September 1992, the Program Plan covers three general sectors:
(1) energy production and usage, (2) industrial and commercial processes or operations, and (3) natural
resource conservation/land management.
Specifically, the Program Plan:
• Developed a baseline of LaRC's most significant chemical uses, activities, wastestreams and
environmental issues;
• Established criteria for ranking pollution prevention opportunities;
• Identified more than 50 pollution prevention opportunities, ranging from a chemical materials
management system to cardboard recycling;
• Developed an implementation plan for the Center;
• Described a pollution prevention opportunity assessment of a major photoprocessing
operation; and
• Created a Recycling Program Plan and an Affirmative Procurement Plan for the Center.
The Program Plan provides the framework within which to identify, plan, implement, monitor, and
evaluate specific pollution prevention projects or initiatives. The Program Plan will be updated periodically
to identify new pollution prevention opportunities and to assess the performance of existing pollution
prevention techniques. Individual pollution prevention projects and initiatives conducted under the Program
Plan are described in the following sections.
NASA LaRC POLLUTION PREVENTION ACTIVITIES
LaRC staff are conducting various prevention activities to reduce the broad range of wastes and
emissions generated at the facility. A major thrust is to eliminate hazardous waste generation and to reduce
the corresponding management costs. The major sources of the wastes listed in Tables 1 and 2 were
targeted for reduction. This includes projects to reduce oil wastes, wastes from electroplating operations,
photoprocessing wastes, and solvents. Another program focus is to eliminate the use of ozone depleting
compounds (ODCs).
The Program is a collection of short- and long-term projects and initiatives designed to accomplish
the Program Plan goals. The projects described in this report are in various stages of completion; some
have been implemented while other are still in the planning phase. It is expected that as projects are
completed new projects will be initiated. This next section begins by describing four foundation projects.
Following this discussion is a summary of specific action projects. Many of these projects were initiated
prior to completion of the NASA Langley Pollution Prevention Program Plan. Additionally, some of the
projects implemented have a net economic cost or long payback period. These projects were undertaken
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despite their poor economic justification because of their ability to reduce waste, lower environmental
liability, or respond to worker concerns.
Foundation Projects
Foundation projects are helping to build the organizational and physical infrastructure required to
support a pollution prevention program. Foundation projects underway include developing a chemical
material tracking system, constructing a pollution prevention building, conducting training, and outreach and
communication. Each of these projects is briefly described.
Materials Tracking System-
LaRC researchers utilize thousands of different chemicals at the Center's many laboratories and
material testing facilities. Each laboratory generates a relatively small quantity of waste. However, wastes
from chemical laboratories collectively represent approximately 10 percent of the wastes listed in Table 1.
Reducing laboratory wastes presents challenges. Laboratory wastes are characterized by a myriad
of different chemicals and chemical mixtures generated in small quantities from many different individual
laboratories. The nature of research and development work requires specific chemicals, thus making
chemical substitution impossible in many cases. The small quantities of a particular waste chemical or
chemical mixture also makes recycling impractical, as does the need for certifiable chemical grades.
The strategy chosen to reduce laboratory waste was to improve chemical utilization by setting up
a Center-wide chemical materials tracking system. The system objectives are to improve chemical material
use and reduce chemical wastes. The tracking system will also help the Center comply with Executive Order
12856.
Specifically, the system will:
• Help alleviate environmental problems and costs caused by inadequate tracking of chemical materials
(e.g., improper handling of chemicals, purchasing materials already on-hand, chemical shelf life
expiration);
• Provide information necessary to comply with Emergency Planning and Community Right-to-Know
Act (EPCRA) reporting requirements;
• Assist the Center in meeting the pollution prevention requirements of Executive Order 12856 by
identifying opportunities to reduce or eliminate the use of toxic chemicals;
• Provide various LaRC staff with adequate access and reporting capabilities so they know what on-site
organizations and locations have specific chemical materials on hand; and
• Provide chemical materials usage statistics by specific organizations and locations.
Implementing the chemical material tracking system will allow LaRC to track the types and quantities
of chemicals entering the Center and where they are utilized. Roughly 75 percent of the Identified benefits
can be achieved simply by accounting for the types and quantities of chemicals entering LaRC. The
remainder of the benefits can be realized by tracking the chemical materials on hand at the facility and
knowing where they go as they change hands or locations. The tracking system is expected to be
operational in early 1995.
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Pollution Prevention Support Building-
A support building is being designed to house pollution prevention related equipment and materials.
The building will house an electrolytic silver recovery unit for centralized silver recovery from
photo processing wastes, used oil management equipment and a drum crusher. The building was designed
with flexibility in mind and includes the necessary utilities (e.g., compressed air lines, water, electricity) to
accommodate different types of equipment as the need arises. Outside covered storage areas have been
designed to be used to temporarily store materials such as glass or other recyclable materials.
Pollution Prevention and Environmental Awareness Training-
The Office of Environmental Engineering (OEE) is developing a series of training sessions for
environmental coordinators scheduled to begin in mid-1994 and continuing briefings for senior management.
The overall objective is to strengthen the pollution prevention program by enlisting the support of staff
throughout the Center.
The training program for environmental coordinators will consist of a series of presentations to raise
environmental awareness and introduce pollution prevention ideas. The sessions will familiarize
environmental coordinators with pollution prevention concepts and techniques and encourage them to
implement pollution prevention at their job-sites.
The primary objective of the senior management briefings is to introduce top management to the
concepts of pollution prevention. It includes sessions on potential legal requirements for environmental
compliance and how pollution prevention can exceed compliance requirements, thus reducing potential
liability. The anticipated result is to institutionalize senior management commitment for the Pollution
Prevention Program.
Communications and Outreach-
A crucial element of the NASA LaRC Pollution Prevention Program is the environmental education,
communication, and outreach necessary to heighten Center staff awareness of environmental issues. The
role of pollution prevention, such that broad-scaled implementation of the Program can occur and work
practices that adversely impact the environment can be avoided, is clearly presented. Another important
component of the Program is to publicize accomplishments, both at the Center and externally.
Among Center staff and contractors, educational and promotional communications would enhance
opportunities for expanded participation in, and ultimate success of, the Pollution Prevention Program. It
is envisioned that as pollution prevention projects are initiated, documented, and publicized as successes,
the staff will begin to understand prevention concepts as well as the benefits of pollution prevention. This
increased awareness should in turn result in expanding interest in the Program. If LaRC employees are
unaware of protective environmental practices and the importance of such practices, they are less likely to
understand the need for pollution prevention programs.
With regard to an external audience, it is envisioned that LaRC pollution prevention experience and
successes could be transferred to other Federal facilities, such as TIPPP participants. Also, LaRC pollution
prevention activities can potentially serve as a model for other NASA facilities, especially in cases where
there are great similarities among the missions of the NASA facilities.
A Communications and Outreach Strategy was developed. Informal focus groups were convened
in early 1994 to solicit additional input on how best to maximize employee participation in and external
awareness of the Program. Specific communications and outreach activities recommended in the Strategy
have been initiated. Display posters are being developed which describe pollution prevention and the LaRC
Pollution Prevention Program. A series of fact-sheets to be distributed to employees and reproduced in the
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LaRC newsletter have been developed. Additional activities planned for FY1995 Include flyers educational
presentations, and seminars. External outreach effort under consideration include active staff'participation
in appropriate forums, conferences and seminars to publicize NASA LaRC pollution prevention technologies
and activities. *"
Action Projects
Ongoing efforts focus on reducing ODCs and the high volume wastes identified in Table 1 LaRC
staff is undertaking action projects to implement the findings from earlier studies or address opportunities
identified during Program Plan development or subsequent investigations. These projects range from
recycling municipal solid waste and eliminating the use of organic solvents, to filtering and reusing
antifreeze. A brief summary of representative projects follow. Each summary discusses the project
background, approach and benefits. Implementation issues, economic data, and project schedule are also
examined. These projects are loosely grouped based on the type of waste to be prevented.
Oil Analysis To Reduce Waste Oil Generation-
LaRC's Operations Support Division (OSD) is responsible for the maintenance and repair of the
hundreds of motors, compressors, vacuum pumps and other equipment required to run the Center's test
facilities and infrastructure. Used oil generated from equipment repair or scheduled equipment maintenance
is one of the Center's largest volume wastestream. Previous maintenance procedures resulted in oil
changes based on hours of operation or a specified time interval.
OSD staff has been using oil analysis as a tod to reduce the frequency of oil changes Oil samples
from equipment containing greater than 100 gallons of lubricating oil are now taken seml-annually and sent
to an outside laboratory for analysis. Based on the laboratory results the oil is either changed or left in the
system. The laboratory results are also used for predictive maintenance purposes to identify equipment
wear.
Replacing oil based on the oil's properties rather than on a schedule (e.g.f every 100 hours or every
year) reduces oil waste generation. Savings include avoided disposal costs ($100 per 55-gallon drum if the
oil is contaminated), the cost of replacement oil, and the labor required to change the oil These savings
can be substantial, given the size of some of the equipment. For example, the motors used to power
LaRG s National Transonic Facility contain 5,000 gallons of oil. Cost savings are not documented to date
OEE is working with OSD to document future cost savings.
The cost of the off-site laboratory used to analyze oil samples is approximately $23,328 per year
This is based on approximately 54 samples per month at $36 per sample.
OSD staff have been very pleased with the oil analysis program. LaRC staff are considering
expanding the program to include equipment containing less than 100 gallons of lubricating oil Currently
the oil is routinely changed every 12 months for such equipment. The oil analysis program may also be
applied in the future to the LaRC vehicle fleet.
OSD will be using a portable oil analyzer in the near future. The oil analyzer (OilView Computational
Systems, Incorporated) is a portable oil analyzer designed for in-shop use by maintenance staff. The system
provides immediate lubricant condition screening analysis. Test results will be used to determine which oil
samples require off-site laboratory analysis. The cost of the portable oil analyzer system (software and
analyzer) is $8,635.
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The analyzer and software measures lubricant condition as a function of the time-rate-of-change of
the electrical impedance and capacitance of a small fluid sample. Tests are performed by filling the sample
bottle with a representative sample of the lubricant to be analyzed and fastening the sample to the analyzer.
The analyzer connects to an IBM PC-compatible computer. The software is loaded directly from DOS.
Numerical test results present five parameters: corrosion index, contaminant index, ferromagnetic index,
large contaminant indicator, and large ferromagnetic indicator. If the oil is within accepted limits, it will not
be changed. If the portable oil analyzer test results show unacceptable contaminant levels, a sample of the
oil will be sent to the off-site laboratory for more detailed analysis.
Used Oil Filter Recycling--
LaRC's Vehicle Maintenance Shop routinely changes oil for approximately seven hundred
government vehicles. Previously, the Vehicle Maintenance Shop would drain the excess oil from filters into
a 55-gallon waste oil drum before disposing of the filters in the trash. The Vehicle Maintenance Shop began
collecting used oil filters for recycling in May, 1993. Three drums of used oil filters are generated annually.
If not recycled, drained used oil filters would otherwise be included with NASA's solid waste, which
is sent to the Hampton Roads Refuse Incineration Facility. The Center incurs a net cost from sending oil
filters out to be recycled. Shipping a 55-gallon drum of drained oil filters costs $88.00. Disposing of the
drained filters as solid waste is relatively inexpensive. In the eight months since the recycling program was
implemented the Vehicle Maintenance Shop has already collected two drums of used oil filters. The Vehicle
Maintenance Shop is very enthusiastic about this and its other waste reduction projects.
Substitute Reusable Absorbent Pads for Single-Use and Speedi-Dry Absorbent Pads-
Currently, LaRC's National Transonic Facility (NTF) and the Vehicle Maintenance Shop purchase
approximately 3,200 pounds of speedi-dry per year and 863 single-use absorbent pads, socks, and pillows
per year. At the NTF, the absorbent materials are used primarily to absorb oils that have leaked from wind
tunnel motors. The Vehicle Maintenance Shop uses absorbents for drips and spills during oil and fluid
changes. The speedi-dry absorbents cost the facilities $286 per year. The absorbent pads cost $1,374 per
year. The Center disposed of 18 drums of used absorbents at a cost of $2,040. An unqualified amount
of soiled absorbent material is disposed of as solid waste and burned in the waste-to-energy facility located
at the Center.
According to the manufacturer, when the pads become saturated with oil they can be wrung out
to remove up to 90 percent of the oil. The NTF and the Vehicle Maintenance Shop are testing reusable
absorbent pads to see how well they perform. OEE has purchased reusable absorbent pads and two
wringer units, one for each facility. Each facility will replace its absorbent pads and Speed! Dry with the
reusable absorbent pads. The pads can be reused up to ten times. The wringer unit sits atop a disposal
drum v/hich collects the oils as they are squeezed from the pads. The pads can be collected in a drum for
later use or immediately be replaced to absorb more liquids. The oil will be collected and sent off-site for
energy recovery.
Wringing and reuse should reduce purchases of absorbent pads and Speed! Dry absorbent. It
should also lessen the amount of waste absorbent pads and speedi-dry absorbent materials. The reduced
volume of waste absorbent materials should decrease disposal costs. Additionally, the oils removed from
the absorbent pads may be collected for energy recovery.
Reusable absorbent pads should be economically and environmentally beneficial to NASA. In these
two facilities alone, a cost savings of approximately $2,281 will be realized from the use of reusable
absorbent pads. The capital investment for the wringer units will be recovered in about six months.
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The NTF staff report that the reusable pads performed poorly when used to absorb leaks. The pads
did not show good wicking properties. Oil soaked up by one of the pad's panels migrated to a seam and
leaked from the pad. NTF staff believe the reusable pads will be better suited for soaking up large spills
where the pads can be wrung out and immediately reused to soak up the spill.
Vehicle Maintenance Shop staff have not used the reusable pads. They report that the large
reusable pads are ill-suited for the small leaks and drips typical of Vehicle Maintenance Shop operations.
Vehicle Maintenance Shop staff use paper towels to wipe up the drips and leaks.
OEE staff are planning to remove the wringer and reusable pads from the Vehicle Maintenance Shop
and place them in one of OSO facilities for a trial basis. Wringer units and absorbent pads have been in the
NTF and Vehicle Maintenance Shop since January, 1994.
Electroplating Waste Reduction-
The 1270 complex manufactures prototype printed circuit boards for use in spacecraft and aircraft
instrumentation and testing. Current printed circuit board manufacturing involves processing copper clad
glass laminate material through a series of chemical tanks to clean and prepare the laminate for
electroplating and etching. Printed circuit board manufacturing is one of the major waste generating
operations at LaRC. The Hampton Roads Sanitation District (HRSD) permit requires the 1270 complex to
pretreat all rinsewater generated from the fabrication processes currently being performed. The rinsewater
pretireatment facility (Building 1270C) is currently certified to pretreat rinse material generated by the 1270
complex processing. Building 1270C currently pretreats an average of 5,000 gallons of rinsewater a week
using 600 pounds of seed material and generates one cubic yard of metal hydroxide sludge. The
management and staff at the 1270 complex are actively working on ways to eliminate or reduce process
wastes. Two recent projects are to install a deionization unit to allow for closed-loop recycling of rinsewater
and redesigning process bath tanks to reduce raw material use. Both projects are described below.
Procurement and Installation of a Deionization/Water Recycling System-
A deionization/water recycling system was purchased and installed in the 1270 complex. The
system will ultimately allow treated water to be reused as rinsewater in the 1270 complex processes. An
additional benefit is the volume reduction of wastewater treatment sludge. The saturated by-product of the
new deionization system will then be processed by the pretreatment system (Bldg. 1270C) on the fifth day.
It is expected that this project will reduce the amount of seed purchased and sludge generated as
well a reducing the associated costs. After the system is up and running the Electronics Technology Branch
will try using the purified water from the system as rinsewater. The capital cost of the new system is
$20,000. It has been estimated that the avoided costs will be $19,868, based on reduced sludge generation
and seed material costs.
The new system should pay for itself in less than one year based solely on reduced waste volume.
The cost savings from reusing treated wastewater as rinsewater has not been estimated.
When the system is operational, it will need to be certified by HRSD for operation. The system will
require a considerable amount of time to workout operational logistics and optimize the system to achieve
full efficiency (75 percent reduction in sludge output; 80 percent reduction in seed material used). Recycling
of pretreated water will be considered when the new system is operating at maximum efficiency.
Testing of the new system it currently in progress. The system was installed in January, 1994.
Certification by HRSD should be completed by May 1994. The system should reach maximum efficiency
or or before January 1996, at this point, water recycling will be considered.
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Electroplating Tank Size Reduction-
In the past, these tanks required 156 gallons of chemical concentrate per year for proper solution
chemistry of the printed circuit board operation. The process tanks used in the printed circuit board
manufacturing were in need of replacement due to rising maintenance costs and upgrades to meet customer
requirements. When the new equipment was ordered, consideration was given to minimizing the size of the
thirteen tanks. This was accomplished by soliciting customer requirements and by determining the
maximum chemical-loading-rate requirements of the various chemistries being used. After determining load
rates and customer requirements, recommended tank specifications were 19 percent smaller, in most cases,
and in some cases 50 percent smaller. The new tanks were operational in March of 1991.
The benefits of this project included reduced chemical supply costs, reduced waste generation, and
reduced labor costs to process wastes. Chemical costs savings due to tank size reductions are $652 per
year. Reduced waste generation and reduced labor costs to process wastes have not been quantified.
There haive been no problems with production, performance, or product quality with the new tank designs.
Implementation of Photolab Pollution Prevention Assessment-
As part of the Pollution Prevention Program Plan, a Pollution Prevention Opportunity Assessment
(PPOA) of the Center's photolab and other similar activities that generate silver bearing wastes was
performed. The PPOA recommended several pollution prevention options to improve photolab operations.
• Modify quality assurance operations to reduce waste generation.
• Install a water meter in order to monitor water usage to establish baseline information.
• Minimize water usage and reuse rinsewater when possible.
• Return packaging materials to manufacturer.
• I nstall solution level alarms on waste photographic solution storage containers to prevent waste solution
from overflowing and draining into the floor drain.
• Minimize evaporation losses of photographic solutions.
The photolab, Bldg. 1155, is a major generator of silver-bearing wastewater. In 1992, the lab began
implementing silver recovery procedures. Previously, the waste solutions had to be disposed as hazardous
waste. A new procedure to remove the silver from the waste photographic solutions was implemented using
the metal replacement canister method. Extensive testing was done to ensure that silver in the effluent from
the canisters would meet discharge permit levels. The used canisters are sent to property disposal, which
ships them to Defense ReutHization and Marketing Organization for sale to metal recovery companies.
These new procedures have reduced hazardous waste disposal and recovered material for recycling.
The photolab has begun implementation by installing a water meter to establish baseline water
usage. This baseline will help to document actual or potential cost savings from any pollution prevention
opportunities involving water usage. The photolab will begin implementation of the other recommended
opportunities involving water usage after applicable information has been available for one year.
Implementation of the photolab PPOA will significantly reduce the amount of hazardous waste
generated and waste disposal costs. Additional benefits include reduced operating and raw material costs,
reduced waste management labor, and reduced liability.
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Implementation of the first of these will save an estimated $35,000 per year. Table 3 lists each
pollution prevention opportunity with its potential impact, anticipated cost savings, and implementation cost.
A first-order economic analysis of each opportunity was provided in the PPOA.
Although no schedule for implementation has been established, OEE continues to work with
photolab personnel to implement one or more of these projects.
TABLE 3. POLLUTION PREVENTION OPPORTUNITIES FOR PHOTOPROCESSING ACTIVITIES
Opportunity
Modify General Processing
Procedures
Potential Impact
Reduced paper,
chemical, water use,
Anticipated Cost
Savings ($/yr>
35,000
Implementation
Cost ($)
Minimal
Install a water meter in
order to monitor water
usage
Minimize water usage and
reuse rinsewater when
possible
Return packaging materials
to manufacturer
Install solution level alarms
on waste photographic
solution storage containers
Minimize evaporation losses
and silver recovery
processing
Establish baseline
information for future
pollution prevention
options
Reduced water usage
Reduced solid
wastestream
Reduce potential for
overflows of untreated
photographic solutions
into floor drains
Reduced replenisher
use
None but will allow OEE 1,856
to monitor water usage
to quantify water
reductions
Unquantifiable without Minimal
water meter
No direct cost reduction 194
but will contribute to the
Center recycling
program
No direct cost reduction 260
but will reduce possibly
liability costs
Unquantifiable Minimal
Centralized Silver Recovery Untt-
Photoprocessing and x-ray operations are located at ten facilities, Bldgs. 1148, 1149, 1163, 1202,
1205, 1238, 1256, 1268, 1270, and 1296, throughout LaRC in addition to the main photolab, Bldg. 1155.
Photoprocessing facilities are used to develop photos used in LaRC publications and for special events.
X-ray processing is used for various research projects and for medical diagnosis. The operations performed
include batch mixing of photochemicals, plate-making, negative and x-ray development. Wastes generated
from LaRC photoshops include silver-bearing liquid wastes. Liquid wastes from x-ray and photo developing
operations are hazardous because of the high silver content. The goal of this project is to recover silver
from photoprocessing wastes and reduce waste disposal costs by eliminating off-site hazardous waste
shipments of silver-bearing liquids.
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A centralized silver recovery unit will be set up for operation in the new pollution prevention support
building by late 1994. The equipment will be used to recover silver from all silver-bearing waste-generating
operations, except the main photolab, which has its own recovery system. OEE will develop an
implementation plan and standard operating procedures for the centralized silver recovery unit.
Implementation of this project will ensure uniform management of ail silver recovery activities. Silver
flake will be recovered from the waste solutions. Disposal of silver-bearing liquids as hazardous wastes will
be reduced by approximately 1,200 gallons and the resulting disposal costs will be lessened by
approximately $3,000. The economic benefits to NASA from implementation of this project will vary
depending on the efficiency of the electrolytic silver unit. If the unit can remove enough silver to meet
regulatory requirements, the economic benefits will be higher than if the unit must be operated in series with
secondary metal replacement cartridges to meet regulatory requirements. Revenue from the recovered silver
is not included in the analysis because of the uncertainty of recoverable quantities and silver price
fluctuations.
OEE must obtain a permit modification to discharge effluent from the centralized silver recovery unit
to the HRSD system. In addition, before mixing solutions from different facilities, compatibility of solutions
should be tested (e.g., bleach fixers cannot be mixed with regular fixer) to insure proper and safe operation.
The pollution prevention support building is scheduled to be completed in 1994. The equipment will be
installed soon thereafter. Some trial runs are expected to confirm the operational efficiency of the recovery
system.
Termination and Restriction of ODC Class 1 Compound Usage-
CFCs have been the solvent of choice NASA-wide to clean wind tunnel components such as valves
and piping. NASA has established a written policy to phase out the use of CFCs and other ODCs in
response to the Montreal Protocol and the CAA Amendments of 1990. NASA has established a goal of
eliminating non-essential uses of chlorofluorocarbons and methyl chloroform [1-1-1 trichloroethane (TCA)].
As a result, NASA LaRC has already begun terminating from the supply system Class 1 - ODCs as defined
by the 1990 CAA Amendments. The Langley Research Center CFC/Halon Materials Requirement Report,
issued annually, called for discontinuing the use of TCA at the end of the second calendar quarter of 1993.
Accordingly, supply is only issuing TCA until the Center's current supply is exhausted. In November 1993,
the Center targeted electrical contact cleaners containing TCA for replacement in stock supply. In addition
to terminating TCA from the supply system, NASA LaRC has restricted the use of CFC 22, CFC11, CFC 113,
and CFC 12 for use as refrigerants only.
The LaRC OEE staff worked with the facility staff to systematically replace ODCs with alternatives
such as aqueous cleaners. The LaRC staff is striving to eliminate all use of ODCs. An ongoing effort is to
identify an alternative to CFC-113, which is used to verify the cleanliness of parts after they have been
cleaned. The verification process involves placing the cleaned parts to be tested in a beaker. Approximately
100 ml of CFC-113 is poured over the cleaned parts. The CFC-113 solution is distilled and the amount of
volatile and non-volatile residue are determined. The use of CFC-113 for verification is a NASA-wide
specification. Alternative verification processes and solvents are being researched by NASA and LaRC staff.
Aqueous cleaners have been found to be a viable substitute for many operations. Several projects
to reduce and eliminate the use of ODCs are described below.
Aqueous Cleaner Replaces Trichlorotrifluoroethane for Cleaning Oxygen Systems-
Oxygen system parts and components from wind tunnels were cleaned with trichlorotrtfluoroethane
(CFC-113). LaRC operating specifications required the use of CFC-113 for cleaning oxygen systems.
Approximately 825 gallons of CFC-113 were used annually to clean the oxygen systems.
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The LaRC staff decided to replace CFC-113 with alkaline detergents. They tested a number of
different commercial alkaline detergents using them with high-purity deionized water in an ultrasonic cleaner.
The goal of the project was to find a detergent that could clean as effectively or more effectively than CFC-
113. The initial project was performed in a laboratory using small components contaminated with a known
amount of contaminant. The contaminant used was chosen because it is extremely difficult to remove.
Using various detergents with deionized water and ultrasonics, LaRC staff determined the detergents with
the best cleaning performance were Selig 101 and Brulin 815GD. After the laboratory test stage, a scale-up
test was started. In this project, different alkaline cleaners, including the two mentioned previously, are being
used in the actual cleaning environment.
Aqueous cleaning has replaced the use of CFC-113 in 99 percent of the cleaning operations.
Cleanliness verification results show the aqueous cleaning is effective and meets cleanliness standards.
Savings are estimated at $15,000 in raw material cost as of 1993. Projected savings are greater as the cost
of CFC-113 continues to increase rapidly due to the declining commercial production and availability of
CFCs in response to statutory mandates. Tests are still being conducted to evaluate other cleaners to
improve cleaning efficiency. A related effort was to rewrite the LaRC operating specifications to allow non-
CFC cleaning.
Aqueous Cleaning Replaces Freon-113 for National Transonic Facility Cryogenic System Parts-
The NTF houses a large wind tunnel used for aeronautic investigations of the boundary layer
between Mach and sub-Mach speeds. Aqueous cleaning replaced the use of CFC-113 to clean small metal
parts used in cryogenic systems in the NTF wind tunnel. The annual consumption of 70 to 130 gallons of
CFC-113 has been eliminated by switching to an aqueous detergent. Parts are cleaned in an ultrasonic
vapor degreaser manufactured by Blackstone. There was no equipment modification required to switch from
using CFC-113 to aqueous cleaning. There were no increased costs associated with the change.
The detergent adequately cleans the parts. However, there has been a problem with excessive
foaming. The NTF staff are experimenting with other detergents to find one that does not foam as much
and still cleans the parts adequately.
Switching to aqueous cleaners at the NTF has resulted in a substantial cost savings by eliminating
CFC-113 use. Annual expenditures for CFC-113 used for cleaning the wind tunnel components was
approximately $18,000 in 1991.
Switching to aqueous cleaning generates a new wastestream. The wastewater from the cleaning
unit is collected, tested, and discharged to the sanitary sewer. In the past the dirty CFC-113 not lost by
evaporation was collected, recycled, and reused.
Non-CFC Cleaning of Flight Hardware-
CFCs, especially CFC-113, are currently being used as the wash and rinse solvents to precision
clean flight hardware. Precision-cleaning removes particles by ultrasonffication and removes organic
contamination by dissolution.
This project involved testing the cleaning efficiencies of ten different cleaners in order to find a
solvent to replace CFCs. The ability of each solvent to clean flight hardware was determined by measuring
the amount of non-volatile residue. Isopropyi alcohol cleaned better than all other solvents tested. Aqueous
solvents were unacceptable because they left a residue on the parts being cleaned. In many cases the parts
were dirtier than when they began. Isopropyi alcohol cleaned parts better than CFC-113. The lab has
converted one ultrasonic tank to allow the use of isopropyl alcohol and a deionized water rinse.
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The lab has decided, however, to continue to use CFC-113 until the phase-out date. A deionized
water blanket in the CFC-113 tank has substantially reduced CFC-113 loss from evaporation. The Center
is planning to purchase an agitation cleaning system which can use a variety of solvents including alcohols,
aqueous solutions or water (Martin Marietta Jet Clean PC100) for additional testing.
Aqueous Parts Washing in the Aircraft Landing Dynamic Facility, the Vehicle Maintenance Shop,
Engineering and Fabrication Building, and the Boiler Plant-
Degreasing parts and equipment is done at a number of buildings within the Center. During the
Program Plan development, thirty-two facilities using solvent-based cleaners were identified. Traditionally,
parts both metal and non-metal (e.g., teflon or plastic), were cleaned using degreasers containing solvents.
Staff cleaned parts in various washer tanks containing solvents such as xylene, methylene chloride, or
petroleum naphtha.
A Program goal is the total elimination of the use of solvents for cleaning purposes. The conversion
from organic solvent degreasers was prompted by a number of factors. Organic degreasers used at the
Center must be managed as hazardous materials because of their flammability and/or toxicity. Organic
solvents also generate hazardous wastes and volatile organic compound (VOC) emissions. Workers at one
facility also expressed concern over potential health risks from being exposed to the solvent.
Aqueous cleaning has replaced solvent cleaning at four locations which previously used organic
solvents. The locations include the engineering and fabrication building, the machine shop, Aircraft Landing
Dynamics Facility, and the Vehicle Maintenance Shop. Four different biodegradable aqueous cleaners are
in use; Big Blue, Natural Blue, Formula 088, and Citraclean. The aqueous cleaners are used in the existing
parts washer tanks, equipment, and tanks at three of the locations. At the Vehicle Maintenance Shop two
aqueous parts washer machines (Better Engineering Model 200P and Impulse Model) were installed at a cost
of $11,692.
The primary advantage of using an aqueous cleaning system is that it reduces the occupational
hazard, waste management costs, and environmental liability associated with solvent parts cleaning.
Approximately 3,500 pounds of hazardous waste and 2,000 pounds of VOC emissions have been reduced
annually by changing to aqueous cleaners. Approximately $1,000 in direct waste disposal costs have been
avoided annually. Raw material costs have also been reduced since the aqueous cleaners are typically less
expensive than the solvent cleaners.
The switch to aqueous cleaners has been successful. Aqueous cleaners effectively remove oil,
grease, soil, and other contaminants from parts. Cleaning parts with aqueous cleaners takes approximately
one-third longer compared to using the solvent degreasers. However, this has not slowed down work, since
the technicians soak the parts in the tank prior to cleaning. There have been some problems with rusting,
however; at one facility the inside of the parts washer tank lid rusted. The Vehicle Maintenance Shop, which
switched to aqueous cleaning in October 1993, experienced some start-up problems. Initial results of using
a terpene-based deaner were not acceptable. The cleaner caused flash rusting of the parts to be cleaned,
piping, and spray nozzles in the parts washer equipment. The terpene-based cleaner also emulsified the
oil so that it was not removed by the oil skimmer. Workers also complained of the strong odor given off
by the cleaner. The Vehicle Maintenance Shop staff have since switched to an alkaline aqueous cleaner that
does not cause rusting, has no objectionable odors, and cleans sufficiently.
The parts cleaners in use at the four facilities are not connected to drains. The cleaning solutions
are reused, therefore, have no associated disposal costs. Makeup water and fresh detergent are added to
the solution as needed. The sludge in the tank bottoms have not required disposal. Once the sludge builds
up to a level where cleaning the machine is required, the sludge waste will have to be tested to determine
the correct disposal method.
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Electronic Document Transfer To Eliminate Paper Use-
The NASA LaRC technical library provides a service whereby researchers can request and obtain
copies of articles, journals, and other publications. The library staff locates the publication, photocopies the
material, and sends the researcher a paper copy of the requested materials. The library uses an estimated
20 reams of paper per week to photocopy requested publications.
The library is investigating the use of electronic transfer methods to replace the paper copies. Under
the new system, documents will be scanned and sent electronically via LaRC Net (the local area network)
to the researcher.
Advantages of electronic document transfer include eliminating the use of paper and corresponding
paper purchase costs, and reducing paper waste. An additional benefits is the reduced storage space for
new journals and publications can be purchased in digital form such as a CD ROM. Once the publication
is scanned or transferred into a digital file, it can be stored in a fraction of the space needed for a hard-copy
document. This will eliminate the need to store hard copies of the publication. Documents stored on
diskette or CD ROM have much longer shelf-life than hard-copy documents, many of which are now falling
apart due to age.
There is some concern that the new system will not be appropriate for transferring documents
containing technical or engineering drawings. It may not be possible to accurately scan engineering
drawings and other technical graphics. These types of documents may still need to be stored and
transferred using paper copies.
The current software under consideration can only process (scan, convert by software, transfer to
a diskette, or sent across the Local Area Network) one page at a time. This is unacceptable since the library
staff typically copy multi-page documents. The labor required to wait while each page is processed is
judged to be prohibitively expensive. The software is reportedly being upgraded so that the processing will
be faster. The project is scheduled to identify and purchase the required hardware and software by late
1994.
Gas Cylinder Management and Recycling-
NASA LaRC annually purchases and rents several hundred compressed gas cylinders that are used
for research and maintenance purposes. There are three ownership categories of compressed gas cylinders
used at the Center:
1. Stock cylinders are government-owned cylinders that are issued by supply to LaRC personnel. Empty
cylinders are returned to supply and then transported off-site to be refilled by a local vendor.
2. Rental cylinders are cylinders that are owned by a vendor but the contents (i.e., the gas) are purchased
by NASA for use In various applications. The vendor charges NASA a daily rental for use of the cylinder
and keeping the cylinder on-stte.
3. Government-owned cylinders are cylinders that have been purchased from vendors. These cylinders
vary in size but many of them are disposable cylinders. The disposable cylinders are designed for
single use and not meant to be refilled. Government-owned cylinders do not include stock cylinders.
Many cylinders are kept on-site for several years and personnel lose track of the location of the
cylinders. In addition, as personnel retire and the cylinders tags fade, knowledge of the contents and
purposes of the cylinders are lost. A repercussion of this situation is that the Center must dispose of the
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cylinders at great expense. On the average, the cost for disposal of a gas cylinder as hazardous waste is
about $300, but can vary significantly depending on the contents of the cylinder. In contrast, it costs
approximately $27 to return a cylinder to a vendor or $75 to prepare and ship a cylinder to the Defense
Reutilization and Marketing Organization (DRMO) for sale as scrap metal. Between 1993 and 1994, the
Center disposed of, or returned to vendors, approximately 200 cylinders for a combined cost of $28,000.
The Center began working to improve cylinder management by first determining exactly how gas
cylinders are currently managed and tracked. Rental cylinders were returned to vendors when empty.
Government-owned cylinders were prepared for delivery to the DRMO by emptying the cylinder, removing
the valves, and drilling holes in the cylinder. Stock cylinders are refilled by a vendor under contract to NASA
LaRC.
After much investigation and discussions with many gas cylinder vendors, the Center found that
many of the vendors will accept empty cylinders made by their company, even if the Center had purchased
the cylinder. The gas cylinder vendors will not reimburse the Center for the cylinder but the Center avoids
any cost associated with hazardous waste disposal. The Center's new policy for gas cylinders is to return
all "returnable" cylinders (rentals and government-owned) to vendors instead of disposing of them as
hazardous waste. Non-returnable government-owned and stock cylinders that are past their service life will
be prepared for delivery to the DRMO for sale as excess government property.
The next step is to track gas cylinders in order to avoid future problems. Gas cylinders pose a
unique problem from a materials tracking perspective since cylinders are often sent off-site to be refilled by
local vendors and then returned to the Center. Although each cylinder has a unique serial number, this does
not suffice for tracking and reporting requirements since each time a cylinder is refilled it may be used by
a different organization. Additionally, for reporting requirements any tracking system will need to account
for the usage of the gas in the cylinder, rather than just the cylinder itself. Given this, NASA is determining
whether gas cylinders can be tracked using the Center-wide Chemical Materials Tracking System or whether
a separate tracking system is required. The Center is reviewing a gas cylinder tracking program called
Cyltrack from OMWARE Inc. for this purpose.
Implementing this project will reduce the number of cylinders disposed of as hazardous waste and
the resulting disposal costs. Tracking of gas cylinders and their content will reduce the number of cylinders
that have to undergo costly testing to identify their contents. Tracking of gas cylinders will also increase
the material usage rates of gases in the cylinders. An intangible benefit of cylinder tracking is reduced
liability to NASA for disposal of hazardous waste.
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CHAPTER 3
FORT EUSTIS • FORT STORY
Fort Eustis and Fort Story, a sub-installation of Fort Eustis since 1962, are the home of the U.S.
Army Transportation Center, 1 of 16 Training and Doctrine Command (TRADOC) installations. Fort Eustis,
which has been owned and occupied by the U.S. Army since 1918, covers 9,000 acres of land, ranging from
tidal wetland to bottomland forest. Fort Story, located 50 miles southeast of Fort Eustis on the Atlantic
shoreline, has been a military installation since 1914.
ACCOMPLISHMENTS
Through TIPPP, Fort Eustis and Fort Story have conducted several pollution prevention activities,
including the efforts summarized below.
Pollution Prevention Program Plan
In February 1993, Fort Eustis developed a facility-wide Pollution Prevention Program Plan. This plan
is a blueprint for using pollution prevention techniques to reduce waste generation and environmental
impacts caused by post operations.
Green Commissary Project
Fort Eustis developed and constructed a display for the entrance of its commissary that discusses
the topic of "reduce, reuse, and recycle". It includes numerous publications from EPA on waste reduction,
recycling, and other current environmental information. Fort Eustis also conducted two employee training
classes on pollution prevention.
As part of the "Green" Commissaries TIPPP program, the Fort Eustis commissary was chosen to
participate in a demonstration project being conducted to show how commissaries can "go green" and still
maintain profitability. The commissary has initiated a comprehensive pollution prevention program that
evaluates all aspects of Its operations and ways to accomplish them in a more environmentally sound
manner. Through the PPOA that has already been conducted and further environmental training, the
commissary will significantly reduce its waste production and prevent pollution from being generated in the
first place.
EcoloQic '93
Fort Eustis held its first-ever environmental fair on April 23, 1993 called EcoLogic '93. It supported
the Army's environmental strategy and provided an opportunity to present environmental information to
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military and civilian personnel on Fort Eustis and to the surrounding communities. Over forty exhibitors
participated and the response to the event was overwhelmingly positive.
Environmental Watch
Fort Eustis developed a quarterly publication that is distributed post-wide to keep everyone informed
on pollution prevention and other environmental issues.
Environmental Stewardship Proclamation Ceremony
In support of the Army Environmental Stewardship Campaign, an Environmental Stewardship
Proclamation Ceremony was held at Fort Eustis on November 19, 1992. During the ceremony, the
Commanding General signed a proclamation affirming the Transportation Center's intentions to integrate
environmental protection with the installation's mission.
Commander's Environmental Excellence Awards Program
Fort Eustis developed the Commander's Environmental Excellence Awards Program as an incentive
to encourage personnel to document and tout their successes in environmental management and training
and awareness programs. This program recognizes successful environmental initiatives with a quarterly
award presented by the Commanding General. The first award was presented on Earth Day 1993.
1992 TRADOC Pollution Prevention and Recycling Award
To meet Army recycling goals, Fort Eustis established a recycling program which has been highly
successful. From March 1990 to November 1992, for example, the following materials were recycled:
More than 2 million pounds of paper
More than 3 million pounds of metal
More than 925,000 pounds of cardboard
More than 316,000 pounds of glass
More than 147,000 pounds of aluminum cans
In recognition of its success, the recycling program was given the 1992 TRADOC Pollution Prevention and
Recycling Award and has been awarded the Department of Army's Pollution Prevention and Recycling Award
for 1993.
Environmental Awartntas Program
As part of its pollution prevention efforts, Fort Eustis has established an ongoing environmental
awareness program. The program has sponsored many activities, included are:
• Various demonstrations for parts washers and non-hazardous solvents and lubricants, material
substitutes, and other equipment to reduce hazardous wastes;
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• F'dlution prevention training classes for the Transportation Officer' Basic Course and the Transportation
Officer's Advanced Course;
• An Environmental Day in October 1992 sponsored by the 24th Battalion; and
• A Household Hazardous Waste Forum, co-sponsored by the city of Newport News.
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CHAPTER 4
LANGLEY AIR FORCE BASE
LAFB, located in Hampton, Virginia, comprises approximately 2,900 acres and is home to more than
9,000 military and approximately 3,000 civilian employees. The host unit at LAFB, the 1st Fighter Wing, is
charged with the mission of maintaining combat capability for rapid global deployment to conduct air
superiority operations. To accomplish this mission, the 1st Fighter Wing flies the F-15 Eagle, UH-1N
helicopters and C-21 aircraft.
ACCOMPLISHMENTS
LAFB has conducted a variety of pollution prevention activities through TIPPP, as demonstrated in
this chapter.
Pollution Prevention Management Plan
In 1991, LAFB developed a Pollution Prevention Management Plan that set forth the objectives of
the installation for reducing pollution to the air, land, and water.
Plural Component Paint System
A plural component paint system was recently installed at the base. This system allows paint to be
mixed in the exact quantities and packaged in units suitable for a specific job. Thinners required to clean
the paint lines and equipment can be collected in separate containers for recycling. In addition, a high-
volume, low-pressure spray gun will be installed to increase the efficiency of paint use. This new system
will reduce the amount of hazardous materials entering and leaving the base and will reduce the amount
of volatile organic compounds (VOCs) emitted.
Antifreeze Recvcter
LAFB purchased an antifreeze recycling system to remove the metals, colloidal silica, and other
harmful participates in used antifreeze. The system will also restore corrosion inhibitors to the antifreeze,
making it ready for immediate reuse. This process will significantly reduce the amount of hazardous material
handled by the base.
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Hazardous Waste Disposal Reporting System
LAFB has developed a computer-based reporting system to track hazardous waste disposal. This
system identifies the waste associated with each operation, tracks the disposal of the waste, and provides
other information required to make management decisions.
Household Chemical Pollution Prevention Program
Household chemicals are used throughout the base and resident housing for cleaning purposes.
Often, facilities and residents have excess household chemicals that may inadvertently become part of the
municipal solid wastestream. LAFB recently established a program which that allows facilities and residents
to turn in excess household chemicals so that they may be re-issued for use, thereby avoiding disposal.
Solid Waste Management
Langley's recycling program is divided into areas that target different parts of the installation. The
1 si Moral Welfare Recreation and Services Squadron recycles aluminum cans, office paper, and corrugated
cardboard boxes for the administrative and industrial areas. The residential communities curbside recycling
program recycles newspapers, corrugated cardboard boxes, brown paper grocery bags, glass bottles and
jars, metal food and beverage cans, aluminum foil and foil products, metal aerosol cans, metal paint cans,
and number 1 - and 2-type plastic bottles and jars.
Environmental Awareness Programs
LAFB maintains an ongoing environmental awareness program that conducts numerous activities
on-base and in the surrounding community. For example, the base sponsors an Earth-Week program each
year. During Earth-Week, the base conducts educational and training programs, as well as poster and art
contests to promote environmental awareness.
To publicize its efforts, LAFB uses various types of environmental awareness information sources
including Federal and State EPA information publications, Air Force Times, the base newspaper, and closed-
circuit television. By combining the efforts of the environmental programs with those of the public affairs,
legal, and contracting offices, LAFB is more efficiently educating the base community on environmental
issues.
Route of Jet Fuel at the Flight Una
The process of powering down an aircraft generates approximately one-quarter gallon of JP-5 fuel
which is collected in a sump on the aircraft. Personnel at the flight line remove the fuel from the sump and
deposit it into specially designed 125- or 660-gallon containers called bowsers. The recovered fuel in the
bowser is tested for contamination and moisture content. If the test results show the fuel is within
specifications the fuel is returned to the main fuel storage tank. The recovered fuel is mixed through the
bulk storage filter banks prior to being used to refuel aircraft. This process recovers approximately 2,400
gallons of fuel annually. Cost savings are estimated at $1,848 in raw material ($0.77/gallon) and $432 in
avoided waste disposal charges ($0.18/gallon).
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CHAPTER 5
NAVAL BASE NORFOLK
Naval Base Norfolk, located in the Tidewater, Virginia, area, covers approximately 5,400 acres of
land, hosts approximately 200 tenant commands, docks more than 100 ships, and employs more than
100,000 military and civilian personnel, qualifying It as the largest naval base in the U S Navy The base
is situated in the Chesapeake Bay watershed and is surrounded on three sides by water - the Elizabeth
River, James River, and Willoughby Bay. i—uou.
The mission of Naval Base Norfolk is to provide quality support to the tenant commands Tenant
commands are very diverse ranging from administrative to operational commands, such as Naval Station
and Naval Air Station, to industrial commands, such as the Naval Aviation Depot and Shore Intermediate
Maintenance Activity Norfolk. To carry out its mission, base personnel conduct a variety of operations
including paint stripping, painting, engine maintenance, cleaning, and other operational and repair work'
These activities consume large quantities of chemicals and materials and generate many different types of
hazardous and non-hazardous wastestreams.
ACCOMPLISHMENTS
Through TIPPP, Naval Base Norfolk has completed numerous pollution prevention activities which
are highlighted in this section.
Household Hazardous Waste Program
Using the LAFB program as a model, Naval Base Norfolk established a household hazardous waste
program in five family housing areas. By collecting and re-issuing household chemicals, this program helps
to ensure complete use of the materials, avoiding their disposal.
Recycling Program
The recycling program at Naval Base Norfolk has been vtry successful since its establishment in
the mid-1980s. Currently, the base recycles approximately 30 percent of its solid waste, which saved
approximately $3.4 million in disposal costs In FY1992. Norfolk's recycling program is ranked number one
throughout the Navy and number three in the DoD.
Waste Minimization Plan
TIPPP was instrumental in helping to gain funding to prepare the Naval Aviation Depot Norfolk Waste
Minimization Plan, which was finalized In June 1993. This plan includes environmental baseline information
and several pollution prevention opportunities for the depot which generates significant quantities of wastes.
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Environmental Awards
In recognition of its environmental excellence, the Naval Aviation Depot was awarded the Navy's
Environmental Quality Award for a large industrial activity in FY 1992. In addition, two individuals from the
depot received environmental awards in FY 1992 for their work in promoting the environment. John
VanName, environmental engineer, received the Secretary of the Navy Individual Pollution Prevention Award
for his work in waste minimization, and Kevin Summers, supervisory environmental engineer, was the runner-
up for the Individual Environmental Quality Award.
PPQA Training
As part of its pollution prevention program, the base established a PPOA training program in FY
1992. Approximately 25 personnel have been trained in the opportunity assessment process. This training
will be essential to the successful implementation of the Waste Minimization Plan.
Improvement of Paint Stripping and Painting Operations
Other environmental efforts in pollution prevention at Naval Base Norfolk include converting wet-
spray paint booths to dry booths. This effort will reduce the quantity and toxiclty of paint wastes, reduce
emissions of VOCs, and increase the efficiency of using raw materials. Efforts to minimize blast grit in the
cleaning and paint shops has also been implemented to further reduce waste generation.
Plating Waste Minimization
A recent waste minimization project for plating activities has significantly reduced heavy metal
sludge-bearing waste containing chromium, cadmium, silver, and nickel. Using commonly available
equipment, this project has reduced the quantity and toxiclty of rinsewaters generated during plating,
stripping, and cleaning processes and has greatly reduced the waste disposal costs associated with plating
activities.
Hazardous Waste Minimization
Through its aggressive hazardous waste minimization program, Naval Base Norfolk has reduced its
hazardous waste disposal requirement from 408,000 gallons in FY 1990 to 253,000 gallons in FY 1992. The
primary focus of the program has been on training and education, and on single point hazardous material
issue at the Naval Air Station Supply Department and Naval Supply Center Norfolk Paint Mart and
Reutilization Store.
Aqueous Parts Washers
To reduce solvent use in the parts cleaning process, aqueous parts washers were installed aboard
the U.S.S. Theodore Roosevelt and at the Shore Intermediate Maintenance Activity (SIMA) Norfolk. These
parts washers use high-pressure water and water-based cleaners, rather than chemical solvents, to clean
the equipment. The parts washers on the U.S.S. Theodore Roosevelt represent the first such systems
aboard ship; Naval Base Norfolk is working with other ships to install additional systems. The installation
of the parts washer at SIMA Norfolk resulted in the cancellation of the base's single largest Safety Ween
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solvent contract which will eliminate solvents and the procurement and disposal of rags, immediately saving
the base $24,000 a year. More than $100,000 can be saved in labor costs the first year. Many other
commands at the base and surrounding area have been provided demonstrations of this technology and
have procured or are in the process of procuring additional parts washers.
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CHAPTER 6
EPA RISK REDUCTION ENGINEERING LABORATORY
HE POLLUTION PREVENTION RESEARCH BRANCH
The Pollution Prevention Research Branch (PPRB) of the Risk Reduction Engineering Laboratory
(RREL) is charged with research, development and demonstration of promising pollution prevention
techniques and technologies. In accordance with the Pollution Prevention Act of 1990, PPRB research
efforts focus on Source Reduction, Reuse, and Recycling alternatives in the reduction of waste generated
in any media.
As Federal environmental objectives are identified for the 1990's, Agency programs are being
restructured to meet new requirements. Chief among these is the increased importance of pollution
prevention in all Agency activities. Further, all Federal departments and services have been directed to
develop pollution prevention opportunities in order to decrease the total environmental burden resulting from
Government activities, and to provide opportunities in both the public and private sector to reduce
environmental risks.
THE WASTE REDUCTION EVALUATIONS AT FEDERAL SITES PROGRAM
In keeping with the Agency's responsibility to advise and cooperate with other Federal departments
on environmental risk reduction, the PPRB has managed a technical support effort known as the Waste
Reduction Evaluations At Federal Sites (WREAFS) Program. WREAFS was established to conduct research,
develop and demonstrate opportunities to reduce the generation of waste from Federal activities. The
Pollution Prevention Program Plan for NASA-Langley Research Center was produced under the WREAFS
Program via an interagency agreement between NASA-LaRC and RREL
WREAFS has also conducted technology evaluations and pollution prevention opportunity assessments in
support of the NASA-LaRC program. Separately, WREAFS continues to support pollution prevention
research and development efforts at Ft. Eustis and Naval Base Norfolk.
Since 1988, WREAFS has funded work on other Federal sites and It has supported RD&D with
Federal departments through Interagency Agreements (IAG). WREAFS has sponsored pollution prevention
opportunity assessments, base-wide assessments, technology and product demonstrations, technology
evaluations, technology and methodology development, technical assistance and technology transfer across
the Federal community. WREAFS has conducted cooperative RD&D activities with the:
National Aeronautics and Space Administration,
Department of Defense,
Department of Treasury,
Department of Transportation,
Department of Energy,
Department of Interior,
Department of Agriculture,
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Department of Veterans Affairs, and
the U.S. Postal Service.
Through WREAFS, the EPA provides support to Federal facilities in researching, developing and
demonstrating pollution prevention technologies and transferring lessons learned among the Federal
community. Continuing efforts under WREAFS has expanded to include projects that combine pollution
prevention and compliance aspects in a single technical effort. A new publication in this area, entitled,
"Federal Facility Pollution Prevention: Tools for Compliance," is being published by the PPRB and will be
available by Fall 1994.
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CHAPTER 7
CONCLUSIONS
The NASA LaRC pollution prevention program is a comprehensive approach to environmental
management. It covers hazardous and nonhazardous wastes and emissions to all environmental media.
Beginning with an environmental baseline data and program plan LaRC systematically examined all Center
operations and activities to identify opportunities for source reduction or recycling. After ranking the
opportunities LaRC pursued specific projects that target the best opportunities. This includes large volume
wastes such as waste oil, wastes with high costs such as electroplating sludge, air emission sources, e.g.,
ozone depleting compounds and organic solvents, and solid waste recycling. Additionally, a series of
foundation projects, (chemical material tracking system, pollution prevention support building, training, and
employee outreach and communication), seek to institutionalize pollution prevention throughout the LaRC
community.
NASA LaRC's pollution prevention program has resulted in substantial benefits. Over 50,000 pounds
of hazardous waste have been reduced, the use of ozone depleting compounds has been lessened by 44
percent, and over $50,000 in waste disposal costs are avoided annually. Additional benefits include
improved worker health and safety, reduced environmental liability, and enhanced environmental compliance.
There is also growing awareness among the LaRC community of the benefits of pollution prevention.
Implementing the pollution prevention program has required personnel throughout the facility to change their
viewpoint. LaRC environmental staff work closely with researchers and support personnel to design and
implement projects. Cooperation and frequent communication between the environmental staff and the
research and support personnel has resulted in wide acceptance, and success, of specific pollution
prevention projects.
TIPPP has demonstrated the value of a model community approach to integrating pollution
prevention into the daily operation of Federal facilities. The installation programs and projects have shown
the worth of pollution prevention concepts in achieving better environmental quality and more efficient
production and operation. TIPPP accomplishments have forged a new understanding of the role of pollution
prevention in supporting the environmental mission of Federal facilities. The individual pollution prevention
projects and initiatives have confirmed the benefits of pollution prevention, both immediate and long-term.
The monthly meetings among TIPPP participants established a formal channel for exchanging ideas
and solving common problems. Installation programs, in turn, provide the common pod of information and
understanding on techniques, technologies, and strategies that might prove successful in reducing waste
from all participating installations. TIPPP has fostered a cooperative spirit among the installation
environmental managers that has extended beyond pollution prevention. An example is the joint
participation of Naval Base Norfolk and NASA Langley Research Center in Earth Day events.
TIPPP has provided a proving ground for various pollution prevention techniques. This enables the
participants to minimize redundant efforts. Information on prevention techniques and technologies have
been disseminated through publications such as the PPOA surveys contained in Appendix A and the fact
sheets included in Appendix B. This information is available to other installations or communities that might
wish to establish a pollution prevention effort.
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A long-term goal of TIPPP was to create a pollution prevention effort that will continue to function
long after the pilot program. This goal seems assured. TIPPP is the genesis for an informal network
whereby environmental and pollution prevention information and ideas are shared among the different
installations. Other Federal installations in the Tidewater area have become active participants. In particular,
the Naval Weapons Station at Yorktown and the Department of Energy Continuous Electron Beam
Accelerator Facility are the latest TIPPP participants.
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APPENDIX A
TIPPP POLLUTION PREVENTION OPPORTUNITY ASSESSMENT REPORTS
A series of pollution prevention opportunity assessments were performed at TIPPP installations. The
assessments were conducted as part of the U.S. Environmental Protection.Agency's Waste Reduction
Evaluations at Federal Sites (WREAFS) Program. The assessments took place during the early stages of
TIPPP and were intended to provide a pool of information on pollution prevention technologies common to
the installations. The waste generating operations chosen for study were found at two or more TIPPP
installations. A mix of industrial and non-industrial operations were selected in order to demonstrate the
range of pollution prevention opportunities.
Working within time and resource constraints, EPA decided to cover a wider range of operations
in less detail rather than study a couple of operations in great detail. Consequently, the reports are a
survey of pollution prevention opportunities rather than a comprehensive assessment. Each report describes
the waste generating activity, lists the wastes generated, points out opportunities for pollution prevention,
and describes source reduction or recycling options. The main difference is the lack of a rigorous economic
or technical evaluation of specific options. A lack of readily available data also limited the analysis.
The information contained in the reports, while accurate in 1991 when the assessment were
performed, may no longer be current. Many of the operations have changed during the past three years.
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POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
BLASTING OPERATIONS
NASA LANGLEY RESEARCH CENTER
HAMPTON, VIRGINIA
Philip Zach
Science Applications International Corporation
Falls Church, VA 22043
and
Deana Stamm, George Wahl, and Gary Baker
Science Applications International Corporation
Cincinnati, OH 45203
Contract No. 68-C8-0062, WA 3-70
SAIC Project No. 01-0832-03-1021-010
Project Officer
Mr. Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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INTRODUCTION
Oepainting operations occur whenever an anti-corrosive coating on a large metal structure needs
replacing. Such structures include buildings, bridges, ships, storage tanks, and other large objects
containing exposed metal surfaces.
There are two objectives in a typical depainting operation. The first is to free the coated surface of
old paint, rust, and scale. The second is to make sure an acceptable surface profile has been left behind,
so that the new paint will demonstrate acceptable adherence.
Most depainting jobs are accomplished using some type of blasting technology. In this group of
technologies, small hard abrasive particles are directed under high pressure towards the structural surface.
The impact of the particles on the surface removes the unwanted paint and, at the same time, scores the
structural surface, creating the needed profile. The blasting abrasive of choice has traditionally been sand,
chosen because of its low cost and availability.
Blasting wastes consist of blasting debris and blasting abrasive. For the purposes of this report,
blasting abrasive is defined as any material applied to a coated surface for the purpose of removing the
coating, and blasting debris consists of paint chips, dust, and mill scale removed from the surface during
the blasting operation. Paint chips may also contain lead, zinc, barium, and/or selenium in the coating
formulation.
There are a number of drawbacks to traditional blasting technologies from a pollution prevention
standpoint; these include:
• Generation of heavy dust clouds, which are hazardous to workers and can leave the
worksite and contaminate surrounding areas
• Mixing of blasting waste and debris, which creates a sizable amount of hazardous waste.
Concerns about waste generation, site contamination, and rising raw material and disposal costs
have lead to the creation and implementation of new technologies and approaches that attempt to alleviate
these problems.
This report outlines several strategies for environmentally sound depainting technologies, focusing
primarily on the recyclable steel grit system implemented by EG&G, the operations contractor for NASA
Langley Research Center. Information on this application was obtained through conversations with Ray
Anderson (EG&G's point of contact), technology descriptions provided by the company manufacturing the
blasting equipment, and case studies describing results and costs associated with use of the technology.
NASA (through its contractor) is already implementing many of the suggestions contained in this report; the
entire strategy is presented as guidance for ways NASA and similar facilities can enhance their current
approaches. This report also examines alternative technologies, both for blasting and for containment of
blasting debris which may be preferable for certain applications, depending on institutional, cost, and
operational parameters. The descriptions of processes and status of projects ARE as of September 1991,
when the onsite assessment was conducted.
PROCESS REVIEW
NASA Langley Research Center's physical plant contains a number of structures that require
periodic blasting and repainting, including numerous wind tunnels coated with lead-based paint. The
depainting system and procedure used on one wind tunnel is the basis for this report. Other structures at
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the Center scheduled for depainting operations in the near future include a plenum shell and the exterior
of another wind tunnel.
The Sixteen-foot Transonic Wind Tunnel is a closed-circuit, single-return continuous flow atmospheric
tunnel used for force, movement, pressure, and flow visualization studies on propulsion-airframe integration
models. It presents several challenges for a depainting operation due to the unusual architectural features
(ribbing, re-bar, etc.) and geometry that comprise the structure's surface. EG&G's objective was to identify
and implement a combination of blasting and containment technologies that would clean the structure's
surface, impart a surface profile suitable for repainting purposes, and realize pollution prevention goals, all
while maintaining a cost-effective operation. For the project, a decision was made to use a recyclable steel
grit blasting system, coupled with a variant of negative pressure containment technology.
Technology Description
Complete Abrasive Blasting Systems, Inc. (Kent, Washington) provided EG&G with their SABAR
model MS-4-25-1 recyclable steel grit blasting system. The system included a model MS-6a abrasive blast
machine, with a working pressure of 125 psig, four abrasive blast outlets (of which two are available for use
at any time), an induction vacuum recovery system, a model SPI-16 combination interceptor/classifier
capable oif processing a minimum of 3.5 tons of abrasive each hour, a 165 cubic foot capacity storage
hopper operating under 29" Hg of pressure, a model 3400 blast lighting system, a dust collector for the
vacuum exhaust, and a skid for easy transport of the equipment.
The system had a total abrasive bin capacity of 285 cubic feet. A total blast cycle (using two blast
nozzles) required approximately 11 hours, while a total reclaim cycle (using one vacuum) took approximately
121/2 hours, depending on hose length, air pressure/volume, and operator effort. The system was designed
to be accompanied by conventional containment (tarps).
The containment tarps used by the facility were made by Aero Canvas Product (Cincinnati, Ohio).
Specifications for these tarps include construction of 22 ounces vinyl coated white nylon, heat sealed fabric
seams, Number 4 solid brass spur grommets every two feet on the perimeter, and external and internal
flaps/aprons.
Process Description
EG&G describes its blasting operations as a mirror image of a typical asbestos removal process.
A modular floor was laid under the worksite and the containment tarps installed to prevent leakage of
hazardous debris from the blasting area. Containment consisted of the tarps and the slight negative
pressure induced by the operation of the recovery system, with makeup air being added to sustain the
partial vacuum and protect workers. The negative pressure helped keep fugitive dusts from exiting the
containment structure through seams in the tarps. Blasting system operators (wearing respirators and
Tyvec™ suits) position themselves a short distance from the coated surface during actual blasting. It is
estimated that although some small quantity of steel grit was lost to the waste stream during each blast
cycle (expenditure of a full system load of grit), it would still be more than 100 blast cycles before addition
of replacement grit is needed. At that rate, spent abrasive was a very small fraction of overall waste
generation during the operation.
Collected blasting debris is stored in 55 gallon drums. Used Tyvec™ and polyethylene film are
disposed of in one cubic yard "Waste Wranglers", which can hold approximately the same volume of waste
as four 55 gallon drums, yet can be disposed much more cheaply ($225 per drum versus $500 per Waste
Wrangler). However, the Waste Wrangler was not strong enough to hold the heavier blasting media and
paint chips, and so was not available for general waste disposal.
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After completing a shift, operators washed themselves and their respirators with the wastewater
flowing to holding tanks. The water then passed through a filter to remove lead contamination before sewer
discharge. It Is estimated that the operation generated approximately 1,000 gallons per week of this
wastewater. Areas surrounding the site were tested periodically for possible debris contamination.
After the blasting operation was completed, the blasting team vacuumed the floors and the tarps,
repainted the structure, and then disassembled the containment.
Process Savings
Savings from the use of this system when used to clean the tunnel interior (as opposed to the
exterior now being blasted) totaled $2,087,990 when compared to conventional sand blasting technology.
This figure includes $134,870 in reduced abrasive purchases, $262,920 in drum costs, and $1,690,200 in
disposal costs. Environmental benefits include a significant reduction in the volume of hazardous waste
generated by the operation, due to the separation of spent abrasive from the debris waste stream [9].
Depainting Operation Pollution Prevention Case Study
The following case study [7] is an examination of the factors affecting hazardous waste generation
during depainting operations. In it, a grit-based blasting system, similar to the one employed by EG&G is
used to test different containment technologies. The study was conducted on a steel bridge structure for
the State of Michigan Department of Transportation. Three different dry abrasive blast processes were
evaluated for the amount of abrasive used, amount of hazardous waste generated, worker
safely/environmental conditions, and cost differences.
The three processes were applied to three different sections of the bridge with identical conditions.
These conditions included peeling paint (25 percent of surface), light to heavy rusting (10 percent of surface)
and heavy corrosion (8 percent of surface in expansion areas).
Once a coating has been applied to a surface the volume of blasting debris generation is roughly
the same regardless of which containment technology is used. Therefore, the real variable in blasting waste
generation (and disposal costs) is spe/it media. One of purposes of this experiment, therefore, was to
identify the blasting/containment technology or combination of technologies that produced the largest
reductions in blasting media waste volume and disposal cost.
Experimental design
The test runs were conducted using three different combinations of waste containment technologies.
The basic test setup (Design 1) incorporated a blast pot, blast nozzles and a four-sided enclosure with
ground drop cloths (total containment). Design 2 added a dust collector and stronger ventilation, and
Design 3 used a negative pressure total containment system with cyclone separation of grit and blast debris
(the level of technology attained by EG&G). The variables studied were the use, disposal, and cost of
blasting abrasives.
Results
The study summarized each of the three tests and rated them as poor, fair or excellent. Design 1
was rated as "poor" due to cost and labor intensity of maintaining a 100 percent enclosure. In addition,
there was very high worker exposure to hazardous lead dust and paint solvent fumes. This translated to
a production rate drop and increased abrasive usage causing more pre-cleaning of the steel prior to
painting.
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Design 2 was rated as "fair" and is similar to Design 1 in that the enclosure maintenance was
extremely costly. The advantage of Design 2 was associated with worker safety, with the addition of a
ventilation system. The major difference between Design 1 and Design 2 was the volume and disposal cost
savings of the spent abrasive. Design 1 resulted in 11.8 tons of hazardous waste disposed for $2,183 versus
10.4 tons non-hazardous, plus 2 5-gallon pails hazardous for a total disposal cost of $330 for Design 2.
Design 3, which was the most technologically advanced, was rated as "excellent". The work area
did not need extensive containment, there was no daily clean-up activities outside the work area and minor
preparation (vacuuming) of the steel was needed prior to painting. The hazardous waste volume generation
for Design 3 was less than one cubic foot resulting in a disposal cost of $35.
The costs per square foot for each of the three designs was calculated and are summarized in
Table 1. It was determined that Design 3 generated the least volume of hazardous waste and was the least
expensive option overall of the three designs tested.
Cleaning rates did not vary significantly among containment designs. The most progressive design
reduced waste generation dramatically, due to the addition of abrasive recovery technology. This study
shows that:
• The cost difference between more rather than less comprehensive containment is small
when compared with overall waste disposal costs (plus more containment provides better
protection against containment leaks).
• Removing abrasives from the waste stream can be the most cost effective containment
technology, as well as the most important pollution prevention technique.
TABLE 1. POLLUTION PREVENTION TECHNOLOGY ASSESSMENT CASE STUDY
Pollution Prevention Technology
Cleaning rate
(sq-ft/hr)
Abrasive Waste
Generation
Cost
(per sq-ft)
Design One:
4-sided enclosure w/ drop cloths
Design Two:
4-sided enclosure w/ drop cloths,
dust collector, ventilation
Design Three:
Total negative pressure containment
enclosure, ventilation, recycling
equipment
116
127
118
11.8 tons
10.4 tons
< 1ft3
(spent abrasives)
$1.30
$0.67
$0.06
The study shows that significant levels of pollution prevention can be achieved through the use of
technologies already on the market.
ASSESSMENT
A review of EG&G's blasting operation at NASA Langley Research Center was done in
September 1991. Data on material inputs and outputs are not available at this time. Worksheets in EPA's
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Waste Minimization Opportunity Assessment Manual (EPA/625/7-88/003) requesting process data were
distributed by the pollution prevention assessment team, but were not returned.
Pollution Prevention Activities
NASA and its contractor have already implemented a number of environmentally-sound blasting
operation waste management techniques that are a significant improvement over conventional technologies.
The most important of these are:
Recycling of steel grit abrasive
Cyclone separation technology
Vacuum exhaust dust collection
Negative pressure full containment (with makeup air)
Site sampling and analysis
Wastewater pretreatment
Pollution Prevention Options
This section presents information aimed at supplementing and enhancing NASA's current and future
blasting operations to become even more effective at pollution prevention. Because the EG&G staff are
already implementing some of these ideas, they may be redundancies in the report. This section presents
a comprehensive approach and may examine alternatives already in use at Langley. It presents information
on new technologies gleaned from a variety of different sources that are aimed at reducing hazardous waste
streams from blasting operations as much as possible. Pollution prevention alternatives are presented as
two main options: source reduction and material containment.
Source Reduction Opportunities
The first priority in any pollution prevention scheme is source reduction - the attenuation or
elimination of both the hazardous elements and the overall volume of the given waste stream. In this case,
source reduction techniques can theoretically be applied to three waste stream constituents: blasting
abrasives, blasting debris volume, and heavy metals contained in the debris.
Blasting Abrasive - eliminating abrasives from the waste stream has both environmental and
economic benefits: it reduces the volume of waste needing disposal, and thus reduces both disposal and
replacement costs. The following process substitutions are commercially available:
Steel grit with recycle (currently in use)
Power tools
Rash blasting
Cavrtation blasting
Cryogenic cleaning
Blasting Debris Vdume and Composition - since blasting debris consists of coatings that have
already been formulated and applied, little can be done to reduce their toxic nature or overall volume. Of
the heavy metals, lead is of primary concern in older coatings, though zinc, barium and selenium are being
used in current formulations and will eventually enter the waste stream as well. NASA estimates that, even
though lead paint is no longer being used in coating formulations, it will be 5-10 years before the last of the
lead already applied enters the waste stream. Lead will therefore continue to be a constituent of concern
for the foreseeable future, and its management will have to be taken into account during blasting operations.
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However, planning for the future will help ensure that hazardous waste generation does not impact
blasting operations indefinitely. Specifications for new coatings can be formulated to include pollution
prevention goals as priority items. For instance, non-toxic anti-corrosives can be substituted for lead-based
pigments with little or no loss in product performance. Similarly, coatings can be specified which
accomplish the desired anti-corrosion objectives with as few coats as possible. Institutional barriers may
have to be overcome to incorporate pollution prevention objectives into coating formulations, but
internalization of waste disposal costs into projected cost/benefit analyses may help make necessary
changes easier to implement.
Containment Technologies
Containment does not have any explicit pollution prevention characteristics, due to the fact that it
does not prevent waste from being generated. Its main contribution comes from the pollution prevention
attributes of the technologies: by preventing wastes from exiting the blasting site, they significantly reduce
or eliminate contamination of the air, ground and water surrounding the site (fugitive emissions).
Containment can be realized primarily through material control technologies. Types of containment
technologies currently available commercially include: conventional total containment; negative pressure
containment enclosures (as currently used by EG&G); and localized containment.
Based on a cursory assessment of available technologies and project requirements, several source
reduction and containment options were selected for feasibility analysis. The source reduction technologies
include power tools and cryogenic cleaning. Containment technologies include negative pressure
containment enclosures and localized containment.
FEASIBILITY
A feasibility analysis was conducted for each component of the pollution prevention options. A brief
discussion of each option is presented below.
Power Tools
Technology Description - power tools are applied directly to the painted surface, removing the
coating by reciprocating or rotating action. They have applications on any type of curved surface or
structural material. Examples of power tools include needle guns and rotary peening machines.
• Needle guns have multiple reciprocating needles powered by a pneumatic piston. Needles
are enclosed by vacuum shroud, and cutting debris is drawn towards the vacuum source
for collection. (1]
• Rotary peening machines have tungsten carbide tipped flap assembly removes coatings in
much the same way as steel shot does. Peening machines can also be outfitted with dust
collectors.
Both types of tools remove the abrasive from the waste stream, thus reducing the volume of
hazardous waste. Although more labor intensive than other alternatives, power tool technology offers lower
waste handling and disposal costs (no media enters the waste stream), and thus may be cost effective if
disposal costs are included in the decision-making process.
The following is a review of three power tool case studies, including data on cleaning rates, waste
generation, and cost per square foot and is summarized in Table 2.
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TABLE 2. CLEANING RATES, WASTE GENERATION, AND COST PER SQUARE FOOT
FOR THREE POWER TOOL BLASTING PROJECTS
Cleaning Rates Wastt Generation
Case Study (sq-ft/hf) (per sq. ft off wall cleaned) Cost per square foot
Case Study #1
Case Study #2
Case Study *3
80 220 gallons/8,600 sq. ft.
14-18 3.2 gallons
60 • 100 .75 gallons/100 sq. ft.
Not available
$3.05
$4.50
Case Study #1 - Two 4,300 square foot tanks in California were recently cleaned using needle gun
technology. Four 55 gallon drums of hazardous waste were generated, and containment of the debris was
characterized by an outside consultant as "near 100 percent". [1] The vendor estimates that conventional
blasting would have generated about 55,000 pounds of waste (an estimated 95 percent reduction).[1]
Case Study #2 - a power tool performance test was performed on a bridge in North Carolina. One-
half the bridge was sandblasted to SSPC-SP10, and on the other half power tools were used to remove the
coating down to mill scale. Material - T beam with 16" web coating system 4.2 mils thick.'2'
Case Study #3 - power tools were used to clean a 60 foot diameter spherical tank. Material - 7
mil of coating, including a red lead primer.(2)
Cryogenic Cleaning
Technology Description - cryogenic technology uses frozen C02 (dry ice) in pellet or crystal form
as the blasting media. The carbon dioxide reverts to gaseous form once the coating has been removed from
the wall, thus eliminating abrasive wastes from the waste stream.
Cryogenic cleaning is perhaps the best technology reviewed in terms of source reduction. It does
not harm the blasting surface, nor does it require a recycling system. Questions include its inability to
sufficiently score surfaces for repainting, and its removal efficiency for hard coatings (epoxies, etc.).
Table 3 provides is a quantitative/qualitative review of available data regarding abrasive
technologies, as compared to steel grit with recycling (Table 3).
Negative Pressure Containment Enclosures
Technotoov Description - a large vacuum pump induces a negative pressure gradient within the
containment area, keeping the air virtually free of dust (a conventional baghouse system is used to filter
particulates from the airstream). Blasting system operators wear air-supplied hoods while in the contained
space.
Drawbacks include the need to make a significant additional capital investment in containment
equipment, the danger of lead intoxication due to seam leakage. However, operator protective gear, such
as respirators and Tyvec™ suits, can minimize the chance of such a situation arising.
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TABLE 3. ASSESSMENT OF DEPAINTING TECHNOLOGY FOR
THE NASA LANGLEY RESEARCH CENTER
CURRENT TECHNOLOGY VS. POLLUTION PREVENTION OPTIONS
Criteria
Current Technology
Option #1
Option #2
Quantitative Data
Cleaning rate
(sq ft/hr)
Waste generation
Cost ($/ft2)
Steel grit with recycling
150
$0.95
Power tools
14- 100
.75 gal/100 sq ft
$3.05 - 4.50
Dry ice
70
$51 /ft2 (CO, only)
[Schmidtz, ASAF]
Qualitative Data
Comparability with existing
containment procedures
Waste hazard reduction
Alternative's adverse
environmental impacts
Yes
No
All media eventually
winds up as waste
Yes
No
Cutting heads must be
replaced; maintenance
for tools
No
No
CO, is released
to atmosphere
Localized Containment (Vacuum Blasting)
Technology Description - vacuum blasting allows the abrasive/debris mixture generated by blasting
to be moved directly to a storage hopper for separation and/or disposal with no area cleanup or total
containment costs incurred. [3] Vacuum blasting can be combined with continuous or non-continuous forms
of recovery/reuse technology for enhanced pollution prevention.
Advantages of localized containment include maximized worker protection, minimized fugitive
emissions, and blasting waste containment efficiencies of greater than 99 percent.
Drawbacks include the difficulty of keeping an effective vacuum seal on curved surfaces, and
operator fatigue due to the effort required to keep the shroud in place against the structural surface. Worker
education in vacuum shroud operation may help minimize leaks. [3]
Table 4 provides a quantitative/qualitative assessment of an alternative and current containment
technologies.
CROSSFEED TO OTHER TIPPP INSTALLATIONS
The blasting operations described in this report could be implemented at facilities which may have
need of blasting operations. Localized containment technologies, although not feasible for use on the
Transonic Wind Tunnel due to its unusual architecture, might possibly be implemented on job sites where
the painted surface is more regular in shape. EG&G's operators can also prove to be a valuable asset in
disseminating practical worksite experience with the new technologies to other worksites within the TIPPP
program. As is the case with NASA Langley Research Center, a number of planning studies would have to
be evaluated before the full feasibility of any technology described in this report could be evaluated.
41
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TABLE 4. ASSESSMENT OF CONTAINMENT TECHNOLOGIES FOR
THE NASA LANGLEY RESEARCH CENTER
CURRENT VS. ALTERNATIVE
Criteria
Current
Alternative
Quantitative Data
Containment efficiency
Negative pressure containment enclosure
Not Available
Localized Containment
95 • 99%
Qualitative Data
Compatibility with existing
operating procedures
Waste hazard reduction
Treatment/disposal cost
reduction
Safety hazard reduction
Effect on operation quality
Yes
Good
Good
No
Very Good
Yes
Good
Very Good
Yes
Very Good
MEASUREMENTS OF POLLUTION PREVENTION
Measuring the impacts of pollution prevention activities requires baseline data on wastes and their
disposal costs, as well as installation, operation and maintenance, and labor and overhead costs for each
blasting operation. Much of this background data were not available from the NASA Langley Research
Center. Table 5 provides a list of facility information required to conduct a PPOA and the documents
wherein the information is contained.
Before a final recommendation can be made about which of the technologies presented in the report
best fits a specific worksite's needs, a complete facility database must be assembled and analyzed. In
addition, criteria similar to those in Tables 3 and 4 should be used to evaluate the application of pollution
prevention techniques.
IMPLEMENTATION
All of the technologies presented in this report are available commercially, and thus their application
is limited only by the respective technologies. For instance, cryogenic cleaning has great potential because
of its pollution prevention capabilities, but cannot be used where no previous surface profile exists.
Localized containment, while possessing excellent pollution prevention characteristics, is difficult for the
operator to hold in place, and difficult to use when the painted surface is not absolutely flat. Combinations
of technologies may be used to overcome certain limitations, as evidenced by NASA experience.
Other initiatives, such as new coating re-formulation, may be hindered by organizational resistance
to change. Technical obstacles such as specifications for longevity and corrosion protection exist. Also,
the cost of any pollution prevention program may exceed a facility's ability to implement it, despite the
certainty of overall program cost benefits due to reduced waste disposal and contamination costs.
42
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TABLE 5. FACILITY INFORMATION FOR POLLUTION PREVENTION ASSESSMENTS
Information Required
Location
Design Information
Environmental Information
Raw material
Economic Information
Other Information
Process flow diagrams
Material/heat balances
Operating manuals/process descriptions
Equipment lists
Equipment specifications and data sheets
Piping and instrument diagram
Plot and elevation plans
Equipment layouts and work flow diagrams
Hazardous waste manifests
Emission inventories
Biennial hazardous waste reports
Waste analyses
Environmental audit reports
Permits and/or permit applications
Material application diagrams
Material safety data sheets
Raw material inventory records
Operator data logs
Operating procedures
Productions schedules
Waste treatment and disposal costs
Utility and raw material costs
Operating and maintenance costs
Departmental cost accounting reports
Company environmental policy statements
Standard procedures
Organizational charts
43
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Finally, pre-existing contracts for materials or depainting systems may exist which preclude the
implementation of superior technologies for the foreseeable future. The extent to which these barriers
obstruct change will ultimately determine the success of blasting system pollution prevention operations at
TIPPP installations.
RESEARCH DEVELOPMENT AND DEMONSTRATION (RD&D) NEEDS
In order to make definitive choices based on sound pollution prevention practice, and to provide
the data necessary to make such choices in the future, NASA Langley Research Center should undertake
a number of RD&D studies. These would involve taking test stretches of typical structures and materials
at the Center and subjecting them to the various depainting technologies described above. Parameters such
as cleaning rate, overall waste generation, containment, and cost could then be compared under conditions
unique to the Center.
New technologies are constantly being made available that may be preferable for some applications
to any of the technologies listed in this report. The Steel Structures Painting Council is an excellent source
of information regarding state-of-the-art technology and case study reviews. Periodic assessment of new
technologies should also be done before any major new investments in depainting technologies are made.
RECOMMENDATIONS/CONCLUSIONS
A pollution prevention opportunity assessment was performed on the depainting operation at NASA
Langley Research Center in September, 1991. A review of the operations currently being conducted by
EG&G was performed, and documentation of their current system and process operations was obtained.
More specific data on waste generation, cleaning rates, and costs is needed to refine the pollution
prevention activities proposed in this report. Two types of technology based pollution prevention techniques
were identified:
• Source Reduction Opportunities
Re-formulate new coatings to eliminate toxic hazard and minimize coating volume
Use cryogenic cleaning where surface profiles already exist (e.g. those previously
grit blasted or rotary peened)
• Containment Opportunities
Use localized containment when feasible
In addition, sustained operator education efforts will continue to minimize fugitive emissions from
the worksite.
NASA Langley Research Center, through its contractor (EG&G), already employs a number of
recommended source reduction and containment technologies. Although NASA is currently employing
pollution prevention activities resulting in the reduction of hazardous waste, additional data is needed to
determine the overall "best available technology". The case study cited in this report details the type of
pollution prevention study which should be conducted at NASA. This would result in direct comparative data
which translates into potentially increased volume reduction of hazardous waste at NASA.
Other commercially available technology options were identified in this report. Additional future
pollution prevention activities should include a review of these technologies to determine future potential
implementation feasibility at NASA.
44.
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REFERENCES
1. Colborn, K.A. Dustless Needle Guns to Remove Lead Paint from Water Storage Tanks. Prepared
for the Steel Structures Painting Council - Fourth Annual Conference on Lead Paint Removal from
Industrial Structures. March, 1991.
2. Bloemke, D.T., of Desco Manufacturing Co. State-of-the-Art Power Tool Cleaning in Dust-Free
Environments. Prepared for the Steel Structures Painting Council - Fourth Annual Conference on
Lead Paint Removal from Industrial Structures. March, 1991.
3. Rex, J. "A Review of Recent Developments in Surface Preparation Methods," Journal of Protective
Coatings and Linings, Vol 7, No. 10, October 1990, pp.50-58.
45,
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September 1, 1992
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
LABORATORY WASTES AT THE
NASA LANGLEY RESEARCH CENTER
HAMPTON, VIRGINIA
by
Kevin Palmer
Science Applications International Corporation
Falls Church, VA 22043
Contract No. 68-C8-0062, WA 3-70
SAIC Project No. 1-0824-03-1021-013
Project Officer
Mr. Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U. S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
46
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INTRODUCTION
The U.S. Environmental Protection Agency (EPA), the Department of Defense (DoD), and the
National Aeronautics and Space Administration (NASA), are developing a pollution prevention model
community project in the Tidewater, Virginia area. The Tidewater Interagency Pollution Prevention Program
(TIPPP) includes Langley Air Force Base, Norfolk Naval Base, Ft. Eustis (Army), and NASA Langley Research
Center (LaRC). Under TIPPP, the participants are identifying, studying, and implementing alternative
practices that will reduce wastes, emissions and adverse environmental impacts at these facilities.
This report summarizes a pollution prevention opportunity assessment conducted with NASA
representatives at the Langley Research Center in Hampton, Virginia as part of TIPPP. EPA supported
TIPPP facilities as part of its on-going Waste Reduction Evaluations at Federal Sites (WREAFS) Program.
This assessment was funded by EPA and was conducted in cooperation with LaRC officials. The WREAFS
Program is focused on identifying and developing management protocols as well as technical changes that
might reduce waste at LaRC. This report has been developed to describe pollution prevention techniques
that may be applicable to other similar governmental and industrial facilities.
The purpose of the WREAFS Program is to identify and promote use of pollution prevention
techniques and technologies through technology transfer. Under the WREAFS Program, innovative pollution
prevention techniques/technologies are identified through an initial opportunity assessment for a specific
process or operation. Various prevention opportunities and alternatives may then be evaluated through
research, development, and demonstration (RD&D) projects. In the past, EPA has initiated and conducted
both individual and joint RD&D projects that investigate pollution prevention alternatives. The results of
these projects are then presented to both the public and private sectors through various technology transfer
mechanisms, including: project reports, project summaries, conference presentations, workshops, and EPA
information clearinghouses, libraries, and document repositories.
As part of the WREAFS Program, pollution prevention opportunities are assessed using the
procedure described in the EPA Waste Minimization Opportunity Assessment Manual (EPA/625/7-88/003).
An opportunity assessment consists of the following phases:
Planning and Organization - organization and goal setting
Assessment - careful review of a facility's operations and wastestreams and the
identification and screening of potential options to minimize waste
Feasibility Analysis - evaluate the technical and economic feasibility of the options sete
cted and subsequent ranking of options
Implementation - procurement, installation, implementation, and evaluation (at the
discretion of the host facility).
Many of the opportunities identified during WREAFS projects involve low cost changes to equipment and
procedures that may be employed at other federal facilities or in private industry. These pollution prevention
opportunities can often be implemented by the facility without extensive engineering evaluations. Other
opportunities identified during these projects will require further study before full implementation can be
realized. Typically, opportunities requiring further evaluation are those that have the potential to affect the
process and/or require the use of new procedures or equipment. In such cases, it may be necessary to
conduct demonstration projects to generate detailed data on the feasibility of the option.
47
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As part of the WREAFS Program, pollution prevention opportunities were assessed at LaRC in the
spring and fall of 1991. The assessment team consisted of EPA Risk Reduction Engineering Laboratory
(RREL) and contractor staff. The assessment team met with representatives of LaRC's Safety and
Environmental Management Section to determine the goals of the pollution prevention opportunity
assessment. At this meeting, the participants decided that the assessment would focus on a general, facility-
wide assessment of laboratory waste generation and management practices.
PROCESS REVIEW
LaRC is located in Hampton, Virginia occupying 787 acres of government-owned land. The facility
shares aircraft runways, utilities and some facilities with neighboring Langley Air Force Base. An additional
3,200 acres of marsh land is under permit to LaRC and is used as a test range for model aircraft. More than
3,000 employees conduct research and/or work at LaRC in approximately 190 buildings including
laboratories, wind tunnels, workshops, and offices.
In initiating the pollution prevention opportunity assessment, the first effort focused on understanding
those activities that resulted in waste operation. The nature of these activities provided insight into the
specific types of wastes and potential pollution prevention alternatives. A summary of the types and volumes
of waste generated was used to identify those operations of greatest concern that may be amenable to
pollution prevention. As part of the LaRC assessment, therefore, both the general site activities and types
of wastes generated were characterized.
Site Activities
LaRC's primary mission is basic research in aeronautics and space technology including
aerodynamics, material sciences, structures, flight controls, information systems, acoustics, aeroelasticlty,
atmospheric sciences, and nondestructive evaluation. Approximately 60 percent of LaRC's efforts is in
aeronautics, relying on over 40 wind tunnels and other unique research facilities as well as computer
modeling capabilities which aid in the investigation of the full flight range - from general aviation and
transport aircraft through hypersonic vehicles. Various research efforts include:
• Studying improved flight control systems to aid aircraft in operating more efficiently in ail
kinds of weather and in crowded terminal airways;
• Examining wind shear, the cause of nearly 40 percent of U.S. airline fatalities; and
• Evaluating the National Aero-Space Plane to expand the limits in hypersonic (Mach 5-25)
engines, heat-resistant materials, and supercomputers for engine and airframe design.
The additional 40 percent of LaRC's work supports the national space program studying
atmospheric and earth sciences, developing technology for advanced space transportation systems,
conducting research in laser energy conversion techniques for space applications, and providing the focal
point for design studies for large space systems technology and Space Station Freedom activities. Various
research efforts include:
• Managing data analysis from the Long Duration Exposure Facility (LDEF), retrieved from
low-Earth orbit, where it exposed a wide variety of candidate space materials, optics,
coatings, and other items to prolonged presence in space;
• Doing extensive work on the structure, aerodynamics and thermal protection for the Space
Shuttle and contributed significantly to the return-to-flight effort that launched Discovery;
48
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• Managing an extensive program in atmospheric sciences, seeking a more detailed
understanding of the origins, chemistry and transport mechanisms that govern the Earth's
atmospheric data using aircraft, balloon, and land- and space-based remote sensing
instruments designed, developed, and fabricated at LaRC.
• Contributing to remote sensor technology for the Earth Observing System (EOS), the first
phase of the international Mission to Planet Earth. EOS is envisioned as a network of up
to five equatorial and four polar orbiting research satellites.
LaRC's record of accomplishments has made it a leader in diversified aeronautics and space research.
These varied research activities result in various types of laboratory wastes that may pose threats to human
health and the environment.
Waste Generation
Since LaRC includes a variety of individual laboratories, the majority of wastes are generated in
relatively small quantities from laboratory research. Specifically, LaRC research results in spent chemicals,
experiment residuals, and expired shelf-life chemicals. Further, most LaRC research activities may include
common lab wastes such as solvents, used oils and gas cylinders; due to it's "cutting edge" research it may
also generate exotic chemicals and materials (e.g. resins, composites, ceramics, etc.). in the past, such
research activities have resulted in wastes requiring offsite hazardous waste disposal. Table 1 shows the
types and quantities of waste generated. The 1991 waste disposal budget for LaRC was approximately
$460,000. The types and amounts of wastes provide some opportunities for pollution prevention initiatives.
These opportunities are discussed in the sections that follow.
ASSESSMENT
The LaRC pollution prevention opportunity assessment focused on the hazardous materials usage
and resulting waste management. In general, the hazardous materials handling, usage, and disposal
protocols of the facility was reviewed to identify any opportunities to reduce the amounts of hazardous waste
generated and disposed. The assessment team sought to identify methods that would not limit or hinder
current (or required) activities or and its researchers. The general pollution prevention opportunities that
were identified as part of this assessment are described in the section below.
Several of the researchers at LaRC use the High Pressure Liquid Chromatography (HPLC) analytical
method. A pollution prevention assessment conducted at the Department of Agriculture's Beitsville research
facility concerning HPLC has been developed in a previous WREAFS project. Since LaRC researchers were
interested in this assessment and the possible applications it might have on their HPLC usage, a brief
discussion of general prevention techniques presented in that report is provided.
In conducting the assessment, several laboratory facilities were visited within the LaRC. In general,
the nature of hazardous materials handling and usage depended upon the complexity and types of research
conducted. The large variety of laboratories, varying research foci, and different waste types prevented
identification on opportunities related to specific techniques. Rather, the emphasis was on providing LaRC
with a general discussion of prevention techniques that might prove valuable for all of its laboratory facilities.
In addition, this assessment was intended to identify laboratory operations that, upon future study by LaRC,
might provide reduction opportunities. With the goal of providing LaRC researchers with a general
discussion of prevention opportunities, the team studied several laboratories that were identified as
representative of the various sizes and complexities of most
-------
TABLE 1. HAZARDOUS LAB WASTE STREAMS AT NASA
Chemical Groups jotai
Solvents 3630 ga|
Lab Packs 195 boxes
Used Oils 30oo gal
Spent Gas Cylinders #
n-pentafluoroethyl 2
isobutyiene 12
vinyl chloride g
ammonia, anhydrous 14
sulphur dioxide 14
carbonyi sulfide 10
phosgene 2
mercaptan 2
methane 5
methyl chloride 8
difluoroethylene 4
dimethyl ether 4
ethyl chloride 4
ethylene oxide 4
trimethyl tin 2
argon hydrogen sulfide 2
monomethylamine 3
lithium metal 8
unknown 20
Notej:
The number of cylinders were generated between August 1990 and March 1991. All other waste quantities were estimated based
upon manifests for the same eight-month timeframe. Waste volumes identified above do not reflect amounts of materials if any
directly released to the environment (!.•., volatilized, spilled, etc.) during use or storage.
research labs at LaRC. Specifically, this document addresses the following topics related to the reduction
of general laboratory wastes at NASA:
• current management activities aimed at reducing waste
• general pollution prevention techniques
• implementation of general pollution prevention alternatives
• prevention opportunities for specific laboratory functions
-------
Current Management Activities Aimed at Reducing Waste
The LaRC Safety and Environmental Management Staff oversees an extensive hazardous waste
management program. Since individual laboratories generate relatively small quantities of wastes, LaRC
consolidates lab wastes into lab packs at collection points in each laboratory facility. The operation of each
collection point is maintained by the research staff. Specifically, each research facility identifies a hazardous
waste officer who is responsible for the lab's accumulation area. The hazardous waste officer is responsible
for proper use of the collection point with respect to storage of hazardous materials prior to disposal.
LaRC has distributed responsibility for materials handling to the individual laboratories. As such,
hazardous materials usage, handling and awareness concerning the potential impacts of hazardous
chemicals tended to vary according to the type of research facility. Those facilities that primarily function
as wet laboratories and use a large variety of chemicals tended to have more sophisticated hazardous
materials tracking and handling procedures. For example, the composite materials laboratory in Building
1293 has established a program and computer system to track and manage hazardous materials. The
process was designed to help the laboratory meet health, safety, and compliance requirements, but could
be used to:
• Reduce toxic materials usage;
• Conduct mass balances to reduce emissions;
• Provide a model for other research labs to develop similar materials tracking systems;
• Function as an initial model for a Center-wide materials management network;
• Provide this research lab an opportunity to transfer excess chemicals to other laboratories
onslte or sell excess chemicals through a regional waste/materials exchange.
Building 1293 provided a good example of how hazardous materials can be managed and tracked within
a laboratory. The organization at this facility could be used as a template for all other facilities.
Various activities have been initiated at LaRC research facilities that may result in either source
reduction or recycling of wastes generated in laboratory operations. For example, the LaRC environmental
staff have already initiated an effort to segregate and recycle oils generated at the various laboratory
facilities. Further, the LaRC purchasing organization encourages its laboratories to use existing chemical
supplies before purchasing materials. Materials exchange or transfer is promoted through use of Center-
wide electronic mail and on-line chemical inventories. Finally, in some laboratories, LaRC personnel were
aware of the potential impacts of certain chemicals and were proactively investigating substitutes, especially
for chlorofluofocarbons.
General Pollution Prevention Techniques
WhHe evidence was found of existing pollution prevention efforts at the Center, there was not a
uniform understanding of reduction concepts among the researchers interviewed. As such, to fully
appreciate and capitalize on specific pollution prevention opportunities, LaRC personnel must first become
more aware of prevention concepts and their potential impact on the environment. A number of references
related to laboratory pollution prevention were identified during the course of this project. The American
Chemical Society (ACS) is a leader in studying and promoting methods to reduce laboratory wastes. ACS
has published two documents that provide useful information: The Waste Management Manual for
Laboratory Personnel (1990), and Less Is Better. Laboratory Chemical Management for Waste Reduction
5*
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(19851). Further, EPA has published a document that describes applicable reduction techniques: Guides to
Pollution Prevention. Research and Educational Institutions.(EPA7625/7-9Q/Q1Q 1990).
EPA has estimated that the total amount of hazardous waste generated by research/educational
institutions is from 2,000 to 4,000 metric tons per year, less than 1 percent of the national total of hazardous
waste generated annually. Most of these facilities generate small quantities of a wide diversity of wastes,
and the types of waste generated may vary over time. The references above provide a number of generic
"common-sense" approaches to laboratory pollution prevention including both source reduction and
recycling methods. Examples of these methods are provided in Table 2. In addition, while source reduction
and recycling methods are generally the preferred waste management technique, treatment can be an
integral component of any laboratory waste management program. The American Chemical Society's (ACS)
Waste Management Manual for Laboratory Personnel (1990) discusses in-lab treatment of hazardous waste
that does not require the laboratory to have a (TSO) permit.
Implementation of General Pollution Prevention Alternatives
Although there are unique impediments to pollution prevention at laboratory facilities in general,
LaRC can promote pollution prevention concepts through various efforts. The pollution prevention process
is in the beginning stages at LaRC. Initially, LaRC personnel must gain a complete understanding of waste
generating processes at the site. The waste tracking system contains information on waste generation (by
building), yet the system does not report the quantities of wastes generated by individual processes. Until
individual waste streams are identified and quantified, LaRC personnel will be unable to determine the full
extent of existing pollution prevention opportunities. Additional information will be needed to develop any
comprehensive pollution prevention program for the center.
Even without these data, LaRC could consider a number of pollution prevention initiatives.
Specifically, they could increase control over the purchase and use of toxic materials through a centralized
purchasing and warehousing system. Chemical orders are currently sent through a central purchasing
department, but research and purchasing personnel are not instructed (or trained) to identify material
substitutions (i.e., identify and procure less hazardous materials). Procurement personnel cannot order less
hazardous materials when specific materials are requested by researchers. Responsibility for identifying less
hazardous substitutes for laboratory uses lies with researchers. Procurement personnel, however, can be
trained to identify and purchase less hazardous materials for non-research functions. The initial components
of a systematic hazardous materials procurement and management procedure and computer tracking
system already exist within some sectors of the Center.
Purchasing personnel do not have a procedure to limit or eliminate duplicative orders to avoid
stockpiling of hazardous materials that might subsequently require disposal after shelf-life expiration. Under
the current procedure, each laboratory places orders through the purchasing staff without cross-checking
the chemicals currently stocked in other laboratories. LaRC's expansion of the central purchasing system
in conjunction with establishing a central chemical warehouse is one potential solution to this problem.
Common laboratory chemicals such as solvents would be available immediately from a central location and
dispensed in quantities required by laboratory researchers. This would minimize wastes generated from
unused surplus. The central purchasing staff could be augmented with a pollution prevention procurement
official who, understanding chemical acquisition and use throughout the facility, could police product
substitution measures.
52
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TABLE 2. EXAMPLES OF SOURCE REDUCTION AND RECYCLING OPTIONS
Pollution Prevention Techniques
Pollution Prevention Options
Waste Stream Segregation
Inventory Controls
Proceus or Equipment Modifications
Raw Material Substitution
Recycling
Training
Segregating hazardous and non-hazardous wastes.
Ordering chemicals in smaller containers in order to reduce onsite inventory and
unused surplus.
Conducting inventory control from cradle to grave onsite.
Providing central warehousing for storage and distribution of chemicals to minimize
excess inventory in individual labs leading to excess surplus.
Using smaller scale operations including microscale techniques. Such microscale
approaches are not universally applicable to all experiments. Certain reactions, for
example, may overheat and are more difficult to control when using microscale
quantities.
Reducing the amount of solvent used to rinse equipment.
Modifying specific experiments either by substituting non-hazardous or less toxic
chemicals, using different analytical equipment, or improving the efficiency of yields.
(Instrumental analysis can use 1/10 to 1/100 the volume typically used in wet
chemistry techniques.)
Substituting detergents, potassium hydroxide, or sonic baths for chromic acid
solutions used to clean glassware.
Reusing spent solvents in applications where purity standards are less critical, such
as performing initial cleaning of glassware with spent solvent from the final rinse of
previous cleaning operations (cascade reuse).
Using spent acids and solvents on routine maintenance of buildings.
Providing all employees with education on pollution prevention. For example,
laboratory technicians who manage hazardous residuals should be trained in proper
waste segregation and disposal practices. Researchers should be instructed on the
adverse impacts research activities may have on the environment and possible
strategies to design research projects that result in minimal waste and release of
chemicals to the environment.
The key to reducing wastes at a laboratory facility rests in educating the personnel to be conscious
of the amounts of waste they generate. In general, the chemical user may have some control over the
volumes of waste produced but may not consider their relatively small individual volume a problem. They
may not realize that all of the laboratories are contributing a relatively small amount to a cumulatively large
problem. LaRC inform its researchers of waste issues and steps to reduce individual generation rates. To
institutionalize pollution prevention, LaRC staff should consider the options discussed in Table 3. These
options have been qualitatively ranked in Table 4.
These efforts would target the impiementation of simple practices which would increase the
awareness of the individual researchers. By incorporating waste reduction into routine laboratory activities,
LaRC personnel can succeed in promoting waste reduction in all aspects of the facility. In the long-term,
researchers may begin to incorporate waste reduction practices into their experimental design and
implementation.
53
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TABLE 3. LaRC POLLUTION PREVENTION OPTIONS
Pollution Prevention Techniques
LaRC Options
Training and Assessments
Process or Equipment Modification
Waste Segregation
Pollution Prevention Policy
Expand on the existing pollution prevention ethic with further education and training.
Successful efforts are already underway including paper recycling and source
reduction in individual operations.
Appoint a pollution prevention "officer" within each research institute to assist
researchers with reduction and recycling initiatives. Pollution prevention
representatives from all the institutes could meet periodically to discuss and compare
efforts among institutes. Such information transfer is crucial for the adoption of
pollution prevention throughout the LaRC and reduces repetitive pollution prevention
development efforts.
Develop and implement a plan to conduct periodic laboratory pollution prevention
laboratory assessments using suitable, in-house expertise. Such assessments may
uncover additional pollution prevention opportunities over time, emphasize NASA's
commitment to pollution prevention and can be used to monitor the success of
pollution prevention efforts.
Keep abreast of commercially available technology changes as they relate to
laboratory pollution prevention. When new technology is too expensive for individual
labs to implement, consider pooling resources and locating instruments at a
centralized facility which may be used by several laboratories.
Reduce atmospheric emissions of chemicals from laboratories as part of a
comprehensive pollution prevention program. Glassware and automated extraction
systems are commercially available which will reduce these emissions. In addition,
for some samples, emissions can be reduced through solid phase extraction
techniques as opposed to classical liquid evaporation techniques that result in the
release of the solvent carrier into the fume hood and subsequently to the
atmosphere.
Segregate hazardous from non-hazardous wastes. Hazardous waste volumes are
often unnecessarily increased due to the addition of non-hazardous wastestreams.
Segregation alone can significantly reduce hazardous waste generation rates and
disposal costs.
Require each lab to have a written waste management/reduction policy. Minimum
requirements would include annual chemical inventories, the dating of chemicals as
received, etc.
If LaRC institutes a charge-back policy, they might consider encouraging laboratory
chiefs to pool resources previously spent on hazardous waste disposal for the
purchase of pollution prevention equipment or technologies (i.e., computers for
inventory control, centralized solvent recovery stills, or new waste minimizing
analytical equipment.
Prevention Opportunities for Specific Laboratory Functions
The objective of this assessment was to survey various types of laboratories to identify general
prevention opportunities and subsequently provide NASA with some documentation concerning options.
Also, the assessment was designed to provide LaRC researchers and environmental staff with specific
pollution prevention concepts in order that they could perform more detailed analyses of commonly used,
waste generating operations. These detailed pollution prevention assessments are being identified and
initiated as part of LaRC Pollution Prevention Program Plan, currently under development.
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As mentioned previously, researchers in the Center's wet laboratories were interested in
understanding pollution prevention techniques that might apply to High Pressure Liquid Chromatography
(HPLC) analyses. Further, providing LaRC with an example of a more detailed discussion of pollution
prevention concepts as they might apply to a specific laboratory operation was desired. Based upon an
assessment performed at the USDA Beltsville Agricultural Research Center (BARC), a discussion of pollution
prevention techniques for HPLC usage by LaRC personnel was developed. The following discussion is
presented to demonstrate the possible results of a more detailed assessment.
High Performance Liquid Chromatography (HPLC)
HPLC is widely used in routine analyses. In contrast to gas Chromatography (GC), HPLC is capable
of analyzing up to 20 percent of all known organic compounds, and would potentially analyze 60 to 70
percent of compounds analyzed by LaRC researchers. GC requires compounds to be relatively volatile and
thermally stable, while HPLC can be used to perform analyses of low volatility compounds at room
temperature. HPLC techniques are becoming much more important in the analyses of environmental
samples. In 1988, EPA formed an HPLC Methods Development Group. This group works to develop HPLC
methods for analytes that currently, cannot be detected and also to develop better methods of employing
HPLC over existing techniques.
Some laboratories at LaRC rely upon HPLC in their research. Like other forms of Chromatography,
HPLC is used to separate, isolate, and identify components of mixtures. Sample components separate on
a column containing solid adsorbent based on differing affinities for the packing material. The solvent
system carries the sample through, separates the materials in the column, and washes separated fractions
off the column. A pump provides the required solvent flow, while sensitive detectors identify and quantify
eluting compounds. Sample extraction, HPLC analyses and other operations at LaRC result in solvent and
sample wastes. In 1990 alone, LaRC personnel disposed an estimate of 3,600 gallons of solvent waste.
HPLC samples, solvents, and sample preparation solvents were major contributions to this total waste
volume.
There are numerous laboratories at the LaRC facility undertaking a variety of research oriented
problems. Each lab uses specific sample preparation procedures and analyses. Based on comments
received from interviews with LaRC personnel during the assessment, two general practices were identified
that may provide opportunities for waste reduction: sample preparation and the HPLC analysis.
Sample Preparation
The sample preparation step isolates either components of interest or interferents from the sample
matrix prior to analysis and quantitation by HPLC. LaRC personnel routinely perform liquid-liquid or solid-
liquid extraction; extracting aqueous samples with an organic liquid, and solid samples directly with solvent.
Often, LaRC personnel rely upon secondary extractions of the sample extract or the sample itself.
The two basic types of sample preparation are analytical (small scale) and preparative (large scale).
The type employed depends upon the researcher's specific needs and goals. As its name implies,
preparative procedures apply to the generation of large quantities (i.e., gram-scale) of material. This amount
may be used to support numerous and varied sample analyses or to provide a purified component in
sufficient quantity. Preparative processes command large sample sizes and solvent volumes; consequently,
large sample wastes are generated.
In contrast, analytical preparations involve small scale processes, with the primary aim concentrating
on sample information and identification rather than production. Additionally, these steps and studies are
usually the precursors to the preparative stage. The focus on sample information/identification emphasizes
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the concern of analyte detection and therefore of analyte concentration in analytical preparation steps. To
increase analyte levels, concentration steps are employed. The most common involves evaporation to
dryness and redlssolutlon. Different concentration factors depend upon the initial and final sample volumes.
As an example, a sample volume of 2 to 3 L is concentrated to 10 to 100 mL The resultant factor achieved
is between one to two orders of magnitude. The higher analyte levels allow easier detection by HPLC.
As previously discussed, LaRC researchers engage in the analyses of varied samples and
components. As an example, for an analysis that relies on a chloroform extraction, the sample is initially
prepared by extraction with solvent. Afterwards, the analyst distills under vacuum the organic solvent, and
the redissolves the extract distillate. The analyst discards the distilled solvent as hazardous and proceeds
with the HPLC analyses. This example typifies the sample preparation step. The following sections consider
possible pollution prevention ideas to minimize wastes generated from sample preparation.
Source Reduction-
As a result of the BARC assessment, two source reduction techniques were identified for sample
preparation procedures that might result in reduced waste. They consist of solid phase extraction (SPE)
and supercritical fluid extraction (SFE). SPE utilizes small disposable extraction columns containing sorbent.
Columns are available commercially, and with a variety of sorbent types. The sample solution is introduced
to the cartridge (or a filter) and either anaiytes of interest or interferents are selectively concentrated on the
sorbent. The bound components can then be eluted off the column using a solvent with a higher affinity
for the analyte than the sorbent. Separation, purification, and concentration of anaiytes of interest therefore
occur based on the bonded silica chemistry of the sorbent. Cartridge costs range between $1.50 to $3.00
each.
SPE offers substantial savings compared to typical liquid-liquid extractions through reduced disposal
costs. Estimates of reduced solvent usage by 98 percent are contained in one manufacturer's literature, and
other literature indicates that 1 to 2 ml of solvent and a SPE filter accomplishes the same function as would
200 to 300 mL of solvent used for a direct extraction. While SPE should be useful in reducing wastes for
LaRC, its application for pollution prevention is limited to aqueous solutions. Scientists at LaRC routinely
use solvents to extract certain constituents from samples. In these instances, organic solvent use is required
to solubillze or extract the constituents of interest from a sample. SPE in these cases would only be useful
regarding pollution prevention if further component classification or purification is needed. Clearly, SPE
usage lies in the domain of analytical sample preparation.
SFE is an innovative technique that offers great promise for replacing chlorinated solvent extractions
in the near future. SFE requires a highly compressed gas above its critical temperature and pressure points.
The gas is transformed into a supercritical fluid exhibiting high diffusion coefficients and low viscosities
(relative to a liquid). These properties allow for very efficient transfer of solutes from the sample matrix into
the supercritical fluid. Carbon dioxide is typically used and modifiers may be added to selectively extract
fractions or compound classes from a sample. Varying the temperature and pressure (density) of the
supercritical fluid can also allow for very selective extractions. For example, low density C02 extraction is
similar to hexane, whfle higher density C02 extracts similar to benzene. SFE also offers shorter extraction
times compared to organic solvents. After the extraction, supercritical C02 returns to a gaseous state at
room temperature and pressure.
The benefits of SFE have been documented in various journals and trade magazines. When
extracting hexadecane and chlorobenzene from diatomaceous earth, the standard Soxhlet extraction
required a 20 to 40 gram sample and 300 mL of freon™. The analogous SFE method used 2 to 5 grams of
sample and only 6 mL of freon. Extraction speed was increased with SFE, and the "cost of the analysis
dropped from $12.50 for the standard Soxhlet extraction to $1.65 for SFE..." Another article states that a
Soxhlet extraction using 450 mL of organic solvent varying in cost between $1.60 and $3.00, can be'
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replaced with SFE methods at a fluid cost of $0.10. An additional $0.90 per extraction is required to dispose
of the Soxhlet organic solvent, while no disposal costs are involved with SFE. This article further states that
assuming an SFE instrument expenditure of $30,000, and based on an average workload of 150 extractions
per week, the payback period would be less than 1 Vfc years.
Various groups within EPA are currently studying SFE. Some EPA environmental laboratory
methods will soon incorporate SFE into analytical methods. While the outlook for SFE looks very positive,
additional research as well as formal method validation and promulgation is required before this technique
becomes universally accepted and used. In addition to the concepts discussed previously, micro-extraction
techniques should be used whenever feasible to reduce solvent usage and hazardous waste generation.
Recycling-
Although source reduction methods are highly preferred over recycling for pollution prevention
purposes, recycling methods do play an important role. Distillation and reuse of waste organic solvents from
sample preparation procedures may be feasible. Recycling is an issue of concern for LaRC researchers in
that recycled solvents may not provide purity required for analyses. Currently, however, some LaRC
researchers are distilling and reusing these spent extraction solvents. As such, LaRC researchers should
identify those operations where recycled spent solvents can be used.
The distillation or rotary vacuum evaporation of spent extraction fluids should yield a virtually clean
solvent for reuse. The solvent purity is achieved through the differing boiling points of the solvent and
impurities. Since the impurities are biological and tend toward high molecular weights, they should have
a small or negligible vapor pressure. Conversely, the low molecular weight solvents have much higher vapor
pressures. A simple distillation under vacuum should separate the solvent cleanly from the biological
impurities. A vacuum lowers the heat requirements for the distillation; and, thereby minimizes thermal
degradation and subsequent distillation of biological impurities.
The efficacy of the distillation depends on the spent fluid composition. A mixture containing solvents
of similar boiling points yields a clean but compositionally impure liquid. As such, spent extraction solvents
should be bulked and categorized prior to distillation. This preliminary effort should produce a clean and
compositionally pure distillate. The purity of the distilled liquid can be checked by injecting a sample into
a gas chromatograph (GC) or by using a refractive index detector.
HPLC Analyses
HPLC analyses generate hazardous wastes through the solvents employed as the carrier media.
This fluid provides the essential vehicle for sample transport through the HPLC instrumentation. The solvent
delivery system pumps the aqueous/organic mixture through the injector, the column, and the detector.
The resulting effluent is a blend of the sample and the initial influent liquid. Acetonitrile, methanol, and
tetrahydrofuran typifies the organic portion of the media. As such, HPLC effluents are characteristically
flammable and therefore hazardous.
Pollution prevention in HPLC begins with an understanding of how the separation process proceeds.
The goal of the analyst is to achieve the best separation in the shortest time. To obtain this separation, the
analyst can optimize the following variables:
• Mobile Phase Composition
• Stationary Phase Composition
• Temperature
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• Flowrate
• Column Configuration
• Particle Size
Each of these factors play a significant role in achieving the desired level of separation. The first three
variables control the elution time of the component (i.e., the time taken between component injection and
detection). The last three variables control the width of the peak. As the peak narrows, detection sensitivity
increases since the signal level rises above the detector's instrumental noise level. Conversely, as the peak
broadens, the analyte signal mires in detector noise. Further, fast and slow eluting compounds will intuitively
possess a corresponding narrow and broad peakwidth. The ensuing cumulative objective is therefore the
segregation of analytes through time (elution time) and space (peakwidth).
The variables affecting the analyte elution time and peakwidth intermingle. The injected analyte has
a relative affinity for both the mobile phase (solvent) and the stationary phase (column packing). A stronger
affinity for the mobile phase yields a short elution time and narrow peakwidth, whereas a stronger affinity
for the stationary phase yields a long elution time and broader peakwidth. To separate two or more
components, their elution times must be different and their peakshapes must have minimal overlap.
Additionally, the analyte exiting the column must be within a specific concentration range dependent upon
the analyte and the type of detector being used. This ensures analyte detection.
By manipulating the parameters, the analyst obtains a separation within the shortest analysis time.
This creates a higher sample throughput since more analyses can be done in an allotted timespan. More
importantly, solvent waste is lowered because the generated waste volume (column flowrate x run time x
# analyses) is minimized.
Source Reduction-
HPLC source reduction occurs from the minimization of solvent use. This impacts several areas,
but in general, focuses on the column processes and the instrumentation involved. A typical column
contains 5 micron packing material and is configured at 4.6 mm i.d. x 25 cm length. Further, the typical
column flowrate is approximately 1 mL/min. By switching to a different column internal diameter while
holding the column length and particle size constant, solvent flowrate is reduced and separation integrity
mairntained. The comparisons are shown below:
Flowrate Comparisons
Column Dimensions Flowrate
ll.d.. fmm) x length (cm) [mL/min]
4.6x25 10
2.0 x 25 0.2
1-0x25 0.05
Narrowing the column bore effectively reduces solvent consumption. However, other effects are created
by modifying the column configuration. A narrower column (and therefore smaller volume) contains less
packing material. Consequently, smaller sample sizes (and analyte levels) must be injected to prevent
column overloading. On the contrary, this may be advantageous since a minimal sample amount reduces
waste at the sample preparation step.
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To increase sensitivity when using a smaller column, the analyst may also choose to reduce the
packing particle size from 5 to 3 micron. This change enhances sensitivity by narrowing the analyte
peakwidths. Further reductions in solvent consumption can then be attained if the column length is
diminished. A shorter column length produces shorter elution and analysis times, while still maintaining
adequate resolution.
Assuming an average laboratory performs 50 HPLC analyses per month with an average run time
of 20 minutes, switching to a 2.0 mm i.d. column would result in a reduction of 2.5 gallons of hazardous
waste generated per year. With HPLC solvent costs of $50 to 100 per gallon, and disposal costs of $5 to
10 per gallon, the method described above may result in significant economic gains when applied (if
possible) on a facility-wide basis. If the column is reduced to a 1 mm i.d., other changes must be
implemented to retain a required separation. The detector cell volume must be minimized from a standard
8 jjL This change is needed because the elution volume of the analyte has been lowered. A lowered
detector cell volume is required to give an accurate portrayal of the analyte peak. Additionally, the injection
volume must be less than 1 /jL An injection volume greater than 1 /jL may change the composition of the
mobile phase. This fluctuation affects the analyte elution times. Both the injection and detector cell volume
changes are therefore required to maintain optimum sensitivity and peak characterization.
In summary, LaRC researchers might reduce wastes by converting to shorter and narrower bore
columns containing a 3 micron particle packing for appropriate analyses. The resolution of the separation
is maintained or increased, while waste volume is decreased. Conversion to a different column configuration
requires a minimal or zero capital investment, dependent on column bore reduction. The cost of 4.6 and
2.0 mm i.d. columns incorporating either 3 or 5 micron packings are almost identical. If a 1 mm i.d. column
is used, however, the injection loop and detector cell volume must be changed. These conversions require
a typical investment of approximately $500 to $800, depending upon the instrumentation.
Communication between researchers may also foster source reduction methods. It was observed
that numerous laboratories employ HPLC for analyzing the same constituents. Communication between
group analysts may yield valuable information regarding the use of other methods and their analysis speed,
reproducibility, accuracy, method detection limit, and prospective pollution prevention. A rapport between
the facility HPLC users would distribute knowledge and expertise to ail analysts. Besides communication,
other source reduction methods for HPLC include:
• Preparing only the necessary amount of HPLC mobile phase solvent. Researchers can
prepare an excess of this solvent which either is never used or requires disposal due to
compositional changes over time.
Stopping the introduction of solvent to the HPLC column as soon as required experimental
conditions have been met.
Recycling-
An HPLC separation can be run under isocratic or gradient conditions. An isocratic separation
means that the mobile phase composition is kept constant during the analysis. A gradient separation occurs
when a mobile phase constituent, usually the organic modifier (acetonitrile, methanol, THF), is altered during
the analysis. At LaRC, both types of separations are used. Isocratic HPLC wastes, however, are easier to
recycle and reuse. The mobile phase employed in an isocratic mode is always of constant composition.
Thus, the mobile phase exiting the column is approximately that entering the column. The added difference
is that the exiting effluent contains the injected sample mixture.
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"Spent" mobile phase can be reused depending upon the detection method employed. Typically,
a sample component is diluted 100 fold after passing through the column. If this waste solvent is used again
for separation, the waste injection analytes will again be reduced 100 fold when they exit the column. The
dilution effects on the original sample multiply to yield a minimal increase in the baseline noise. This
approach can generally be used for detection with a UV-Vis detector. It is, however, not as useful for very
sensitive detectors such as the fluorescence detector or with highly absorbing compounds in the UV-Vis
detector. A 10,000 fold analyte dilution may still be detected.
Alternatively, spent solvent could sequester previously eluted sample analytes prior to reuse by
passing the solvent through a "trap" column. The trap column may contain the same support, but with a
higher coating of stationary phase to ensure a high trapping efficiency. The particle size should also be
large compared to the analytical column. This helps maintain a low backpressure prior to the solvent
delivery system. Overall, this configuration enables the analyst to maintain a closed loop system whereby
the solvent is continuously recycled. A periodic check on the trap column is advised in order to prevent
contaminant breakthrough.
Distillation of the HPLC solvent is also a potentially effective procedure to purify solvents for recycle
and reuse. This is analogous to recycling methods described previously for sample preparation waste
solvents. In this case, however, the aqueous HPLC solvent would form an azeotropic (constant
composition) distillate for reuse. This liquid should be as pure as the starting solvents (HPLC grade) since
the biological impurities are nonvolatile. However, with respect to the initial HPLC fluid, the distillate
composition may be different. The addition of fresh solvent to the distillate regenerates the initial HPLC
mobile phase.
As previously discussed, the purity and compositional make-up of the solvent can be checked by
using the GC or refractive index detector. This would be beneficial when solvents have been stored in
containers over a long period of time. Furthermore, the waste HPLC solvents should be segregated
respective of the assay. This separation enables easier and cleaner recycling and reuse. Recycled solvent
unsuitable for use in HPLC applications could potentially be used in other ways by researchers. The
required costs for distillation equipment and the trap column are minimal. Coupled with the high costs of
HPLC-grade solvents ($50 to $100 per gallon) and of disposal ($10 to $15 per gallon), spent solvent
recycling and reuse seems ideal. However, the required labor costs and solvent purity concerns may prove
to be significant, and unacceptable to researchers.
Suggestions described above are general pollution prevention concepts that may or may not be
applicable to the individual researchers at LaRC. In addition, some researchers may not consider their
efforts to contribute to waste generation and thus are not likely to expend effort and funds on pollution
prevention. The concepts described above should, however, have broad application to LaRC. The goal of
any pollution prevention program is to ensure that all facility residents systematically identify whether or not
they adversely impact the environment, further, if they do contribute to an environmental problem, they must
know how to resolve it (preferably through source reduction) or who can help them resolve it.
Future Methods and Trends-
There are several methods currently under investigation which would greatly reduce organic solvent
waste generation from HPLC analyses. The method theories, instrumentation, and application of these
techniques are still in a developmental stage. SFE has previously been discussed as a method which could
replace organic solvent extraction. An analogous method with respect to HPLC and SFE is supercritical fluid
chromatography (SFC). SFC is in the developmental stage, less advanced than SFE practices, even though
commercial units are on the market. SFC operation lies between the realms of GC and HPLC. As in SFE
the supercritical fluid possesses viscosities between those of liquids and gases. This provides for a more
efficient separation of nonvolatile compounds when compared with HPLC. Additionally, SFC can utilize the
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detectors employed in GC. The universal flame ionization detector can therefore aid in quantifying difficult
HPLC components such as carbohydrates, triglycerides, and fatty acids. It is similar to GC, however
nonvolatile compounds can be separated and detected. By coupling SFE to SFC, a complete sample
extraction and analyses may be obtained wherein virtual elimination of organic solvents is attained.
Capillary zone electrophoresis is another method which would greatly reduce organic solvent usage
from HPLC. This technique involves the use of a high voltage differential between the inlet and outlet of a
capillary column. Samples are loaded into a capillary filled with buffer solution. An electric potential field
is established causing analytes to migrate at different rates and separate into discrete zones. The capillary
tube length is approximately 100 cm with a diameter of 50 jjL This method has high resolving power and
may replace HPLC as the method of choice for analyses performed at LaRC. The technique, however, is
not widely accepted at this time as a standard method to replace HPLC.
Waste generating operations at LaRC and similar research institutions provide obstacles to pollution
prevention initiatives. Some of these obstacles are due to the nature of laboratory research, while others
can be solved only by forces outside of LaRC's direct control.
There are over 70 individual laboratories performing scientific research at this facility. The nature
of laboratory work results in a large number of small quantity wastestreams being generated. LaRC is
different from industrial operations where large quantities of a certain waste type are generated, and payback
periods for pollution prevention initiatives are relatively short given the application of appropriate technology
(e.g. replacing solvent degreasers with alkaline washers). Conducting an engineering/scientific analysis of
ways to reduce each LaRC wastestream will not be cost effective, and due to the small quantities generated,
there may be little economic incentive for the free market to devise pollution prevention solutions to these
problems. The limited solution to this problem is that scientists should be trained in the pollution prevention
ethic. With such training, scientists can use their specialized knowledge in their research to incorporate
individualized pollution prevention concepts into each research effort.
Scientific research presents other unique problems. There is a need for reproducibility of lab results
over a long time period, and naturally scientists are reluctant to entertain changes in accepted procedures.
Also, many of these analyses are performed according to standard methods used nationally and
internationally. Deviations from those methods may cast suspicion on or invalidate their research in the eyes
of their peers. Authorities responsible for methods development (e.g., EPA or Association of Official
Analytical Chemists (AOAC), etc.) will need to continue to develop and incorporate techniques in approved
methods that result in reduced waste. Further, it may be useful for these developing authorities to develop
a comprehensive laboratory pollution prevention manual that becomes part of their standardized methods.
This manual could include major topics such as solid phase extraction as well as other issues; such as
substituting ethyl acetate for ether, hexane, or dichloromethane for cleaning the grease from ground glass.
Such a manual, however, would require extensive research to define scientifically acceptable methods that
result in minimal wastes. The techniques used in this report as alternatives were developed because they
could provide more accurate or reliable results while coincidentally resulting in less waste. Laboratories
could benefit from standardized, scientifically acceptable methods that are designed with reduced waste as
a goal of the development effort. Such a method development effort, however, would require modification
of how scientists are taught to design and develop techniques and research projects.
LaRC may also consider material and waste exchange as a viable option for pollution prevention.
However, the discussion of waste exchange keys the issue of transportation issues with respect to moving
chemicals. Using waste exchanges requires movement of waste be performed by a licensed hazardous
waste transporter, with packages meeting all Department of Transportation (DOT) requirements. This
increases costs for transfer of to the receiving facilities. Many of the regulations affecting LaRC support the
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overall public interest. Better communication between government agencies would be helpful in alleviating
some of the unnecessary problems described above.
The researchers themselves present special challenges to pollution prevention efforts. While
scientists are certainly able to implement pollution prevention, some believe that waste generation a
necessary part of their work and that it is relatively unimportant. Other researchers do not believe it is cost
effective for them (or their technicians) to spend time on recovering small quantities of solvent or taking
similar steps. The complexity of the hazardous waste regulations acts as a barrier, preventing scientists and
engineers from dedicating time to pollution prevention engineering.
For LaRC the problem lies in the fact that a variety of small operations may contribute to a large
problem but researchers do not see themselves as a major contributor. In order to help in this potential
problem it may be useful for LaRC to provide a forum to make researchers more environmentally aware
while providing a unified forum to challenge or demonstrate inconsistent regulatory barriers.
CROSSFEED TO OTHER TIPPP INSTALLATIONS
Wet chemistry research labs exist at all other TIPPP bases. The philosophical and awareness
options identified in this report should be transferred throughout the TIPPP. The opportunity for TIPPP-wide
material and waste exchanges would enhance source reduction effectiveness.
MEASUREMENT OF POLLUTION PREVENTION
Measurement of the successes of the options identified are dependant on establishing a definitive
baseline of current waste generation and specificity. These data were not available at the time of the writing
of this report.
IMPLEMENTATION PLAN
LaRC can begin implementing pollution prevention specific projects. Similarly, implementing a
charge-back system to generate revenues for pollution prevention research would support the program
Finally, general awareness training, coupled with the development of a Center-wide plan will provide the
foundation and support for subsequent pollution prevention initiatives.
RESIEARCH DESIGN AND DEVELOPMENT NEEDS
Site-specific RD&D should be conducted for HPLC analysis. Establishing the exotic materials and
waste exchange will also require research of the viability of the system, identification of exchange partners
and the tracking documentation to satisfy control of liability from one lab to another.
RECOMMENDATIONS
The initial effort provided to the LaRC is intended to be the with a starting point from which LaRC
may begin to systematically investigate pollution prevention opportunities. During this initial assessment
several areas and concepts were identified that NASA could investigate further to define pollution prevention
onnnrtunitip*-
opportunities:
Baseline Development -it is important to study and characterize the sources of laboratory
wastes to understand the exact sources of waste materials, lab packs, and excess
chemicals. This study should include identifying similar processes or operations among
laboratories that may result in similar wastes. For example, LaRC personnel and scientists
realize that they use HPLC analyses but the volumes generated by various laboratories is
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not well defined. To remedy this, LaRC should take existing waste generation records and
identify the specific wastes and associate them with specific laboratories and operations.
• Materials Tracking - Some of LaRC's laboratories have already initiated computerized toxic
materials inventory, use, and disposal tracking systems. Such efforts should be
standardized, networked and expanded to include all laboratories at the Center. Such an
system would provide the Center with a better understanding of the sources of wastes,
amounts by waste type (as opposed to numbers of laboratory packs) and usage statistics.
A chemical materials tracking system might allow the Center to order and use chemicals
more efficiently. With this system, LaRC might reduce operating costs (through more
efficient ordering) and decreasing waste of chemicals.
• Materials and Waste Exchange - In understanding its usage and waste generation patterns,
LaRC may find opportunities to transfer materials between laboratories at the Center. The
Center already has a limited system of exchange between laboratories using a
computerized inventory of available chemicals. As this system is developed internally, LaRC
may find that exchange with parties external to the NASA may also provide opportunities
to find additional uses for materials that would otherwise require disposal as hazardous
waste. Such activity may be limited by Transportation and/or LaRC regulations but still
may be viable for some materials. Further, the establishment of a Chesapeake Bay Waste
Exchange may provide a useful forum to test the usefulness of waste exchange practices
for the Center.
• Exotic Materials Reclamation - The nature of LaRC's research may also provide a unique
opportunity for reclamation of exotic (and usually valuable) chemicals at a centralized
reclamation area. Specifically, the amounts of specialty metals and solvents used at the
Center may provide LaRC with the opportunity to establish a chemicals reclamation
operation onsite. The chemicals reclamation operation would be developed to reclaim
specialty solvents, metals and other chemicals commonly used in various Center research
operations. The reclamation operation could be funded with savings from decreased raw
materials usage and hazardous waste disposal. In cases where the reclaimed material is
not needed, the reclamation operation could receive additional funds through sales of
reclaimed chemicals. In developing such a reclamation operation, the Center would need
to:
identify exotic chemicals used;
quantify costs associated with purchase of these chemicals;
characterize the nature, volumes, and costs for disposal of wastes;
identify procedures and equipment needed to reclaim the materials;
determine which chemicals could be reused by LaRC researchers and which would
be sold to parties outside of LaRC, and
balance the potential cost savings against costs for reclamation;
Such a reclamation operation would be developed slowly with initial efforts focusing on
easily reclaimed, extremely expensive chemicals that are currently disposed as hazardous
materials after use.
Even after investigating and initiating appropriate efforts, LaRC must still perform what may be the
most difficult effort of its pollution prevention program: bringing pollution prevention concepts to the
consciousness of all LaRC personnel especially researchers. For pollution prevention to succeed at it is
essentiail to identify and develop specific demonstration projects that can provide tangible results.
Communication, education, and technology will help to bring about reductions in hazardous waste
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propagation. The personnel at LaRC have already demonstrated willingness to participate in some
programs. For example, materials tracking is being developed and used at Building 1293. Such efforts
might be used to demonstrate the ease of changing old procedures and the potential environmental,
economic, and compliance gains that can be achieved through prevention concepts. Lastly, it is
recommended that the Center develop a plan for educating its personnel on pollution prevention concepts
and techniques as part of its pollution prevention program plan.
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September 28, 1992
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
NAVAL AVIATION DEPOT, NORFOLK, VIRGINIA
ELECTROPLATING OF NICKEL AND CHROME
by
George Cushnie
Science Applications International Corporation
Falls Church, Virginia
Cincinnati, Ohio 45203
EPA Contract No. 68-C8-0062, WA 3-70
SAIC Project No. 01-0832-03-1021-010
Project Officer
Mr. Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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INTRODUCTION
Purpose
The purpose of this project was to conduct a Pollution Prevention Opportunity Assessment (WMOA)
for selected processes at NADEP's Electroplating Shop. The assessment was conducted for the EPA's Risk
Reduction Engineering Laboratory under the purview of the Tidewater Interagency Pollution Prevention
Program (TIPPP) and the Waste Reduction Evaluations at Federal Sites (WREAFS) program of the Pollution
Prevention Research Branch. A procedure described in the EPA Waste Minimization Opportunity
Assessment Manual (EPA/625/7-88/003) was used to conduct the study. The manual provides detailed
worksheets and a process/option evaluation method for use in industrial settings.
Approach
A PPOA consists of four systematic steps: Planning and Organization, Assessment, Feasibility
Analysis, and Implementation. Figure 1 presents the PPOA process. Of the 19 worksheets in the WMOA
manual, selected sheets were completed for the processes and waste minimization options considered. The
detailed worksheets used are presented in Appendix A. The implementation of the recommended options
presented in this report is at the discretion of the host facility.
PROCESS REVIEW
The Naval Aviation Depot (NADEP) at Norfolk, VA is one of six U.S. Navy facilities where aircraft are
routinely overhauled. Each of these facilities employs up to 4,000 skilled industrial workers. The NADEP
at Norfolk performs rework of F14 and A6 airframes, engines, and landing gear. The aircraft rework process
consists of complete disassembly, inspection of reusable parts, remanufacture of parts, reassembly, and
testing. The remanufacturing operations include numerous machining and metal finishing operations which
generate significant quantities of hazardous and oily wastes. The focus of this study was metal plating which
is performed at the NADEP plating shop. This facility contains more than 30 different metal finishing
operations including: degreasing, aqueous cleaning, stripping processes for existing coatings, electroplating,
electrolytic plating, anodizing, conversion coating, passivation, etching, and abrasive blasting.
A Pollution Prevention Opportunity Assessment (PPOA) was conducted for hard chromium and
nickel sulfamate electroplating operations performed at NADEP, Norfolk. The two processes are used by
the Navy primarily for building up worn surfaces of metal parts including engine and landing gear
components. Following plating, the plated deposits are machined back to the specified dimensions of the
part. Each of the two processes consist of several steps including degreasing, stripping, cleaning, plating,
machining, and rinsing. Use and maintenance of the plating processes generates wastewaters contaminated
with dilute concentrations of dissolved metals, spent process solutions, tank bottom sludges, spills/leaks
of concentrated solutions, and spent carbon and cartridge filters from bath maintenance systems. Some
provisions for pollution prevention have been successfully implemented at this facility and are documented
in this report Additional pollution prevention opportunities have been identified and evaluated during this
study and recommendations for implementation have been developed.
The NADEP plating shop is located in building LP-24 which also houses a machine shop. The
building was constructed in 1986. The plating shop has a first floor working area of 41,600 ft2 and support
operations and equipment on the perimeter, including: parts receiving/shipping, masking/demasking,
abrasive blasting, ovens, chemical storage, predeaning, laboratory, offices, maintenance, mechanical, and
rest room/break faculties. The plating room has a 16 ft. ceiling to accommodate the movement of long parts
which are transported using manually activated electrical hoist systems. The tanks are arranged in 16 lines
with each line being dedicated to one or two processes. Mezzanines, which hold rectifiers and support
68
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69-
-------
utility conduit are located between the plating lines. The plating area has a grated floor, below which is a
basement. The basement contains ventilation ducting, scrubbers, wastewater piping and storage tanks, and
miscellaneous support equipment.
The NADEP plating shop has made significant strides in pollution prevention, due primarily to a
commitment by management, good inhouse engineering, and the cooperative efforts of plating personnel.
The following are examples of the NAOEP's efforts.
• Rinse water use was cut 75% (from 80,000 gpd to 20,000 gpd) by installing flow restrictors
on all water inlets feeding rinse tanks and through training platers to close water valves on
idle plating lines. Periodic inspections (at least two per day) are made of each plating line
to assess water use. Water meter readings are recorded on a daily basis to track water use
and identify unusual conditions.
• Process solutions are rarely discarded at the NADEP. This is primarily due to the exclusive
use of deionized water for evaporative makeup in the process tanks. Also, the facility
performs some bath maintenance including filtering, sludge removal, carbonate control,
dummying, and carbon filtering.
• Electrolytic metal recovery has been installed for the recovery of cadmium. The recovered
cadmium is reused as anode material.
• A non-cyanide nickel strip solution was substituted for their conventional cyanide bath.
• The shop contains a mist eliminator system to recover chromic acid from hard chromium
plating tank emissions.
Hard Chromium Plating
Hard chromium plating refers to chromium electroplating that is deposited in heavy thicknesses
usually directly onto a base metal such as steel. It is used to provide resistance to heat, wear, and
corrosion and a low coefficient of friction. It is also commonly applied at rework facilities to increase the
dimensions of worn bearing surfaces. Hard chromium plating differs from decorative chromium plating
which is usually applied in thin deposits as a final or top coat over copper and/or nickel deposits.
The NADEP hard chromium shop plates approximately 4,000 parts per year. Approximately 25%
of this workload is landing gear components. The hard chromium processes used at the NADEP shop are
shown graphically in Rgures 2 and 3. Table 1 contains data relative to the equipment and chemical
solutions used for the stripping and hard chromium plating processes. Most of the parts that are chromium
plated are made of steel. The following describes the procedures used for plating steel parts. Variations
of the process are used for other base metals.
The used parts typically arrive at the shop with an existing chromium deposit and varying amounts
of grease, oi and dirt Initially, ols and greases are removed In a 1,1,1-tricWoroethane fTCA) vapor
degreaser. If the parts rave an existing chromium deposit, this deposit te stripped. Prior to stripping, the
parts are sometimes masked (depends on the part) to protect nonplated surfaces by dipping the parts into
a hoi; plastic compound and carefully removing the plastic film from the surfaces to be stripped. The
masked parts are then placed into a caustic solution where a reverse current is applied (the part is positively
charged and anodes are negatively charged) and the existing chromium plate is stripped. After stripping,
the parts are rinsed and then placed into hot water to remove the bulk of the plastic masking. Small
amounts of residual maskant are then removed by returning the parts to the vapor degreaser. At this point,
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TABLE 1. PLATING AND RINSE DATA
Operation
Vapor Degrease
Vapor Degrease
Chrom« Strip
Chrome Strip
Chrome Strip
Chrome Strip
Chrome Strip
Chroma Plate
Chrome Plate
Chromo Plate
Chrome Plate
Chrome Plate
Chrome Plate
Chrome Plate
Chrome Plate
Nickel Strip
Nickel Plate
Nickel Plate
Nickel Plata
Nickel Plate
Nickel Plata
Nickel Rate
Nickel Plate
Tank
Number
T-1
195a
T-191
T-69
T-70
T-71
T-36
T-192
T-27
T-29
T-30
T-31
T-32
T-33
T-34
T-35
T-36
T-54
T-51
T-53
T-56
T-60
T-1 96
T-106
T-106
T-110
T-109
T-115
T-117
T-1 18
T-1 19
Tank Function
TCA Degrease
TCA Oegrease
Maskarrt
Cr Strip
Cr Strip
Rinse
Demask
Maskarrt
Chrome Plate
Chrome Plate
Chrome Plate
Chrome Plate
Chrome Plate
Chrome Plate
Chrome Plate
Oragout Rinse
Hot Water
Demask
HCL Activation
Non-brazed
Strip
Non-brazed
Strip
Brazed Strip
CWR-
CWR«
CWR-
Desmut
CWR-
Maskant
Electroclean
Anodic Etch
Activation
CWR*
CWR-
CWR'
Ntake* Strike
Nickel Plate
Nickel Plata
Dragout
Recovery
CCR"
CCR"
Tank Dimensions (ft)
L
6.0
a.o
6.0
8.0
6.0
8.5
8.5
8.5
8.5
8.5
12.0
8.0
6.0
6.0
4.0
6.0
4.0
6.0
4.0
4.0
4.0
4.0
4.0
6.0
4.0
4.0
4.0
4.0
4.0
4.0
4.0
6.0
6.0
6.0
4.0
4.0
X
W
3.0
4.0
4.0
4.0
4.5
4.0
4.0
4.0
4.0
4.0
4.5
4.5
4.5
4.5
4.0
4.0
4.0
4.0
4.0
4.0
4.0
4.0
4.0
3.0
4.0
4.0
4.0
4.0
4.0
4.0
4.0
5.0
5.0
5.0
4.0
4.0
X
D
3.0
8.0
8.0
8.0
10.0
5.0
5.0
5.0
5.0
5.0
10.0
10.0
10.0
10.0
4.0
4.0
4.0
4.0
4.0
4.0
4.0
4.0
4.0
3.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
4.0
4.0
4.0
5.0
5.0
(gals.)
337
1.795
1.795
1.795
1.919
0
1.144
1.144
1,144
1.144
1.144
3.837
2.556
1.919
1.919
419
626
419
628
419
419
419
419
419
337
539
539
539
539
539
539
539
785
785
785
539
539
Solution
Temp. (F)
Amti.
350
130
130
130
130
130
130
130
N/A
200
N/A
190
180
Amb.
Amb.
Amb.
130
130
Bath Chemistry
1.1.1-trtchloroethane
1.1.l-trtchloroethane
Hot plastic
8 to 16 oz/gal caustic
8 to 16 oz/gal caustic
Water
Hot plastic
Chromic acid (33 oz/gal). sulfuric acid (.33 oz/gal)
Chromic acid (33 oz/gal). sulfuric acid (.33 oz/gal)
Chromic acid (33 oz/gal). sulfuric acid (.33 oz/gal)
Chromic acid (33 oz/gal). sulfuric acid (.33 oz/gal)
Chromic acid (33 oz/gal). sulfuric acid (.33 oz/gal)
Water
Hydrochloric acid
Metalx B-9 (protein) solution
Enthrone NP Strip
Chromic acid (60 oz/gal)
Wax
soprepS4P .
Sulfuric acid
Hydrochloric acid (20 to 30%)
Nickel chloride (32 oz/gal). HCL (16 oz/gal)
Allied KaHte bath
Same as T-1 15
" cold witter rinse
" counter current rinse
73
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the parts are ready for the next rework procedure which is typically rechroming or an intermediate machining
step.
Initially, the parts are baked in an oven for stress relief (baking eliminates internal stress in ferrous
metals caused by machining, grinding, etc.) to alleviate potential adhesion and cracking problems. A
maskant step is then performed using a hot plastic coating, vinyl and aluminum tape, and aluminum and
lead foils. Following masking, the surface of the parts to be plated are exposed. The parts are then
subjected to abrasive blasting with glass beads to ensure that the surface is clean and to roughen the
surface to improve bonding of the chromium deposit. The parts are now ready for rechroming and they are
arranged on fixtures and electroplated in a chromic acid solution. The chromium plating process often takes
one to two days to complete since thick chromium deposits (i.e., up to 0.05 in.) are usually applied and the
deposition rates are slow (0.001 in./hr). Following chromium plating, the parts are rinsed and then
demasked in hot water and the vapor degreaser. The parts are then baked for hydrogen embrittlement relief
(parts adsorb hydrogen during plating which must be removed by baking to prevent cracking and other
deformations of the deposit). Abrasive blasting is then used for final cleanup and the parts are sent to the
machine shop for further processing (i.e., grinding).
Information and data relative to the hazardous wastes and wastewaters generated by the hard
chromium plating process are shown in Table 2. Generally, hazardous wastes and wastewaters generated
in plating shops can be grouped into six categories: (1) spent process solvent and solutions resulting from
contamination or exhaustion, (2) rinse water, (3) scrubber water blowdown, (4) tank bottom sludges and
solids from filter cleanout, (5) miscellaneous chemical losses including spills and drips, and (6)
miscellaneous solids, including used masking materials and abrasive blasting dusts.
The process solvent and solutions used for hard chromium stripping and plating include: TCA
caustic stripper, and the chromium plating solution. TCA degreasing is performed in two degreasers one
of which was recently installed. The newer unit has an integral still which is used to recover TCA when the
solvent becomes contaminated. The older unit does not have an integral still and when the solvent is
contaminated with grease, oil and maskant, or becomes acidic It is discarded. Disposal of the solvent and
sludge from the older unit occurs approximately once per year. The caustic stripper is discarded when ft
becomes overly ladened with dissolved chromium. This has occurred only once since 1986. Chromium
plating solution is not routinely discarded, although one of the chromium plating tanks currently contains
contaminated solution.
Rinse water is generated by rinsing operations following chromium plating and stripping. The rinse
waters are discharged to the industrial wastewater treatment plant (IWTP). Treatment of these wastewaters
results in the generation of hazardous sludge (F006). Rinsing following chromium stripping is performed
in a single overflow rinse. Rinsing following chromium plating includes use of a hand-held air assisted water
spray over the plating tank followed by rinsing in a dragout tank and an overflow rinse. The solution
contained in the dragout tank is periodically pumped into the plating tanks to recover the chromium. This
recovery method has not been fully implemented because the pump is undersized and operators are
reluctant to use It The method will work, but the pumping time required is not acceptable to the operators.
The chromium plating and stripping tanks are ventilated to remove toxic fumes from the work place.
The exhausted air Is treated by wet scrubbers to remove contaminants before releasing the air to the
atmosphere. The chromium exhaust system also includes a demister unit which removes most of the
chromic acid from the exhausted air stream before ft reaches the scrubber. Although not reported, typical
demister efficiency is 97 to 99% removal. Based on NADEP data, the demister recovers approximately 4 000
Ibs of chromic acid (CrO3) per year. Scrubber water is periodically discharged from the scrubber units to
the IWTP for treatment. The chromic acid recovered by the mist eliminator is pumped to an unused
chromium plating tank. At one time the demister contained chevron-type plates that were made of stainless
steel. The plates corroded during use and the recovered chromic acid contained too much dissolved iron
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for reuse as plating solution. The chevron plates have been recently replaced by mesh pads made of
synthetic material. The recovered chromium is being stored in an unused chromium plating tank until the
usefulness of the material is determined. Also, NADEP is testing electrodialysis (ED) technology in the same
inactive tank in an effort to removed the dissolved iron. Use of ED technology is discussed in the
assessment/feasibility sections.
In order to reduce the misting of process solution from chromium stripping, a mist suppressant is
used. To reduce air emissions from chromium plating, the NADEP is planning on replacing existing air
agitation with mechanical agitation.
Sludge is periodically removed from the bottom of the chromium plating tanks. The sludge is
primarily lead chromate generated from corrosion and flaking of lead alloy anodes. This material causes
pitting of the chromium deposits when it contacts the parts during plating. The frequency of sludge cleanout
is not known exactly; however, it is less than once per year per tank. A recent cleanout of the largest
chromium plating tank generated six 55-gal. drums of sludge (D007).
The greatest threat of miscellaneous losses is from tank overflows that could occur during refilling
for evaporation makeup. Evaporation makeup is needed for heated solutions such as the chromium plating
solution. The makeup water (deionized water) is added from a hose. It is shop policy that during refilling
the operator remains at tank site to prevent overflows; however, some instances of overflows have occurred.
The shop is ordering high level alarms for critical tanks to help prevent these occurrences.
Nickel Sulfamate Electroplating
Nickel sulfamate plating is used at NADEP, Norfolk for many of the same reasons as hard chromium,
(i.e., to provide resistance to heat, wear, and corrosion). The mechanical properties of the nickel deposit
are similar to hard chromium, however, nickel deposits are slightly less hard. Nickel is applied in thick
deposits, when required for resizing worn surfaces. The speed of deposition is significantly faster than with
hard chromium plating and therefore the process takes less time to complete. Approximately 1,000 parts
are nickel sulfamate plated annually at the NADEP.
The nickel sulfamate process is described in Figures 4 and 5. Table 1 contains data concerning the
equipment and chemical solutions used for the nickel sulfamate plating process. The nickel stripping
process is similar to that for chromium and it consists of vapor degreasing, acid cleaning and activation,
stripping, desmut, and abrasive blasting. Two types of stripping solutions are used, the choice depends on
whether the part is brazed or not. The nickel sulfamate plating process consists of degreasing, stress relief,
masking (wax maskant rather than plastic), abrasive blasting, electrodeaning, acid etch, acid activation,
nickel strike, and nickel electroplating. Each of the aqueous process steps is followed by rinsing.
Table 2 contains information and data concerning the waste generated by these processes. These
wastes can be grouped into the same five categories discussed for hard chromium plating. The following
is a discussion of the key wastes in each category.
The process solvent and solutions used for nickel sulfamate stripping and plating include: TCA, acid
activator, two stripping solutions, desmut, electrocleaner, acid etch, nickel strike, and nickel plate. All of
these solutions and the TCA solvent are routinely discarded, except for the nickel strike and nickel plating
solutions.
Rinse water is generated from rinsing after each of the aqueous process steps. The rinse waters
are discharged to the IWTP. Treatment of these wastewaters results in the generation of hazardous sludge
(F006). Efforts are underway at the NADEP to recover nickel from rinsing after nickel sulfamate plating using
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an electrolytic metal recovery (EMR) unit. A similar device has been successfully used for cadmium
recovery at this shop.
Each of the aqueous process tanks used for nickel stripping and plating is ventilated and the fumes
pass through wet scrubber units. The blowdown form these units is treated at the IWTP.
The nickel plating solution is maintained through continuous filtration to remove suspended solids
and periodic carbon treatment to remove excess organics. These operations generate miscellaneous solids
that are drummed for offsite disposal.
As with hard chromium plating, tank overflows are a serious pollution threat and these occurrences
are most likely to occur with heated process tanks which require frequent replacement of evaporated water.
The nickel plating tank is of particular concern in these operations since this solution is heated to a relatively
high temperature and It contains the highest concentration of metal of the nickel plating process.
ASSESSMENT/FEASIBILITY
Identification of Pollution Prevention Options
Numerous methods and technologies have been utilized by electroplating shops for pollution
prevention. A list of common source reduction and recycling options is presented in EPA's Guides to
Pollution Prevention, The Fabricated Metal Products Industry (USEPA 1990). Using the applicable
suggestions from this reference and ideas generated by NADEP personnel and the assessment contractor,
the list of potential options in Table 3 was developed. The following is a discussion of key pollution
prevention options from the list.
Good Operating Practices
Good operating practices are defined as procedures or institutional policies that result in a reduction
of waste. The practices include: waste stream segregation; personnel practices such as management
initiatives and employee training; procedural measures such as documentation/record keeping, Inventory
management and control; and loss prevention practices such as spill prevention, preventative maintenance
and emergency preparedness. The following are specific good operating practices that are applicable to
the NADEP plating shop.
• Construct and utilize a data base for tracking water use and chemical use. Presently,
records are maintained for water use and chemical use in files and logbooks. A computer
data base would provide a convenient means of storing and retrieving the data and
preparing statistical evaluations that would show usage trends, identify unusual incidents,
and help the NADEP to quantify the success of their pollution prevention program.
• Improve tracking of water use. Presently, water use is measured daily at the NADEP shop
through readings of a water meter located in the shop's basement. The location of the
meter is inconvenient and it cannot be seen from the production areas. The only other
water meter present in the shop is located on the feed line to their deionized (Dl) water
system that feeds most rinse tanks and all process tanks. This meter is not in working
condition.
-------
TABLE 3. POTENTIAL POLLUTION PREVENTION OPTIONS
Wastestreams
Applicable Pollution
Prevention Options
Potential Impact*
All Wasteetreams
Contaminated TCA
and Still Bottoms
Spent Chromium Strip
Solution
Chromium Strip Rinse
Water
Chromium Plating
Rinse water
Chromium Plating
Scrubber Water
Chromjum Plating
Spills and Drips
All Aqueous Nickel
Strip Process Solutions
Nickel Strip Solutions
and Rinses
All Aqueous Ntoket
Plating Process Solutions
Except Ni Plating
Ntekel Plating Spills
nd Drips
- Implement good operating
practice*
Substitute aqueou* cleaner with
bath maintenance technology for
degreasing operation
Eliminates use of vapor degreaser
that does not have an integral still
Substitute mechanical stripping
(grinding) where practical
Recover strip solution with
electrodialysis (ED)
• Dragout recovery rinsing
Use multiple stage recovery rinsing
and an atmospheric evaporator
Implement conforming anode
plating
Improve mist eliminator operation by
eliminating tank and adding
additional pads
Install high level tank alarms
Install drip pan below plating tanks
Install in-tank filtration units to
remove suspended solids
Recover nickel using ion exchange
and electrolytic metal recovery
Install in-tank filtration unit to
rsmove suspended solids
Install high level tank alarms
install drip pan below plating tanks
- Creates employee awareness,
reduces waste generation, improve*
work quality and improve* work
place environment
• Eliminates F002 waste*
Minimizes discarded quantity
Minimizes contamination of solvent
Reduces disposed frequency of
strip solution
Eliminates disposed of strip
solution and recovers chromium in
reusable form
Reduces dragout loss but must be
implemented with ED to prevent
frequent bath disposal
Eliminate* dragout losses but
requires use of ED for bath
maintenance
Reduces introduction of anode
corrosion products into bath
Eliminating one tank will reduce
ventilation requirement and permit
use of additional pad for higher
recovery rate
Reduces potential for tank overflow
Recovers chromic add dripped
through grated floor
Reduces bath dumps
Prolongs life of strip solution and
recovers nickel in reusable form
Reduces bath dumps
Reduce* potential for tank overflow
Recovers chromic add dripped
through grated floor
83
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Water meters are an excellent means of tracking water use at any plating shop. Meters or remote
readouts should be conveniently located on the main water line and throughout the shop. Internal shop
meters should be located on individual process lines. All meters should be maintained in working condition.
All meters should be read, at a minimum, on a daily basis to help identify unusual conditions before a major
problem occurs. If possible, the meters should be read during each shift since operational procedures
oftenvary from shift to shift. The water meter readings should be recorded in a data base and analyzed as
described in Reference 2.
• Improve instrument maintenance. It was observed that the plating shop is well maintained in terms
of general housekeeping. For example, the basement floor, which is designed to catch drips and
spills, is relatively free of dampness or chemicals. However, many computer controls and
instruments present in the shop were not functioning. Some controls have never functioned since
the opening of the facility in 1986. Repair or replacement of controls and instruments that are not
in working condition will improve the overall operation of the shop. Continued maintenance will be
necessary to keep them functioning in the future. The proper instrument/control maintenance
personnel need to be assigned to the shop or a maintenance contract should be considered.
* High level alarms on process tanks. At present, there are no high level alarms on process tanks.
Alarms are needed on heated process tanks where water is routinely added to make up for
evaporation. Even though the NADEP has a strict rule requiring operators to stay at a tank when
It is filling, the potential exists for a tank overflow. The NADEP has recognized the need for high
level alarms and is in the process of procuring them.
• Segregate abrasive blasting workload. Abrasive blasting dust from aluminum oxide and glass bead
blasting is manifested offsrte as a hazardous waste due to cadmium contamination. The cadmium
is contributed to the dust from incompletely stripped parts that were previously cadmium plated.
The NADEP may be able to reduce the quantity of hazardous waste generated by segregating the
cadmium plated parts from other parts and blasting the cadmium plated parts in its own blasting
unit. *
• Energy conservation. At present, most process and rinse tanks that are used at an elevated
temperature are maintained at the elevated temperature even when not in use. Depending on the
tank heat-up time and the scheduling of work, it may be possible to reduce the heating of idle tanks.
Vaoor Decreasing Options
The Clean Air Act Amendment of 1990 phased out production of 1,1,1-Trichloroethane (TCA) by
2002 due to its harmful impacts on stratospheric ozone. Facilities presently dependent on this material
should initiate efforts to find a replacement which does not have negative effects on human health and the
environment Other chlorinated solvents such as trichloroethylene (TCE), percNoroethylene (PERC) and
methylene chloride (METH) are not considered good alternatives due to carcinogenicity and, for TCE and
PERC, due to their contributions to photochemical smog formation. Rather, investigations should focus on
aqueous and semi-aqueous cleaning materials. Those that are especially attractive are materials that are
amenable to the maintenance techniques for extending usage (e.g., microfiltration) and for dragout recovery
(e.g., ultrafBtratlon). The choice of an appropriate substitute cleaning method is highly dependent on the
specific cleaning characteristics of the operation (e.g., types of ofl, grease and dirt present, workload, base
metals cleaned); therefore testing is recommended. Due to the regulatory deadline for TCA phaseoutmany
companies are developing alternative cleaning methods including both chemicals and equipment
Simultaneously, many private industry and government metal finishing facilities are conducting research and
testing of available substitute products. A wealth of current information and data are available in product
literature, technical journals, conference proceedings and reports. This information wHI serve as a starting
point for finding substitute degreasing processes.
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The implementation of a substitute degreasing process may take up to several years to complete.
To reduce present F002 waste quantities the NAOEP should consider (1) eliminating use of the existing
old degreaser which does not have provisions for solvent recovery, (2) minimizing use of vapor degreasing
for maskant removal. The latter of these options can be implemented by using hand scrubbing and rinsing
to remove as much maskant as possible prior to use of the degreaser and/or improve the design of the
vapor degreaser. The degreasers are conventional units with a boiling chamber, vapor or working zone,
cooling zone, and freeboard. TCA usage is 16 tons per year (the shop's air permit allows a much higher
emission rate). Discussions with NADEP personnel indicate that the majority of the TCA is lost through
evaporation. Some TCA is removed as spent material and drummed for disposal. The evaporative losses
from the degreasers could be decreased by retrofitting the units with a refrigeration zone (freeboard chiller),
just above the cooling zone. The refrigeration zone will condense vapors that escape the cooling zone.
Hard Chromium Plating Process Options
Various methods and technologies are presently available that permit nearly 100 percent closed-loop
operation of hard chromium plating processes. In general, these approaches are most effectively applied
when designing and installing new operations due to space requirements and processing configurations.
However, retrofitting existing hard chromium processes can also achieve better efficiency and less waste.
There are six pollution prevention components of a closed loop hard chromium process: (1)
conforming anode plating, (2) recovery rinsing, (3) chromic acid emissions recovery, (4) plating bath
maintenance, (5) caustic strip solution reformulation, and (6) spill and drip prevention. The NADEP has
partially implemented elements 2,3, and 4. A potential approach for completing the existing system follows.
Conforming anode plating refers to the use of anodes shaped similarly to the surface of the part
being plated. These anodes are fabricated from cast lead alloy mats. There are several commercial sources
that specialize in conforming anode production. Use of conforming anodes replaces conventional "stick"
anode plating. The conforming anode method reduces rejects and rework, reduces plating time by a factor
of two to four, and permits a higher loading of plating tanks (i.e., more parts can be plated simultaneously
in the same tank). Higher loading of tanks permits consolidation of operations and the potential for
eliminating 50 percent of tankage.
At present, there are six hard chrome plating tanks at the NADEP. Potentially, three of these tanks
could be eliminated if conforming anode plating is implemented. The space made available could be used
to add additional recovery rinse stations. Counter-current rinsing reduces the volume of rinsewater required.
When a sufficient number of recovery rinses are added, 100 percent of the dragout can be returned to the
plating baths. The reduced air exhaust requirement would permit altering or replacing the mist eliminator
unit (e.g., adding pads that could not be added if the design air flow had to be maintained) and increasing
its recovery percentage (EPA sponsored tests show the mesh pad design can remove an average of 99.7%
of Cr*5 from the airstream).
When dragout and chemicals in the exhaust are recovered, bath contaminants are also recovered.
Eliminating these purges of contaminants will result in a buildup of trivalent chromium, iron, copper and
aluminum; this wll eventually cause the baths will become unusable. To prevent this condition from
occurring, the baths should be maintained. Electrodialyses has recently been applied for chromium bath
maintenance. A single test unit is presently installed at the NADEP. This unit may have sufficient capacity
to maintain all chromium plating baths. If not, an additional unit might be installed.
The spent caustic strip solution can be recovered by the separation of caustic and chromic acid.
The recovery process is performed using a multiple cell eiectrodialysis unit The recovered caustic is reused
as strip solution and the chromic acid is reused for plating tank make up.
85'
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Spils and drips can be minimized through prevention and recovery. As discussed previously, the
potential for spils can be reduced by installing high level alarms. Also, pH and conductivity sensors, with
associated alarm systems, can be installed in floor drains, pits, or at other points in the collector system to
identify spVIs and tank leaks before an entire tank's contents are lost. Drips from parts and racks can be
captured by installing drip pans below the grated floor. The pans should extend across the work isle to
capture solution from parts that are placed onto or above the floor for inspection purposes. The collected
solution can be returned to the plating baths after adequate filtration to remove any dirt and debris. These
devices supplement the use of existing drip guards which effectively prevent drips from failing between
tanks. The pans are mostly needed on processes such as hard chromium plating where parts are often
removed from the tank and placed on the floor for periodic measurements.
Nickel Plating Process Options
The identified pollution prevention options for nickel stripping and electroplating relate to the quantity
of process bath discarded. Preplating process baths such as cleaners and acid dips have a limited life span.
Filtering (in-tank cartridge type) can be used to remove suspended solids and aid in maximizing bath life.
Reusable filter cartridges are available that eliminate the bulky waste caused by throw-away cartridge filters.
Nickel recovery is possible from nickel strip solutions and rinsewaters from stripping, nickel strike
and nickel plate. The NADEP plans to install an electrolytic metal recovery (EMR) unit on the rinse following
sulfamate nickel plating. It may be possible to use the same EMR unit to directly recover nickel from the
spent stripping solutions. Recovered nickel can be used as anode material in the sulfamate nickel plating
tank. If direct recovery of nickel from the strip solutions is not possible, the nickel can be removed using
ion exchange and the EMR unit can recover the nickel from the ion exchange column reagent. Similarly,
ion exchange and EMR can be used to recover nickel from the rinses following stripping and nickel strike.
As with chromium plating, high level alarms and other devices for sensing spills and leaks could be
used to prevent catastrophic chemical losses.
A drip pan located below the grated floor in front of the nickel plating tank could reduce nickel
losses during parts inspection. The recovered chemical could be returned to the plating bath, after adequate
filtration to remove dirt and debris.
Some of the rinse tanks on the nickel stripping/plating line are equipped with conductivity controls
to limit the flow of rinse water. The facility has experienced maintenance problems with the units and most
of them are no longer used. In place of automatic control, this facility relies on the operator to manually
close water valves when the rinse tank is not in use. The Navy should consider the use of pushbutton timer
controls to replace the conductivity units and manual control method. With pushbutton timer controls, the
operator pushes a button located at the rinse tank which activates a timer and opens a solenoid valve. The
valve remains open for a preset time period and then automatically closes. A flow restrictor should be
placed on the incoming water line. Knowing the flow rate through the restrictor, the shop can set the timer
to provide arty needed volume of water. The timer setting should be selected to provide adequate rinsing.
Countercurrent rinsing was considered at the site, however there is no additional space for further rinse
tanks. Reducing dragout through the increase of draintime, thus slowing withdrawal rates from process
tanks, was not considered due to the fact that it is not applicable to manual lines. Also, drainage time can't
be increased with some parts.
The pushbuttons and timers are commonly available equipment than can be procured and installed
by Navy personnel or an electrical contractor. The existing solenoid valves used with the conductivity
controllers can be reused with the pushbutton timer system. This method of rinse water control is especially
suited to intermittent production like that observed at this shop.
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CROSSFEED TO OTHER TIPPP INSTALLATIONS
A minimal amount of electroplating is conducted at NASA-LaRC and at Langley AFB. The general
pollution prevention guidance in this report should find application at other TIPPP facilities, but not on the
scale of NADEP.
MEASUREMENT OF POLLUTION PREVENTION
Good operating practice implementation is relatively easily monitored in terms of water use and
direct waste generation. Other options, such as changeover to aqueous cleaning will require documentation
of current baseline generation data, preferably on a waste per square foot of plated area basis.
IMPLEMENTATION PLAN
Due to the diverse nature of the selected options, implementation will require a staged approach.
The good operating practices option can be immediately implemented through the creation of an internal
NADEP program.
Eliminating the F002 wastes can be achieved through implementation of aqueous cleaning. The
selection of effective cleaning equipment and chemistry will require an investigation of available technology
and some testing. Due to the range of variables involved, the substantial cost of an aqueous cleaning
system and the installation/startup requirements it is estimated that a three year time period is needed for
implementation. During this interim period, use of vapor degreasing should be restricted to the newer unit
which has an integral recovery still. The older unit should be removed from service. Operators should be
instructed to avoid use of vapor degreasing for heavy soil/grease or maskant removal.
Implementation of the selected hard chromium plating options will require: (1) collection of
additional production and waste generation data; (2) design of an integrated hard chromium plating system
that includes conforming anode plating, effective dragout and emissions recovery, bath maintenance, and
spill/drip pollution prevention; (3) phased installation that prevents production shutdowns, and (4) startup
and training.
Implementation of the selected nickel sutfamate plating options also involves a staged plan. Initially,
efforts should focus on bath maintenance (in-tank filters) and spill/drip pollution prevention (high level
alarms, drip pans). These options are relatively inexpensive and easy to procure and install. Implementation
of the nickel recovery options (strip solutions and rinses) will require some initial investigation and testing
to define, and subsequently design, a suitable system. Operation of the system will require skilled labor and
training.
RESEARCH & DEVELOPMENT AND DEMONSTRATION NEEDS
Aqueous Cleaning
Vapor degreasing with chlorinated solvents is an effective and fast cleaning method for a wide range
of organic sols. A single TCA vapor degreaser can meet most of the predeaning needs of shops such as
the NADEP's plating facility. Aqueous cleaning is a more specific technology in that the equipment and bath
chemistry must be more carefully tailored to the application. For many facilities, multiple aqueous cleaning
operations wHI be needed to meet their various cleaning needs. Therefore, before any investigation is
performed, the NADEP should fully define their cleaning needs. This effort should include determining: base
materials, parts, dimensions, soil types, cleanliness criteria, and corrosion protection requirements.
A wide range of cleaning equipment and chemistry is commercially available that can meet nearly
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all cleaning needs. Therefore, the process of finding a substitute method is one of selecting the best existing
technology rather than developing a new one. To select the proper system an investigation should be
performed to find successful applications for similar cleaning requirements. The aerospace industry has
taken the lead in this area and should be consulted. Various technical information sources exist that can
guide the investigative efforts including journal articles, conference proceedings, and government reports.
Once a set of viable methods is identified, testing should be performed to find the most suitable
system(s). Testing can be accomplished through equipment and chemical manufacturers and vendors.
Some chemical testing work can be performed onsite while other testing, such as equipment testing, may
be performed at the manufacturers location. Offsite testing should be viewed by Navy personnel.
Hard Chromium Plating
A data collection effort is needed to develop the design criteria for an integrated closed-loop hard
chromium plating system. The required data includes: workload (e.g., number and dimensions of parts,
plating times, base metals plated), existing ventilation system dynamics (flow rates, pressure drops), dragout
quantities, evaporation rates, and bath contaminant build up rates.
Nickel Sulfamate Plating
Testing is needed to determine the applicability and design criteria for ion exchange and electrolytic
metal recovery technologies. Testing could be performed either onsite or at a vendor's facility.
Baseline data are needed to properly size the selected equipment. The data collection effort should
determine average dragout rates for each process solution and the nickel build up rate in the strip solutions.
These data should be collected over a sufficient time period to show average conditions.
RECOMMENDATIONS/CONCLUSIONS
Good operating practices and collection of baseline data must be conducted as soon as possible.
Both nickel and chrome plating process waste can be reduced by these methods. Significant reduction in
waste operation can be accomplished by implementation of closed loop hard chrome plating, nickel
recovery systems, and use of aqueous cleaning systems.
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September 28, 1992
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
CHEMICAL MATERIAL MANAGEMENT SYSTEM
Naval Base Norfolk
by
Science Applications International Corporation
Cincinnati, OH 45203
and
Kevin Palmer
Science Applications International Corporation
Falls Church, VA 22103
Contract No. 68-C8-0062, WA 3-70
SAIC Project No. 01-0832-03-1021-010
Project Officer
Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U. S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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INTRODUCTION
Chemical materials are an indispensable part of the day-to-day operations of many Industrial
processes. Chemicals may be used for a variety of purposes including raw materials, catalysts, or reactants
during process unit operations. They may also be used in conjunction with on-srte pollution control or waste
treatment operations.
Although essential for many industrial processes, chemical materials have the potential to pose
serious threats to human health and the environment if not managed carefully. Examples of chemical
mismanagement include excessive procurement, poor bookkeeping, unauthorized handling or exchange of
materials by untrained workers, chemical storage in leaky or otherwise unsuitable containers, hoarding and
inappropriate material applications, (i.e., using the wrong chemical for the wrong job). Also, inflexible
procurement systems may require the use of one material when another, less toxic material will do the job
just as well. Any of these scenarios can result in the unnecessary generation of hazardous waste, site
contamination, and/or harm to exposed workers.
Hazards are compounded at large installations, such as the Naval Base Norfolk, because of the
large number of shops requiring the acquisition, storage, and use of chemical materials. However large
complexes can offer economies of scale through centralized inventories, bulk purchases, and employee
training sessions, and thereby achieve pollution prevention opportunities. A well-planned materials
management and training program is essential to ensure the safety of personnel, as well as the pollution
prevention potential and cost-effectiveness of hazardous chemical material usage at Norfolk.
The NSC currently has made limited progress toward control of chemical inventory and in solvent
recovery and a Paint Mart exchange. They do not have a regimented, computerized system for tracking
chemical purchases, matching purchases to processes, identifying viable substitutes or changes to
procedures, and in controlling the large amounts of chemicals disposed each year due to expired shelf life
Such a control system allows systematic environmental reporting, establishment of accountability for waste
generation and chemical use in the workplace, and dearer tracking of usage patterns to reduce shelf life
problems.
This report outlines several strategies for environmentally sound chemical materials management
with an emphasis on computer tracking systems, worker training, and centralized control of acquisition'
handling, use, and disposal of chemicals. These strategies were compiled from a number of sources'
including the experiences of several large chemical companies, such as Dow, Du Pont and 3M as well as
other military facilities. The information for this report was acquired from the Environmental'Protection
Agency's Pollution Prevention Information Clearinghouse (PPIC). The objective behind the chemical
materials management strategy presented in this report is to minimize hazardous waste generation at the
Norfolk Naval Supply Center (NSC) through effective elimination of hazardous materials misuse.
PROCESS REVIEWS
The Naval Supply Center is one of many commands located at the Naval Base in Norfolk Virginia
Its mission is to provide materials and supplies to all naval shore activities east of the Mississippi'river and
all units in the Atlantic and Mediterranean fleets. Among the services provided are procurement, customer
services and industrial support. In addition, the NSC performs equipment maintenance duties and maintains
its own pnnt shop.
Hazardous waste generation from the NSC totaled 404,670 pounds in 1991, including approximately
165,200 pounds of paint, 19,400 pounds of trichloroethylene (TCE), and 129,500 pounds of cleaning
compounds which were discarded as a result of having exceeded their shelf life. The NSC is considered
a pnme candidate for implementation of a chemical materials management system (CMMS)
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ASSESSMENT
Current Chemical Materials Management initiatives
Naval Base Norfolk has already implemented a number of chemical materials management practices
including:
• Direct delivery of chemicals to requestors;
• Approving all new chemicals of safety prior to purchase;
• Investigating nonhazardous substitutes for process chemicals by materials engineers at the
Naval Aviation Depot, Norfolk (NADEP);
• Recycling of process solvents;
• A Paint Mart run by the NSC in which paint is exchanged;
• Solvent elimination studies presently being conducted by the Naval Energy and
Environmental Support Activity.
The identification of spent solvent generators and potential applications of recovered solvents are
among the options identified for future pollution prevention projects.
In addition to the above initiatives, NSC Norfolk and the General Services Administration (GSA) have
coordinated activities to overcome problems encountered by the NSC in obtaining supplies from GSA and
to promote more efficient chemical materials management initiatives. Discussion has focused on shelf-life,
paint testing, packaging and just-in-time delivery.
Shelf-life
The GSA has proposed several methods of supplying shelf-life materials to the NSC Norfolk with
the intent of providing maximum remaining shelf-life. These include:
• Direct vendor delivery of priority chemicals, (i.e. those large order chemicals which create
undesirable shelf-life distribution situations);
• Establishing direct requisition-specific codes to identify those requisitions which may require
other means of support, such as partial issue from stock balances;
• Differentiating between materials which will be directly delivered and those stored;
• Pre-stock agreements between the Navy and GSA for direct delivery materials.
Paint Testing
Through a Memorandum of Understanding between the Navy and GSA, certain Navy shipyards have
been recognized as being capable of conducting paint testing. With this agreement, GSA wUI accept paint
test reports from certain shipyards without the need for further laboratory verification of complaints. This
satisfies Navy and GSA objectives of eliminating the generation and storage of hazardous waste through
expedient return to the vendor of rejected paints, and improving productivity and paint quality.
Packaging
NSC Norfolk has several old storage faculties with storage racks set up for pallets of two-high-
stacking of 5-galion can materials. Often, GSA ship pallets are packaged three high with 5-gallon cans,
meaning that a lot of labor is expended to take apart the three-high shrink-wrapped pallets and re-stack the
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materials two-high. GSA is working to address this packaging problem in order to eliminate the excess
packaging waste and improve productivity.
Just-in-Time Delivery
NSC Norfolk is willing to work with GSA to establish a delivery system that minimizes shop inventory
by distribution close to the time of use Oust-in-time delivery) of materials if GSA can meet the required
delivery dates.
Pollution Prevention Options
As described above, the NSC has initiated several methods of effective chemical materials
management. However, additional measures can be implemented to achieve further waste reductions This
section attempts to identify other pollution prevention alternatives currently available to chemical materials
managers. It should be noted that some of the ideas presented here may already be in use at the NSC
The pollution prevention options presented here are divided into three categories: information management-
management initiatives; and employee education.
Information Management
Careful tracking of quantities and uses of chemicals at a facility can result in more efficient material
use and ensure that hazardous materials are not misused. Comprehensive chemical tracking utilizes a
computer program to track the procurement, storage, distribution, use, disposal of, and recvdinq of everv
chemical purchased. J
Kelly AFB CMMS-
Several years ago, staff at the Kelly Air Force Base-San Antonio Air Logistics Center in Texas
developed a computerized system for tracking chemical material purchases, distribution, processes and
users, and waste generation. The system was developed with government personnel, and is therefore
available to other interested users without charge. The system configuration and program elements are
descnbed in reference 2.
The Kelly CMMS was designed to satisfy the following objectives:
• It must meet required employee "right-to-know" standards;
• The hazardous nature of chemicals used in facility processes must be assessed prior to
use, and that use must be strictly controlled throughout the process;
• A "paper trail' must be used to keep managers informed of the quantities and locations of
materials currently in use;
• Unsafe or unauthorized practices, such as hoarding, improper storage, and/or tradinq of
chemicals must be eliminated.
The CMMS provides a life cycle tracking and control mechanism for chemical materials entering and
leaving the SA-ALC and related staging areas and shops. The movement of chemical materials through the
industrial processes at the facility is rigorously controlled and documented, from raw material inputs to final
product and process waste outputs. The tracking and control mechanisms of the CMMS system serve to
connect all functions connected with chemical materials management including MA, Industrial Hygiene (IH)
supply functions, and chemical staging areas as well as individual shops.
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The heart of the Kelly AFB CMMS system consists of both a computer data management system
(an HP-3000 computer network) and a material tracking form (AFLC Form 3916) which the Center developed
for controlling the use of each chemical. This form serves both as the initial step of the procurement
process and as an on-site repository of material-specific information.
In developing the system, the SA-ALC identified the shops or work areas likely to request chemical
materials. Each was assigned a specific code number for tracking purposes and furnished with a chemical
information management notebook. This notebook contains site specific spill plans, the most recent
industrial hygiene survey for the shop, and the AFLC Form 3916 for each chemical used in the shop.
The Kelly AFB CMMS tracking process begins with the completion of AFLC Form 3916 for each
chemical. By design, only authorized persons may receive a hazardous material under CMMS. In filling out
the form, the requestor must identify the material needed and justify the request by describing the process
for which the chemical is intended and its proposed use. Upon completion, the form is sent to the shop's
engineering support group for approval.
The form is then sent to the MA environmental office for review. Before issuing its approval, MA
checks the requestor's hazardous material training level, the chemical's intended use, the quantity requested,
and the material's hazard against the computer database. If accepted, the form is entered into the database
and forwarded to Industrial Hygiene which adds a Material Review Code, a material hazard classification,
a Material Safety Data Sheet (MSDS), and the time period for which the authorization is valid.
Upon approval, both the MA and the shop receive a copy of the final form and accompanying
information. The chemical is then issued to the authorized person from one of several chemical staging
areas. This process ensures that no unauthorized person can receive a hazardous material, and that
quantities and locations of chemical materials at the Center are documented.
Du Font's Corporate Waste Data Base-
Du Font's Corporate Waste Data Base is another example of a waste tracking system. This system
takes advantage of Digital Equipment Corporation's Datatrieve interactive language, and is designed to run
on VAX/VMS mainframe computer systems. An important feature of Du Font's waste tracking system is its
ability to monitor the progress of pollution prevention measures. The computer program normalizes waste
generation figures to production increases, so that gains in process efficiency are not masked by increases
in overall waste generation. Also, reporting of waste figures is done on an annual basis. This allows for
meaningful comparisons between successive yearly waste generation figures, without requiring excessive
reporting by individual shops.
Management Initiatives
This option encompasses a number of initiatives which can help to increase hazardous material
management efficiency. These initiatives include inventory control, chemical storage, proper labeling, and
reusing chemical containers.
Inventory Control-
Expired shelf-life materials have been identified by the NSC as a major waste generating source.
Strict inventory control is the most effective and cost-efficient way to prevent materials from needlessly
becoming wastes. Inventory control practices range in sophistication from simple operating procedures to
more complex computerized inventory control systems. Despite these differences, all inventory practices
share the common goal of minimizing hazardous waste generation due to expired shelf life or material
obsolescence.
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Simple material control practices include "first-in, first-out" inventory control - that is, using older
materials before new supplies - and direct delivery of process chemicals to specific shops. These practices
prevent excess chemicals from accumulating and minimize the amount of waste generated due to material
obsolescence.
The 3M Company provides an example of a more complex inventory control system Their system
known as "just-in-time inventory control-, is designed on the principle that no more of any given material is
stored at the facility than is absolutely necessary. Just-in-time procurement and delivery are the
cornerstones of 3M's inventory control approach. As such, only the minimum amount of a chemical needed
for a specific job is purchased at a time, and the material is transported to the shop only when it is needed
for production. This type of inventory control system effectively eliminates excess inventory and the potential
for waste from becoming obsolescent material through strict purchasing, storage and transportation control
Despite its pollution prevention advantages, just-in-time inventory control is difficult to maintain because it
requires predictable production scheduling and coordination between the purchasing and the production
departments.
Purchase quantity management, the technique of purchasing only the specific amount of a raw
material for a certain task, is another 3M initiative for effective inventory control. Stockless production in
which the amount of required end product dictates how much of its feedstock will be produced is another
variation of the same concept.
Finally, many out-of-date chemicals can be returned to supply centers and recertified for use or
returned to the chemical supplier. Some suppliers will even give credit for returned materials against future
purchases. It is important to remember that disposal of materials should take place only after other pollution
prevention options, such as materials recertification and return, have been considered.
Chemical Storage-
Proper chemical storing and handling can reduce the needless loss of materials. There should be
an ensurance that chemicals are compatible with the containers and conditions in which they are stored
For example, organic solvents should be stored under proper conditions so that they do not undergo
temperature extremes. Routinely check storage areas for damaged or leaking containers, and promptly
correct identified situations. Storing chemicals off the ground (on pallets or shelves) simplifies the task of
identifying leaking or damaged containers. Finally, keeping lids closed and bungholes tightly plugged
prevents the evaporation of solvents, reduces spills, limits contamination from dirt and moistuTe and
minimizes health risks and air pollution.
Material Identification-
Perfectly good chemicals may enter the waste system due to improper or missing identification or
labeling. Keeping container labels up to date, including names, expiration dates, and other pertinent
information can prevent this waste source. One suggestion might be to install a bar code system for
hazardous material containers. In such a system, each container is issued a unique code that records the
chemical content the recipient, the date it was issued, the chemical's intended use, and the chemical's
expiration date. This would make additional information available while allowing for easier tracking of the
chemical through its life cyde.
Container Management-
Empty material containers often contain hazardous residue, forcing the containers to be disposed
of as hazardous waste. Many suppliers will accept returned containers for reuse as part of their pollution
prevention effort. In addition, purchasing large-sized containers may reduce the number of partially filled
or empty containers in the management life cycle. However, according to the American Chemical Society
purchasing chemicals in exact quantities and in smaller containers may prove more cost-effective thari
purchasing large "economy-size" containers, due to the costs associated with disposing of any excess
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chemical. The decision on which size container to buy therefore depends on the relative demand for the
chemical and the probability that excess chemicals will exceed their shelf life.
Material Substitution-
Many nontoxic substitutes are now available for hazardous chemicals. For instance, aqueous,
biodegradable cleaners can be used instead of halogenated solvents in many cleaning operations. Using
these materials can eliminate hazardous waste generation fr-m many process operations, and eliminate
having to stock, store and track hazardous materials.
Waste Exchanges-
A waste exchange allows one facility to sell or give its waste to another facility which can use the
waste as a raw material. Generally, a waste exchange lists both those who have materials available and
those who need them. Exchanges can be conducted "in-house" or between facilities, and can reduce
disposal and raw material purchases while promoting environmental protection. Of course, use of a waste
exchange should be considered only as a last resort, after all other source reduction opportunities are
exhausted.
Employee Education
A well-trained staff is the cornerstone of any successful chemical materials management program.
Every employee should receive training in the following areas:
• The importance of pollution prevention;
• Proper use and handling of the chemicals used in the shop;
• Spill prevention and safe cleanup;
• Proper disposal and/or recycling practices for all chemicals used in the shop.
Properly trained employees can help to ensure that the correct chemical is used for the correct job,
and that chemicals that can be reused, recycled or otherwise segregated from the waste stream receive
appropriate handling.
FEASIBILITY
Following the initial pollution prevention assessment a feasibility analysis was conducted for each
component of the pollution prevention options using a modified Worksheet Number 13 (Waste Minimization
Opportunity Assessment Manual, p. A18, EPA/625/7-88/003). Each option was rated qualitatively for a
number of different criteria since quantitative data were not available. Table 1 displays the data. A brief
discussion of each option is presented below.
Chemical Material Management System (CMMS)
Computer data base tracking systems are available in a number of different forms. The NSC would
likely require a system similar to the one used by SA-ALC which is available free of charge from the Air
Force Material Command (AFMC). There will most likely be substantial institutional resistance to the extra
work load required by the new reporting practices. In addition, the time required to get the CMMS started
may create resistance to the system. One year of data input was required to obtain the funding and
installation of seven chemical distribution centers for the CMMS.
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Inventory Control
The feasibility of Implementing just-in-tlme inventory control depends on several factors, including
shop operating requirements, Institutional resistance to the extra planning required, and quick turnaround
of chemical procurement requests. Ships pose a special set of complications to just-in-time scheduling
since the delivery of materials is hindered by the vessels' deployments away from the naval base and the
supply center.
In addition, ships create difficulties for inventory control due to the length of time a vessel is at sea
which can be a large factor in determining which chemicals are stocked. Enough chemical materials for
an entire voyage may have to be purchased and transported aboard at one time. Estimating the correct
amount of a specific chemical required for a job can be difficult If the pb is not done well, certain
chemicals may not be used and will have to be returned. If the vessel does not return to port pnor to the
chemical's expiration date, it will become obsolescent and will have to be recertified, returned to the
supplier, or disposed of as waste.
Rrst-in, first-out inventory is crucial since the number of different operations for which a chemical
may be used is more limited aboard ship than at the base.
Chemical Storage and Material Identification
Container labeling practices and bar coding should be much easier to implement since they simply
require an increased awareness and attention to detail on the part of inventory workers. Employee
education will help rake implementation go smoothly.
Container Management
Planning and cost/benefit analysis should be done for each chemical before the various container
management schemes, such as correct-size purchasing and container recycling, are implemented. Most
suppliers should be willing to work with the NSC in implementing a container return/optimal product-sizing
system.
Material Substitution
A number of substitutes for hazardous chemical materials are currently available in the marketplace.
However, research will need to be done to identify and test these materials under base conditions. In
addition, military specifications may need to be changed to allow substitution of materials.
Waste Exchange
Waste exchanges, both "in-house" and between facilities, are an efficient method of reducing
disposal and raw material purchases. This concept may be applied to the NSC in two ways. One would
be to partteipata in a waste exchange outside the base, such as the exchange serving the Tidewater area
which is currently under development. The other would be to expand the concept of the Paint Mart to
include other materials, such as cleaning compounds.
Employee Education
Training and technical information from other chemical supply centers in the military should be
investigated for applicability with the NSC. In particular, SA-ALC's experiences may prove to be a valuable
resource.
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CROSSFEED POTENTIAL
The information management systems discussed in this report have the potential to be adaoted for
use at ail other TiPPP facilities. The chemical management initiatives and employee Sducatio^ options are
also widely applicable, and are in fact utUized in chemical material management operations in both the DubHc
and pnyate sector As with the NSC, other facilities would have to conduct a numbed p£n^£
before the feas.b.lity of any of the options discussed in this report could be fully evaluated
MEASUREMENT OF POLLUTION PREVENTION
Measuring the impact of pollution prevention activities requires baseline data on chemical material
types, costs and volumes, as well as handling and disposal costs and volumes. Other categories of required
information include inventory maintenance costs (physical plant, administrative, overhead etc)
transportation costs (equipment, labor, maintenance) and sales of surplus inventory, in particular those from
the Paint Mart. Although this information apparently exists, it was not made available by the time this reoort
was written * «pv/n
imnin ^ t^is11baseljne da te has been established, a given set of pollution prevention measures may be
mplemented. Following implementation, a database similar to the one outlined above should be Gathered
^CJJ^etand ldentif£ Pr°gT benefitS' ln °rder to ensure a reliable comparison, the new system should
%?££ aPSr^ff 3 steadyn state before data js col|ected. Anally, adapting some of the normalization
and reporting-period features of Du Ports Corporate Waste Data Base to the NSC system will permit more
accurate assessments.
IMPLEMENTATION
As with any major procedural change at a large industrial setting, there wHI likely be significant start-
up delays assorted wrth the CMMS. Initial implementation of the CMMS at Kelly AFB dU nTmn as
SA"A ° Planned' RrSt' constructlon lead *"•• ^ the chemical staging are^sdSTyS
***** ** "* ^orms to <*** *™& ** entire sySem turned
n a K Primarily t0 the dlfflculty of aoc»*lnfl sufflcient techni data to support
9 C " °3 9IVen ^ Thlrdt the "***™ ™* Wft«y hesitant to accept the new
OP °f 3" JnVOlVed <*«**' However' in tlme thls ^uctance vanished
personnel gained expenence and recognized the benefits of the life cycle tracking system.
RESEARCH DEVELOPMENT AND DEMONSTRATION NEEDS
» *• '" ^Wl° °Ptlmlze tne ^"e^8 from the installation of a CMMS, the NSC should undertake several
stud,es to identify which option or combination of options fits best with the available Za^mS
management needs. These are briefly outlined below: 9
* MMS' SA-ALCs and Du Pont>s'
n^r ,
iK ^ t?y^3ble t0 lm**Bm&[« eitner sy^em in its entirety, or develop its own
tracking system code that implements the best features of both systems. In addition there are
other computer-based material management systems that should be investigated.
Management Initiativ^ - Cost/benefit analysis of many of the management initiatives presented in
the Assessment section should be undertaken before any are implemented. For instence the
conflict over the cost efficiency of buying in bulk or on an as-need basis should be sTuoW Only
by analyzing specific situations and needs can such questions be resolved
98
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Employee Education - As is the case with management initiatives, cost/benefit analyses should be
undertaken before any training initiatives are implemented. Questions such as whether it is more
cost-effective to train one responsible person for each shop, or if all workers should receive at least
some training should be answered before implementation of a training program.
RECOMMENDATIONS/CONCLUSIONS
Of the pollution prevention options listed above, the CMMS, just-in-time inventory control, and
increased use of waste exchanges all require additional study prior to implementation. Tight budgets may
preclude the full implementation of one or more of these options, especially the CMMS. One approach
might be to select high visibility waste streams (paints, TCE, cleaning compounds, etc.) for selective
implementation, then to expand these programs as budgetary constraints permit. Other options, such as
chemical storage and material identification, may have a lesser pollution prevention impact but will probably
be easier to implement. Material substitution may be the most cost effective option presented for immediate
hazardous waste stream reduction, but its application as a technique may be limited.
99
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REFERENCES
1. American Chemical Society, Department of Government Relations and Science Policy 'Less is
Better - Laboratory Chemical Management for Waste Reduction', Washington D.C. 1985.
2. Chabot, Robert I/Hazardous Chemical Control in a Urge Industrial Complex", JAPCA, Vol. 38, No.
9, September 1988.
3.
"HazWaste Processes and Quantities, Naval Base. Norfolk Listed by Commands/Activities"
rS^
4. Hollod, G.J.
5' SSI in°w S; "1;— M;nlrTT9 Waste ^ Source Segregation and Inventory Control", in Case
Studies in Waste Minimization Government Institutes, Inc., Rockville MD. October 1991. ~~
6. Naval Base Norfolk, "Pollution Prevention Projects", draft. January 6, 1991.
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September 28, 1992
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
NAVAL AVIATION DEPOT, NORFOLK, VIRGINIA
MACHINE COOLANT FLUIDS
by
George Cushnie
Science Applications International Corporation
Cincinnati, Ohio 45203
EPA Contract No. 68-C8-0062, WA 3-70
SAIC Project No. 01-0832-03-1021-010
Project Officer
Mr. Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
101
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INTRODUCTION
Purpose
The purpose of this project was to conduct a Pollution Prevention Opportunity Assessment (PPOA)
for selected processes at NADEP's Machine Shop. The assessment was conducted for the EPA's Risk
Reduction Engineenng Laboratory under the purview of the Tidewater Interagency Pollution Prevention
Program (TIPPP) of the Pollution Prevention Research Branch. The procedure described in the EPA Waste
Minimization Opportunity Assessment Manual (EPA/625/7-88/003) was used to conduct the studv~~The"
manual provides detailed worksheets and a process/option evaluation method for use in industrial settings.
Approach
A PPOA consists of four systematic steps: Planning and Organization, Assessment, Feasibility
Analysis, and Implementation. Figure 1 presents the PPOA process. Of the 19 worksheets in the PPOA
manual, selected sheets were completed for the processes and waste minimization options considered The
detailed worksheets used are presented in Appendix A. The implementation of the recommended options
presented in this report is at the discretion of the host facility.
PROCESS REVIEW
The Naval Aviation Depot (NADEP) at Norfolk, Virginia is one of six U.S. Navy facilities where aircraft
are routinely overhauled. Each of these facilities employs up to 4,000 skilled industrial workers The NADEP
at Norfolk performs rework of F14 and A6 airframes, engines, and landing gear. The aircraft rework process
consists of complete disassembly, inspection of reusable parts, remanufacturing of parts, reassembly and
testing The remanufacturing operations include numerous machining and metal finishing operations which
generate significant quantities of hazardous and oily wastes. The focus of this study wis machining and
gnnding which is performed in building LP-24. This facility contains approximately 100 machines used for
manufacturing new aircraft parts and remanufacturing used parts.
nono^t ™? '***? ^SenlS ?* r6SUltS °f ** ™c*™"9 and Sending PPOA. These two operations
generate oily waste as a result of discarding used machining and grinding coolants and hydraulic oils.
Coolants are d.scarded when they become contaminated with solids and tramp oil and/or become rancid
Due to rts chromium concentration, the spent coolant is discarded as a hazardous waste. Hydraulic oils are
^ ^ ^ C0nteminated wrth SOWS -A* -oisturr Both wastes
General Oveivlew of NADEP Machine Shop
The NADEP machine shop is located in two adjoining buildings (V-28 and LP-24) that have the
appearance of a single building. In addition to housing a portion of the rUchining operations Z*Z LP-
old and
e . cn machines and equipment in the machine shop rangVin
o 10 so years. 9
Machining and grinding operations at the NADEP were recently grouped into a cellular organization
s method, machines that work on the same parts are grouped together rather than r—-'~ --
(e.g., locating all drill processes of milling equipment in the
d tnM+ •!***£«• MA* ».. — ^1 i _ * • ..
responsibjity and ownership among machinists and results in higher facilVworrarel^^ter^fw
ZSomthe' ^~r9anCatl0n etWnated «^ "eed for approximately 25 machos which ^
102
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Tha rteognizad naad to minimfea
PLANNING AND ORGANIZATION
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ANALYSIS PHAM
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FIGURE 1. THE WASTE MINIMIZATION ASSESSMENT PROCEDURE
103
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The cellular organization presently includes six cells. A seventh cell is under construction The kev
operations in each cell include: '
Cell 1 - Turning
Cell 2 - Milling
Cell 3 - Large turning, grinding
Cell 4 - Cylinder grinders, drill presses
Cell 5 - Large milling, drill presses
Cell 6 - Small turning, grinding
Cell 7 - Flexible manufacturing system (FMS), numerical controlled mills
The machining shop manufactures and reworks approximately 6,200 different aircraft parts with a
wide range of base metals from aluminum to high tensile steel. A central computer is being installed that
will track the inventory of parts and permit use of the "just-in-time" inventory concept. This plan is expected
to reduce operating costs. Also, a separate computer has been purchased to provide statistical process
control (SPC). The types of data that will be tracked include total parts manufactured, reject rate, and tool
life. The SPC program is expected to increase efficiency at the facility and reduce operating costs.
The NADEP machine shop has an excellent housekeeping program. All equipment is laid out in
an orderly and organized fashion. No unused equipment is present that could clutter work areas An area
under reconstruction (Cell 7) was clearly roped- off to prevent co-mingling with production areas Floors
are kept relatively free of chips, dirt, and debris, and no fluid leaks were found. These conditions deserve
a tribute to management, engineering and machinists. Such conditions, by themselves, reduce the
generation of pollution by reducing contamination of machine fluids. Also, they create an amenable
environment for the implementation of other pollution prevention options.
Machine Coolant and Hydraulic/Lubricating Oil Usage
Machine coolants are used primarily for cooling and lubrication during machining and grinding
Cooling is needed to remove heat from the tool and workpiece that is generated by the friction of the metal-
on-metal contact. If left uncontrolled, the high temperatures would eventually damage the workpiece and/or
the tool. A good coolant allows a faster production rate for a given tool life than a poorer coolant would
for the same given tool life. When the chip-tool interface is lubricated, the cutting operation becomes more
efficient and less heat is generated than without a lubricant
Water is an excellent fluid for cooling. It is capable of dissipating heat 2tt times faster than the type
of oil typically used for machining. However, water is a very poor lubricant and it causes rust For
lubrication, Oy is a much better fluid. [1 J Therefore, coolant formulation strategies often lead to combining
these two fluids to give overall satisfactory results.
In addition to lubrication and cooling functions, a coolant must also inhibit corrosion and bacterial
growth, and be free of objectional odors. A coolant must also be nontoxic both for inhalation and for skin
contact.
__ „ **VaJy tnere are various types of machine coolants in use; the choice depends mostly on the
cooling/lubricity requirements and cost. The available coolants can be categorized into four groups-
synthetic, semi-synthetic, straight oH, and soluble fluids. Synthetic fluids are generally more expensto than
other types of coolants; however, they also last longer. Straight oils are used infrequently due to health and
safety problems such as fire hazards and slippery floors. Water soluble fluids are the most commonly used
They contain an oil and an emulsifying compound and are dUuted with water for use. The water provides
cooling and the oil provides lubricity. [1][2]
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Hydraulic/lubricating oils are used in metaiworking operations for non-contact purposes such as
transferring energy hydraulically and lubricating gear boxes and moving parts in metaiworking machines.
Except for way lubrication, these lubricating oils and greases are contained within enclosed reservoirs in the
individual machines. [2] Way lubricant is used to lubricate the surface or slide (way) on which the carriage
of a lathe, etc. moves along its bed. Straight oils are typically used for these applications; however, soluble
oils can be used under certain conditions.
There are a total of 100 machines in the NADEP machine shop. The average machine coolant sump
size is 50 gallons (5 to 200 gallon range). Therefore, the total machine coolant capacity is approximately
5,000 gallons.
Two types of machine coolants are employed at the NADEP. These include Microcut 5863, which
is used for machining, and W&B Grinding Coolant E-55 (referred to as E-55) which is used for grinding.
Both products are water soluble fluids. The annual quantities of coolant purchased are 8 drums of Microcut
5863 and 4 drums of E-55. The purchase costs are $6.85 per gallon and $15.36 per gallon respectively.
Microcut 5863 is diluted with tap water to a 5% concentration for use and E-55 is diluted to a 2%
concentration. Therefore, the total quantities and unit costs of diluted coolant are:
* 8,800 gal. of 5% Microcut 5863, $0.34 per gal.
* 11,000 gal. of 2% E-55, $0.31 per gal.
Data concerning hydraulic oil type, use and cost are not available.
Machine Coolant
Coolant replacement is necessary when the coolant becomes contaminated leading to degradation.
There are various interacting factors that affect the rate of coolant degradation. The primary contaminants
of coolant are tramp oils such as way lubricant that is flushed into the coolant system during machining and
hydraulic oil that is contributed through leaking hydraulic seals. Other contaminants include metal particles,
grease and dirt. Bacteria can grow in a coolant and tend to flourish in contaminated coolant. The use of
poor cleaning techniques between coolant changeouts hasten the growth rate of bacteria.
Two general types of bacteria are found in coolant systems: 1) aerobic, which multiply in the
presence of oxygen, and 2) anaerobic which propagate in the absence of oxygen. The anaerobic bacteria
produce hydrogen sulfide as they degrade coolants which is responsible for the rancid or "rotten eggs" odor
of some coolants. Although the odor is unpleasant, it is not an indication that the coolant is degraded in
terms of capability. Aerobic bacteria consume coolant constituents and reduce the lubricity and corrosion
inhibition properties of the fluid. [3] The bacterial life cycle while "eating" the fluid concentrate also results
in the deposition of various acids and salts. These can cause rusting/corrosion of machine parts, tools and
work pieces. [1]
The degraded and rancid coolant creates a very unpleasant working condition and a potential health
hazard. At the NADEP, the determination of when coolant sumps/reservoirs will be changed is made by
a supervisor at the request of an operator. Most sumps are changed every one to three months. The
removal, cleaning, and replacement of coolant is performed by the Maintenance Department.
The waste coolant generation rate reported by the NADEP is 178,000 Ibs. per year (21,340 gpy).
This quantity is slightly higher than the diluted raw material usage rate (19,800 gal.). The difference can be
accounted for by: 1) over dilution during usage; 2) reservoir wash-out water being combined with spent
coolant; and/or 3) the data representing slightly different time periods.
105
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1.1 ^ ^T ! C^ant reservojr is changed, the spent coolant is pumped into 55-gallon drums and
shipped offsite for hazardous waste disposal by the Defense Reutilization and MarketingOffice (DRMO)
The spent codant contains chromium in excess of RCRA criteria for a toxic hazardous wasT(CX)07) The
cost of transportation and disposal is $2.10 per gal. or $41,580 per year
Hydraulic/Lubricating Oils
Hydraulic and lubricating fluids used at the NADEP are straight oils. The condition of these oils is
routinely checked by the Maintenance Department. During use. these oils become conMnMdrtAW
cot°oT™Ch!n! ±mcnf Wh'Ch ^ damage maCn'ne 'Ubricati0n and nydraulic **««"*• D"« »»ne high
tef NADEP priori^ °r replacement' «"*«**o hydraulic and lubricating oils in good condition
n«r WM, TH Y; ^ ^9**-°* these oils on an as-needed basis which has averaged two times
c"*™ so" was
WM,
nST ! c"*™^ so" was d™™*d and sent offsite for nonhazardous disposal. Recently the
NADEP purchased oil filtration equipment for maintaining and extending the useful lifeof these oils
Th« fi.t J?9 S6leCted flltratl?n equipment is a P°rtable unjt wlth a ' hP motor and a filtration rate of 12 gpm
The filtration equipment and motor are mounted on a hand truck or dolly for portability It contains a 1 00
rcl^Vr^ "?,*" dUPl6X dJSPOSabl6 fllterS' °ne Set for ^rticul*e remL tw^rnch "
°n W3ter adSOrti '
Set for ^rticul*e rem twnch
adSOrpti°n (tW° 1 1'lnCh' 1° micron filters>' Various replacement filter
»~ , ratm9S 3re aV3ilable (3 10 20° microns>- ^ filtratlon unft ^ two 10 ft. flexible
hoses (inlet and outlet) for connecting to a machine or drum. There is a drip pan located beiowthe
^
ASSESSMENT/FEASIBILITY
A list of potential pollution prevention options is presented in Table 1 that were identified durina the
assessment phase. The following is a description of each option. "entitled during the
and uM^*SSl?!S!"n'JSlnq *?* <^mrnl DePendin9°n«"» characteristic of the machining operation
and usage, coolant should be monitored on a daily to weekly basis. Higher usage rates and condiHom
conduct, to evaporation or contamination require daily monitoring. Monitoring3 «££ mtt?£
ollowing measurements and observations: pH. specific gravity (refractometer), t«al dissolved S(TDS)
™"8"' 8nd tad-* COUnt f™8 and bacteria count a~ n« needed more^u^Ttten 1 -r
rrc^
prevent c
_^ ldj"frY Osmium Source and Implementation Wasta Sagreoation Plan The soent coolant is
currently discard^ as a hazardous waste because of its chromlim^ontent The source^chrl^um
and -
waste coolants should be segregated to reduce the quantity of hazardous waste discarded
,„ ,h U88 Peionizej (PI) Water for Coolant Maka-un ann Pvaporatlon Ranto^m^n. Hardness present
'" *e
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TABLE 1. POTENTIAL POLLUTION PREVENTION OPTIONS
Option*
Potential Impact
Estimated Capital
Coat
Machine Coolant
Fraquent coolant tasting and control
Hydraulic and lubrication system
maintenance
Identify chromium source and
implement waste segregation plan
Use deionization water for coolant
makeup and evaporation replacement
Use concentrated coolant in hydraulic
and lubrication systems where possible
Assign coolant testing and
management to a single qualified
individual
Sterilize coolant reservoirs during
change-out
Utilize cellular organization to track
coolant usage costs
Incorporate elements of fluid
management into existing SPG system
and total quality management
program. Relate coolant quality to tool
life, work quality and reject rate. Track
and report machine coolant waste for
each machine and organizational cell.
Periodically filter coolant to remove
contaminants
Recycle used coolant either using Navy
purchased equipment of an onsite
recycle service
Hydraulic and Lubricating Oils
Replace current fluids with high quality
fluids containing additives which
extend the life of the oils.
Replacement of hydraulics with
electrical systems
Frequent monitoring will identify coolant quality problems $2,000 (laboratory
before the coolant is degraded beyond the point where it equipment only)
can be corrected. Controlling coolant parameters within an
operable range will extend coolant life.
Preventative maintenance, including periodic replacement of
hydraulic seals will reduce contamination of coolant with
tramp oil.
May reduce the quantity of spent coolant that is disposed of
as a hazardous waste
May reduce the disposal frequency of coolant
Will reduce hardness contamination of coolant and extend
coolant life
Will add consistency to coolant management program and
reduce losses caused by ignorance
Will retard the initial growth of microorganisms and extend
the life of the coolant
Due to the importance of cost in the overhaul process,
identifying particular problem cells with eventually lead to
better coolant management
Will generate data useful in evaluating production quality
and costs. Also will identify problem areas and eventually
reduce coolant waste generation.
A cartridge filter system will remove suspended solids for
the used coolant and extend it* useful life.
Will reduce the quantity of coolant sent to offsite disposal.
Will reduce the quantity of oil disposed of
Newer electrical system can replace hydraulic systems on
some machines. Conversion would be performed during
machine overhaul. Conversion will eliminate a major spent
hydraulic fluid and minimize coolant contamination for that
particular machine
use, water evaporates from coolant. If the evaporated water is replaced by water containing hardness, the
hardness concentration of the coolant will increase, if waste minimization methods are used to extend
coolant life, then the hardness concentration will reach intolerable levels. Softened or 01 water can be used
to formulate coolant and for evaporative makeup without adding hardness. A small water softener or Dl
system can be purchased or leased.
107
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The cost of
108
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a less direct method of transferring power and therefore, are less efficient. The additional energy usage
would need to be evaluated on a case-by-case basis.
Replace Current Hydraulic/Lubricating Fluids with Higher Quality Fluids. Like coolant systems, there
are various qualities of fluids available for hydraulic/lubricating systems. Except for synthetic hydraulic oils,
most hydraulic oils are made from the same base oil (mineral oil). However, the additives vary from oil to
oil. Sophisticated additive packages are available that increase the Itfespan of the oil and improve machine
operation. Synthetic oils may provide similar improvements and should also be considered. The number
of fluids selected should be minimized to reduce the efforts associated with fluid control and maintenance.
CROSSFEED TO OTHER TIPPP INSTALLATIONS
Machine coolants are used at least in some amounts at all four TIPPP facilities. Options that are
supplemented should be measured as to their success, and described in detail at regular TIPPP monthly
meetings.
MEASUREMENT OF POLLUTION PREVENTION
Many of the options presented in this report are relatively easily measurable. Extending the life of
coolants and elimination of some hydraulic systems with electrical components would result in immediate
reduction of waste quantities generated.
IMPLEMENTATION PLAN
In general, the suggested implementation plan (Table 2) involves a staged approach with
organizational options implemented first, followed by inexpensive source reduction options, then moderate
capital intensive source reduction options, and finally recycling. Proceeding in this manner will result in a
highly organized and efficient fluid management program with an optimal return on investment and maximum
waste reduction.
Organizationally, the plan suggests that a single person be assigned the responsibility for coolant
testing and management. This person would report to the machine shop supervisor for this particular task.
He or she would make decisions on methods of controlling fluid condition and determining if a coolant
changeout is necessary. The existing SPC and Total Quality Management Systems should be used to
support a fluid management program. For example an SPC system can be used to identify the impacts of
extending coolant life on work quality and tod life. Use of the cellular organization is suggested for
accounting purposes, to highlight both positive and negative coolant use and disposal frequency.
The inexpensive source reduction options, moderate capital intensive options, and recycling options
(if implemented sequentially) will reduce, in a step-wise manner, the quantity of waste sent to off-site
disposal. Also, by implementing the less expensive and complicated options first, the quantity of waste
managed by subsequent, more expensive options, will be less.
The key inexpensive source reduction option is frequent coolant testing and control. This effort
should be performed by the assigned coolant management person. The initial task would be an inventory
of all machine sumps and reservoirs. The inventory should identify the machine, type and age of machine,
sump or reservoir capacity, hydraulic/lubrication systems, and a measure of relative use. Subsequently, the
coolant management person would develop and initiate a testing and control plan, and implement remaining
inexpensive source reduction options.
109.
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The success of implementing the inexpensive source reduction options may reduce the need for
moderate capital intensive source reduction options. A reevaluation is suggested at this point to estimate
the impact of these additional source reduction options. Several of these options require that preliminary
investigative work be performed. This is described in the next section.
The need for and the cost effectiveness of recycling will also require reevaluation once the source
reduction options are implemented. The unit cost of recycling will increase as the quantity of recyclable
material decreases.
RESEARCH, DEVELOPMENT & DEMONSTRATION NEEDS (RD&D)
Most of the pollution prevention options suggested for the NAPED have been previously
implemented at other locations. There is not a need for basic RD&D. However, some investigative efforts
and testing are needed before certain operations can be implemented. The following is a brief description
of this work.
Material substitution is a potential source reduction method in terms of: 1) using higher quality
fluids for coolant requirements and hydraulic/lubrication needs, including possible use of synthetic fluids;
2) use of same coolant product for machining and grinding, and; 3) use of concentrated coolant for
hydraulic/lubricating systems.
Prior to an evaluation of these substitution options, the NADEP should establish baseline data from
experience with existing fluids. This suggestion, in part , relates to use of the SPC system to aid in fluid
management. Once established, the baseline data can be used as a starting point to investigate alternative
fluids with fluid manufacturers/suppliers. Using the performance data, a short list of potential alternatives
fluids can be identified and tested. Testing should be performed on representative machines covering the
various applications where the fluids may be substituted.
RECOMMENDATIONS/CONCLUSIONS
Several options exist for reducing waste generation of various machine coolants at NADER. The
implementation plan and RD&D needs described should be initiated and their effects measured.
-------
REFERENCES
1. Master Chemical Corporation. A Guide to Coolant Management. Perryburg, OH, 1986.
2. Higgins, Thomas. Hazardous Waste Minimization Handbook, Lewis Publishers, Inc. Chelsen, Ml,
1989.
3. Ebasco Environmental and CAI Engineering, Hazardous Waste Minimization at Air Force Plant
No. 6, 1992.
4. Earth Technology Corporation, Waste Minimization at Air Force Plant 6, Prepared for U.S. Air Force,
Aeronautical Systems Division, November 1985.
112,
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August 6, 1992
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
FT. EUST1S GOLF COURSE
NUTRIENT MANAGEMENT
by
Gary Gaunt
Science Applications International Corporation
Falls Church, Virginia 22041
Cincinnati, Ohio 45203
EPA Contract No. 68-C8-0062, WA 3-70
SAIC Project No. 01-0832-03-1021-010
Project Officer
Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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INTRODUCTION
Golf courses have long been recognized for their recreational and aesthetic values. By preserving
large areas of open space in increasingly urbanized areas, golf courses serve many important functions,
including:
• provide wildlife habitat;
• provide buffer areas which help to mitigate flow and pollution impacts from runoff;
• enhance real estate value;
• provide noise abatement.
Despite these many benefits, golf courses can become damaging to the environment if sound land
management practices are not followed.
Certain aspects of gotf course nutrient and land management have the potential to increase point
and nonpoint sources of pollution if not conducted property and with care. Some of these impacts were
addressed in a comprehensive literature review (Spectrum Research, Inc., 1990) conducted for the United
States Golf Association (USGA), including:
• leaching losses of nutrients and pesticides to groundwater;
• runoff losses of sediment, nutrients, and pesticides;
• degradation of stream and lake quality resulting from sediment, chemical, and thermal
pollution;
• excessive use of water resources for irrigation during drought conditions and in semi-arid
and arid climatic zones;
• exposure of beneficial soil organisms, wildlife, and aquatic systems to pesticides;
• soil erosion and sediment transport during construction and from disturbed riparian zones;
• disturbance or loss of wetlands;
• disturbance and toxlclty impacts on wildlife;
• runoff of contaminants from parking lots and maintenance facilities;
• development and resurgence of insect and disease populations resistant to current chemical
management strategies.
This paper does not address all of the potential impacts listed above. Instead, it primarily examines
those related to the impacts of gotf course management on nutrient (and, to a lesser degree, pesticide)
pollution of surface and ground water. This focus was selected because Fort Eustis is located in the
Chesapeake Bay watershed, where issues associated with excess nutrients in water are of primary concern.
Nutrient enrichment (mostly nitrogen and phosphorus) is currently recognized as the major water
quality problem lacing the Chesapeake Bay. Elevated levels of certain toxic materials (e.g., pesticides) have
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also been noted and are beginning to receive attention, but the focus of most current programs is on
nutrients. Water quality modeling estimates suggest that nonpoint sources (e.g., runoff from agricultural and
urban/suburban areas) contribute 67 percent of the nitrogen and 39 percent of the phosphorus entering the
Bay, with point sources (e.g., wastewater treatment plants) contributing the balance (Chesapeake Bay
Program, 1988), of leachate.
The results of nutrient enrichment can be devastating to the aquatic environment and have
contributed directly or indirectly to an array of interrelated problems in the Bay, such as:
• algal blooms and eutrophication;
• decrease in dissolved oxygen levels throughout the Bay, with many areas becoming
depleted of oxygen at certain times of the year;
• decline in the BaywkJe abundance of submerged aquatic vegetation;
• decline in harvests of finfish and shellfish;
• decline of waterfowl.
Phosphorus and nitrogen are associated with eutrophication of surface water. Phosphorus is more easily
bound to sediment than nitrogen. Since phosphorus is readily adsorbed by surface soils, it seldom
contaminates ground water. However, transport of phosphorus to groundwater is possible if excessive
loading of fertilizer or manure phosphorus is applied to sandy soils with limited phosphorus adsorption or
buffering capacity. Nitrogen, especially the non-adsorbed anion nitrate, is more soluble than phosphorus
and is the principal nutrient detected In appreciable quantities in subsurface water.
Concerns about the nutrient enrichment of Chesapeake Bay waters and associated water quality
impacts has lead to a concerted effort to reduce and control these sources of pollution. Most of these
efforts are guided by milestones established in the 1988 BavwkJe Nutrient Reduction Strategy. The Strategy
called for tightened point source controls and increased emphasis on reducing nonpoint source nutrient
loading from agricultural and urban/suburban sources. To achieve these goals, the jurisdictions are
implementing a variety of actions and programs, and are depending on the cooperation and participation
of all entities within the Chesapeake Bay basin. The problems in the Bay stem from the cumulative impacts
of a wide array of activities of varying sizes and pollutant loadings. Cleanup activities for the Bay are
addressing all levels of contributors, from the individual homeowner to larger corporate and government
entities, with the recognition that all Improvements, no matter how small, can help improve water quality in
the Chesapeake Bay. The most recent initiatives within the Chesapeake Bay are focusing on pollution
prevention, with the goal of stopping pollution before it starts.
This report outlines several strategies for environmentally sound golf course management, focusing
primarily on nutrient and pesticide management These strategies were compiled from documents provided
by the United States Golf Association (USGA) and the Virginia Cooperative Extension Service (VCES). The
report also describes a set of "Watershed Nutrient Control Standards", initially developed for commercial
lawn care companies by the Northern Virginia Soil and Water Conservation District, Northern Virginia
Planning District Commission, Virginia Cooperative Extension Service, and the Lake Barcroft Watershed
Improvement District The golf course management strategy presented in this report is a comprehensive
approach for reducing the water quality impacts from golf courses. Fort Eustis is already implementing
many of the suggestions contained in this report; the entire strategy is presented as guidance for ways Fort
Eustis and similar facilities could enhance their current approaches. This report also introduces an option
for using domestic wastewater and/or sludge material from the Fort Eustis Sewage Treatment Plant as an
organic alternative to the currently used chemical fertilizers.
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PROCESS REVIEWS
The Fort Eustls golf course is located on a triangular piece of land bounded to the northeast by the
Warwick River and to the southwest by the James River. The 18 hole golf course covers approximately
70 to 80 acres and is primarily located adjacent to the Warwick River. In many places the golf course lies
within 2,000 feet of the river or its wetlands and drainages. The golf course is constructed in a low-lying
coastal plain area. Several natural wetlands are found within or beside the golf course. The water table is
near the surface in all locations.
Greens are constructed on 70 percent sandy soil to promote rapid drainage. The fairways are
planted on native soils. Runoff from the golf course drains into a small stream that feeds into the Warwick
River. The greens and fairways drain into four water hazards or ponds. Three of the ponds are small, each
is approximately 350 square feet in area. The fourth pond is approximately 2 acres in size. The larger pond
is stocked with catfish.
The major golf course operations are nutrient management, pesticide use, and grounds keeping.
Each of these operations and the major waste streams are discussed below.
Nutrient Management
Fairways and greens are fertilized. Fertilizer application frequency, timing, and amount is based on
annual soy analysis results, best professional judgement, and the advice of the fertilizer supply company
representatives. Care is taken to avoid fertilizing the course immediately before or when it is raining.
Fertilizers are in a granular form and applied using a calibrated spreader. Annual fertilizer cost for fairways
and greens was approximately $25,000 to 30,000 in 1991.
The fairways at the Fort Eustis golf course are planted with bermuda turf grass. These areas are
fertilized using a slow release (32-3-10) homogeneous granular formulation. This fertilizer is applied two to
three times in the summer to the fairway, tee box, and apron areas. Annual application rates are
approximately 2 to 2.5 pounds of nitrogen, 0.18 to 0.23 pounds of phosphorus, and 0.6 to 0.78 pounds of
potassium per acre. The golf course superintendent would like to increase the annual nitrogen rate to
3 to 3.5 pounds of nitrogen per acre. The fairways are seeded with perennial rye grass in winter so they
stay green. No fertilizer is used on the rye grass.
The 3.5 acres of greens on the golf course are planted in bent grass and are fertilized using a slow
release (19-26-5) homogeneous granular formulation. Fertilizer is applied two to three times in the summer
and once in the spring. The annual application rate is approximately 4 to 5 pounds of nitrogen, 5.5 to 6.8
pounds of phosphorus, and 1 to 1.3 pounds of potassium per acre.
Wastes
The major wastes from fertilizer use are empty fertilizer bags and surface and subsurface losses of
nitrogen and phosphorus. Empty fertilizer bags are disposed of as nonhazardous solid waste.
There are no quantitative data on nutrient loss from the golf course. Dissolved nitrogen and
phosphorus can be lost in surface water runoff, subsurface baseflow, or groundwater. Factors that can
contribute to high fertilizer loss include the timing of application, quantity applied, formulation used, and
amount of water present. Fertilization prior to a rain storm or heavy irrigation can result in surface water
runoff and subsurface leachate containing high nutrient concentrations. Over fertilization (i.e., adding more
fertilizer than the grass can use) makes the excess nutrients available for runoff or subsurface leaching.
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Rapid draining of the greens combined with a shallow water table are conditions which promote leaching
and nutrient loss to groundwater.
A qualitative indication of nutrient loss would be excessive algal growth or eutrophic conditions in
the golf course water hazards which collect drainage water from the course. According to the course
superintendent, the ponds have not shown signs of excess algal growth in the past. Two to three years ago
the grounds crew started adding Aqua-Shade, a dye, to the three smaller ponds for aesthetic purposes and
to control algae. The use of Aqua-shade may mask signs of nutrient over-enrichment.
Pesticide Use
The golf course is in the third year of a five year pesticide control program. The program,
established by the pesticide supply company, stresses limited pesticide usage aimed at preventing pest
problems before they occur. Greens are treated with insecticides, fungicides, and herbicides. Fairways, tee
boxes, and apron areas are treated with an herbicide. Greens and fairways are visually inspected daily for
indications of disease or infestation. Pesticides are only applied when insect infestation is noticed or climatic
conditions favorable for fungi growth occur. Pesticide application rates follow product label
recommendations. Annual pesticide cost for 1991 was approximately $12,000.
Pesticides are purchased under a Blanket Purchase Agreement (BPA). This allows the course
supervisor to place small orders throughout the year on an as needed basis rather than purchasing large
quantities at the beginning of the year based on estimates of the total quantities and types of pesticide
needed for the entire year. The BPA negates inventory problems such as pesticide storage and expiration
of pesticides. Under the BPA pesticides are purchased in response to a specific pest. This may prevent
excessive or improper use of pesticides that otherwise might occur because they were in stock.
Insecticides
Greens are treated with Dursban or Sevin in the spring to kill cut worm and chinch bugs.
Insecticides are applied to an individual green only when insect damage is evident. The insecticides come
in pre-packaged water soluble bags or powder form which is dissolved in water and applied in liquid form.
Insecticide dosage is determined by the infestation rate in a specific area. The amount of active
ingredient per typical application is approximately V& ounce pen 000 ft2. The number of applications and
the rate vary year to year consequently, the annual quantity of active ingredient applied is not available.
Fungicides
Greens are treated against three different fungi: Brown Patch, Dollar Spot, and Pvthium. Greens
are susceptible to these fungi during a 2 to 3 month period in the spring when climatic conditions
(temperature and humidity) are ideal for fungal growth. Greens are visually inspected daily for Brown Patch
and Dollar Spot When signs indicate damage from Brown Patch or Dollar Spot the green is sprayed with
DaconN2787. Tht early infestation stages of Pyjhjym cannot be detected from visual inspection. Therefore,
Pvthium is controlled by spraying greens with a mixture of Foray*, a contact fungicide, and Subdue™, a
systematic fungicide, whenever climatic conditions are conducive to its growth. The golf course personnel
use two different application rates for the fungicides depending on the severity of the problem. Table 1
shows the application rate for fungicides used. Because the number of applications and the rate varies each
year the annual quantity of active ingredient used is not available.
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TABLE 1. FUNGICIDE APPUCATION RATES
Application Rate
(Ounces of active ingredient per 1000 ft2!
Fungicide Preventative Rate Curative Rate
Daconil 2782 2 8
Subdue™ 0.5 2
2 8
Herbicides
Greens and fairways, tee boxes, and apron areas are treated once in the spring with a pre-emergent
herbicide. Greens are treated with Scotts Goose Grass-Crab Grass Control. Benzolite, the active ingredient
of Scotts Goose Grass and Crab Grass Control, is applied to greens at a rate of approximately 3 36 pounds
per acre per year (11.76 pounds total for all of the greens per year). Fairways are treated with Southern
Weed Grass Control. Annual use of Southern Weed Grass Control is 10,170 pounds. The quantity of
Pendimethalin, the active ingredient, is unavailable. Average annual cost of herbicides for both the greens
and the fairways is $6,000. Herbicides are in granular formulation and applied using a calibrated spreader
The course superintendent does not expect to have to use any herbicides on the fairways next year because
nuisance grasses are under control. He does expect to begin reapplying herbicides the following year.
Pesticide Wastes
There are no quantitative data on pesticide wastes. Wastes from pesticide use include empty
containers, contamination of surface and ground water, loss through volatilization, and impacts on non-target
areas or species. Container waste is minimized for formulations packaged in water soluble packages
Empty pesticide containers are handled according to instructions on the container labels.
Grounds Keeping
The major groundskeeping operations are mowing, turf aeration, liming, brush control and irrigation
Mowing and irrigation practices have the potential for causing the greatest environmental impact Mowing
operations are discussed below. Information was not available for irrigation practices.
Mowing
Mowing takes place year round but most frequently during the spring and early summer. Mowing
is accomplished using gasoline powered riding mowers. Fairways and the short rough are mowed short
to reduce weed growth. Greens are treated in the high growth season with a plant hormone (turf grass
growth regulator) to slow the grass's growth so mowing frequency is lessened.
Grass clippings are left on the fairway as a soil nutrient. Grass clippings from the greens are
collected and dispersed in the undeveloped areas adjacent to the golf course. Lawn mowers emit exhaust
from the gasoline powered engines.
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ASSESSMENT
Standard pollution prevention assessment worksheets contained in the ORD Waste Minimization
Opportunity Assessment Manual (EPA/625/7-88/003) were not applicable to the evaluation of nutrient and
pesticide management at the Fort Eustis golf course. Instead, Fort Eustis personnel were requested to
provide process and facility information by completing a pre-assessment questionnaire (see Appendix A).
This was followed-up by a site inspection of the golf course with Fort Eustis personnel in September, 1991.
Further information was gathered through telephone interviews with Fort Eustis personnel.
Data Gaps
As the assessment team made its visual inspection of the golf course and follow up telephone
interviews, it was never able to obtain written documentation of golf course management procedures, nor
annual records of fertilizer or pesticide information (e.g., times or amount of application, weather conditions
at time of application, etc.). Although much information on operating procedures was obtained through oral
communication, much of the quantitative information needed to perform a rigorous and thorough
assessment was unavailable. Therefore, the following data gaps were noted:
• precise records or information on application rates, date and time of application, weather
conditions at time of application, detailed information on fertilizer brand and pesticide
formulations, total annual quantities of nutrients and pesticides applied;
• adsorption, mobility, and persistence characteristics of pesticides;
• irrigation records (e.g., time and quantity of water applied);
• soil analysis results
• written documentation of fertilization and pesticide programs.
One pollution prevention option that will be proposed in this paper is the use of sludge and
wastewater from the Fort Eustis sewage treatment plant as supplemental organic fertilizers for the golf
course. A significant amount of background information is needed prior to assessing the feasibility of these
techniques at Fort Eustis (e.g., sludge and wastewater characterization studies). Specific information needs
are described in more detail in the Pollution Prevention Options section of this paper. This type of
information was not available for the preparation of this report.
Pollution Prevention Activities
Fort Eustis staff already implement a number of environmentally-sound golf course management
techniques that help to minimize wastes. Some of these techniques, as described in interviews with golf
course personnel, are listed below:
• Conduct annual soil analyses to help determine fertilization rates;
• Use slow-release fertilizer;
• Leave grass dippings in place as a soil nutrient supplement, where possible;
• Do not apply fertilizers/pesticides if it is raining or threatening rain;
• Base most pesticide applications on visual inspection;
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• Use purchasing policies that enable pesticides to be acquired on an "as needed" basis
rather than purchased on an annual basis based on estimated need;
• Aerate the turf on a routine basis.
Pollution Prevention Options
As described above, the Fort Eustis staff already implement a number of nutrient and pesticide
management approaches aimed at minimizing waste and reducing the environmental impacts of golf course
management. This section presents information aimed at supplementing and enhancing Ft. Eustis's current
golf course management program to become even more environmentally sensitive. Because the Ft. Eustis
staff are already implementing some of these ideas, there may be some overlap. This section presents a
comprehensive approach and does not separate out those activities currently practiced at Ft. Eustis. It
presents the results of research by a variety of organizations on environmentally sound turfgrass
maintenance and it proposes an alternative source of nutrients. The pollution prevention options are
presented as two main options and discussed in the following sections.
Option 1 - Nutrient and Pesticide Management
The growth of healthy turfgrass suitable for golf courses requires an adequate supply of all essential
plant nutrients. Nitrogen, phosphorus, and potassium are generally the most important nutrients with
respect to turfgrass fertilization. Research suggests that turfgrass is most responsive to nitrogen fertilization
followed by potassium and phosphorus. Fertilization needs vary by site depending on plant sol, and
climatic conditions. Evaluation of soil nutrient levels ensures the best possible efficiency and economy of
fertilization. Addition of soM nutrients far in excess of plant growth and uptake requirements can result in
nonpoint source pollution, affecting both ground and surface water (Spectrum Research, Inc., 1991).
The USGA commissioned a study to examine "environmental issues related to golf course
construction and management'. The study presented a comprehensive literature review, from which a series
of recommendations was made on how to reduce nitrogen and phosphorus contamination of surface and
ground water. The study also evaluated pesticide management and developed guidelines on
environmentally sound pesticide practices. Results from the USGA study were combined with
recommendations from the VCES publication "Ecological Turf Tips... To Protect the Chesapeake Bay" to
prepare a comprehensive set of recommendations on environmentally sound nutrient and pesticide
management at golf courses (see Tables 2 and 3). The detailed recommendations from each of these
publications are presented in Appendix B.
Another approach to reducing the impacts of nutrients on water quality resulted from a joint effort
of the Northern Virginia Sol and Water Conservation District, Lake Barcroft Watershed Improvement District
Northern Virginia Planning District Commission, and the Virginia Cooperative Extension Service These
organizations teamed to develop a series of Watershed Nutrient Control Standards. These standards were
initially developed for commercial lawn care companies, but are equally applicable to other turf grass
management situations. The Watershed Nutrient Control Standards very closely follow the nutrient and
pesticide recommendations developed by the USGA and VCES and can be used in conjunction with these
standards to ensure an environmentally sound management approach. According to literature describing
the Watershed Nutrient Control Standards, there should be no additional costs to turfgrass maintenance
programs as a result of adopting these nutrient control principles. Table 4 outlines the Watershed Nutrient
Control Standards and briefly describes available cost information; the environmental benefits from these
practices are obvious, as most propose a form of pollution prevention (e.g., using less fertilizer).
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TABLE 2
RECOMMENDATIONS FOR ENVIRONMENTALLY-SOUND
NUTRIENT MANAGEMENT
Nutrient Source: Use slow release fertilizers. Water-soluble sources of nitrogen have
a higher leaching potential than slow-release sources, especially when application is
followed by a large amount of water (either from rainfall or irrigation). If water soluble
sources must be used, apply in several split applications rather than all at once, to
reduce pollution potential.
Application Rate: Develop and implement a comprehensive nutrient management
plan. Avoid applying excess fertilizer by using rates recommended as a result of soil
testing and an understanding of the needs and growth requirements of the crop. Use
the minimum amount of fertilizer necessary to meet the plant needs. The most
effective method to reduce the loss of fertilizer-derived nitrate to groundwater is to
reduce the quantity of nitrogen fertilizer applied. Even on greens, plan fertilization
commensurate with uptake capacity of the specific turfgrass species. Increasing the
rate of nitrogen application to highly sandy greens will lead to a deterioration in
drainage water quality. Slow-release fertilizers should be used on sand amended
areas of the golf course (e.g., greens and tees). If soluble sources are applied to
these modified soHs, nitrogen applied should not exceed 0.75 Ibs N/1000 square feet
On traditional Virginia soils, nitrogen applications should not exceed 1.0 Ibs N/1000
square feet.
Timing of Application: Apply nitrogen fertilizer as dose as possible to the time
required for maximum plant uptake. Time nitrogen application to minimize leaching
losses from rainfall or irrigation (i.e., apply after these events). The best time to fertilize
cod-season grasses is in the fall. In late fall to winter, cool-season grasses are
beginning to develop their root system and store carbohydrates. Warm season
grasses have the greatest rate of uptake in the spring after green-up and throughout
the summer.
Leave Vegetated Buffers Around Water Bodies: Maintain and repair vegetative
buffer strips around water bodies. Do not apply fertilizers directly into or immediately
adjacent to water bodies; leave an unfertilized buffer strip.
Practice Water Conservation: Avoid excess irrigation. Use sensors to determine the
need and timing of irrigation. Intensive fertilization and irrigation practices can cause
transport of nitrate to groundwater. The potential for subsurface loss of nitrogen is
increased when the turfgrass is irrigated at a rate in excess of plant use,
evapotranspiration, and soil storage.
Mow Wisely: Use the highest mowing height acceptable for the use being made of
the turf. Avoid mowing turfgrass areas that are too wet or under extreme heat or
moisture stress (e.g., when temperatures are high or in time of drought).
(Table 2 continued on next page.)
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TABLE 2 (CONTINUED)
• Leave Grass Clippings In Place: After mowing, leave grass clippings in place, where
possible. In areas such as greens, where it is not possible to leave clippings, disperse
clippings in roughs or wooded areas or compost clippings. The finished compost can
be used as a soil amendment
• Aerate the Turfgrttr Heavily trafficked cool-season grasses should be aerated
spring and fall during periods of active foliage growth, although mid-summer aeration
can be beneficial if irrigation is available and temperatures are favorable. Warm-
season grasses can be beneficially aerated from the time they green up until thev ao
dormant in the fall.
• Investigate Alternatives to Nitrogen: Research has shown that iron applications to
turfgrass can increase chlorophyll content, carbohydrates, and rooting while
decreasing respiration rates. Mid-summer green-up can be accomplished with iron
instead of nitrogen. Late fall applications of iron with nitrogen on cool season grasses
have produced earlier spring green-up and enhanced rooting.
• Ensure Application Equipment (s.g., sprayer, spreader) Works Properly: Calibrate
equipment frequently. Calibrate on similar terrain and at speeds similar to actual
spraying conditions. Check distribution pattern of sprayer/spreader. Ensure uniform
distribution.
• Keep Detailed Records: Record information on golf course management procedures.
Include such information as brand used, formulation, date and time of application,
amount of application, climatic conditions during application, irrigation schedule and
annual quantities of fertilizers/pesticides used.
• Work With tht Virginia Cooperative Extension Service to develop nutrient
management plans and other environmentally-sound techniques for gorf course
management.
Source: VCES (1991); Spectrum Research, Inc. (1990)
Option 2 - Use of Waatewater and Sludoe as a Fertilber Supplement
Sewage treatment plant wastewater and by-product sludge can serve as useful supplements to
chemical fertilizers. They contain significant amounts of important nutrients such as nitrogen and
phosphorus, although the exact chemical compositions of wastewater and sewage sludge varies greatly from
site to site. Typical chemical compositions for domestic wastewater and sewage sludge are given in
Tables 5 and 6.
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TABLES
RECOMMENDATIONS FOR ENVIRONMENTALLY-SOUND
PESTICIDE MANAGEMENT
• Pesticide Source: Aim to use pesticides with low mobility, high adsorption, and low
persistence.
• Application Rate and Timing: Use the minimum amount of pesticide necessary to
meet the plant needs. The most effective method to reduce the loss of pesticides to
groundwater and surface water is to reduce the quantity of pesticides applied. Discard
excess pesticide property; do not dump or spray off excess. Unless the problem is
extremely common and recurring, withhold pesticide application until scouting or
monitoring indicates that unacceptable damage will occur.
• Spot Treat: Scout for and treat specific pest problems instead of treating large areas
on a routine basis.
• Understand Damage Thresholds: Only apply pesticides when the pest populations
develop sufficiently to cause damage; the presence of just a few insects or spots does
not require full blown use of a pesticide.
• Utilize Integrated Pest Management Techniques.
• Leave Vegetated Buffers Around Water Bodies: Maintain and repair vegetative
buffer strips around water bodies. Do not apply fertilizers directly into or immediately
adjacent to water bodies; leave an unfertilized buffer strip.
• Practice Water Conservation: Avoid excess irrigation. Use sensors to determine the
need and timing of irrigation. Intensive fertilization and irrigation practices, can cause
transport of nitrate to groundwater. The potential for subsurface loss of nitrogen is
increased when the turfgrass is irrigated at a rate in excess of plant use,
evapotranspiration, and soil storage.
• Ensure Application Equipment (e.g., sprayer, spreader) Works Properly: Calibrate
equipment frequently. Calibrate on similar terrain and at speeds similar to actual
spraying conditions. Check distribution pattern of sprayer/spreader. Ensure uniform
distribution.
• Keep Detailed Records: Record information on golf course management procedures.
Include such information as brand used, formulation, date and time of application,
amount of application, climatic conditions during application, irrigation schedule, and
annual quantities of fertilizers/pesticides used.
• Work With the Virginia Cooperative Extension Service to develop nutrient
management plans and other environmentally-sound techniques for golf course
management
Source: VCES (1991); Spectrum Research, Inc. (1990)
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TABLE 4. BRIEF ASSESSMENT OF WATERSHED NUTRIENT CONTROL STANDARDS
Nutrient Control Standard
Use less fertilizer
Use no phosphorus or very little
Use slow-release fertilizer
Determine existing conditions with
available soil test data
Apply fertilizer periodically rather than
all at once
"Spot control' for broad-leaf weeds
instead of blanket applications
Estimated Savings
Research previously described in this paper indicates that
the average "Do-it-yourselfer" applies 2 to 4 times the
desirable amount of fertilizer. By reducing fertilization
amounts, costs could equally be reduced.
The newsletter by NVSWCD et al. (1991) says that no
additional costs should be incurred by adoption of these
nutrient control standards. The NVSWCD is offering a 50-
Ib bag of "No-Phos Watershed Protection Formula" at
$35/bag. A representative of Natural Lawn Co. stated that
it cost them $1.00 to 1.50 more per household to use
phosphate free fertilizer. In working with the Lake Barcroft
Water Management District, Natural Lawn anticipates a fall
reduction in the phosphorus loading of 7000 Ibs and an 80
to 85 percent reduction in the spring (Bonifant, 1991,
personal communication).
Organic fertilizers tend to be slow acting and less soluble
than chemical fertilizers (Schultz, 1989}. The Washington
Post cited an interview with Jeff Edwards, President of
Home Harvest garden store, where he said that to convert
to organic fertilizer would result in an initial investment of
nothing, as many municipalities have free composting
services, to about $1.00 per 100 sq ft for top of the line,
100 percent commercial organic fertilizer (Cook, 1991).
Soil tests (and the accompanying report which provides
fertilizer recommendations) range in cost from nothing to
an average cost of $5.00 if done by the Cooperative
Extension Service. The cost of soH testing in Virginia is
$6.00. Private soil test labs may charge $30 to $45 for
their services (Carr et al., 1991).
Excess fertilizer is likely to leach into groundwater, rather
than be used by the plant. Since a plant has a limited
capacity to use fertilizer in any one application, any excess
wll be lost (Le., ft cannot be save for later use). Since the
plant is unable to use all of large dosage, ft may need to
be re-fertilized at a later date to ensure that its annual
fertilization needs are met This excess fertilization results
in wasted fertilizer and unnecessary costs.
Natural Lawn Company reports that by switching from
blanket applications to the spot application of herbicides
they were able to reduce 85 to 90 percent of their
herbicide needs (Bonifant, personal communication, 1991)
Obviously, such a dramatic reduction in herbicide usage
would result in comparable cost savings.
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TABLE 4. (continued)
Nutrient Control Standard
Estimated Savings
Avoid using broad-spectrum
insecticides
Mow lawns at the recommended height
Leave clippings when possible
No data, but intuitively suggests a cost savings by not
purchasing such chemicals.
No data, but proper mowing technique results in a
healthier lawn and can reduce pesticide and fertilizer needs
(Schultz, 1989; Carr, 1991).
Starr and DeRoo (1981) conducted research showing that
the return of grass clippings to the lawn is beneficial to
grass growth. They conducted research on grass growing
in a low-N, sandy loam soil. In one test plot, clippings
were not returned, in the other, dippings were returned. In
the plot where clippings were .not returned, "about half of
the plant-N was derived from the fertilizer and half from the
soil. Where clippings were returned, yield of grass
increased by about one-third, with the additional plant-N
derived from the cumulative return of the clippings over the
3-year period." The increase in grass yield by one-third by
leaving grass clippings in place implies that fertilization
could be reduced by a comparable amount (thus reducing
costs). Natural Lawn Company confirmed this view and is
promoting this practice. The Professional Lawn Care
Association of America also recommends this practice.
TABLE 5. IMPORTANT CONSTITUENTS IN TYPICAL DOMESTIC WASTEWATER (mg/L)
Constituent
Biochemical Oxygen Demand
Suspended solids
Nitrogen (total as N)
Organic
Ammonia
Nitrate
Phosphorus (total as P)
Organic
Inorganic
Total organic carbon
Strong
400
350
85
35
50
0
15
5
10
290
Type of wastewater
Medium
220
220
40
15
25
0
8
3
5
160
Weak
110
100
20
8
12
0
4
1
3
80
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TABLE 6. CHEMICAL COMPOSITION OF SEWAGE SLUDGES1
v^omponem
Total N
NH3 - N
NO3 - N
P
K
ixumoer of SampJ
191
103
43
189
192
es Range
<0.1 - 17.6
5x10^-6.76
2 x 10"4 - 0.49
<0.1 - 14.3
0.02 - 2.64
Median
(Percent2)
3.30
0.09
0.01
2.30
0.30
Mean
3.90
0.65
0.05
2.50
0.40
(ma/kQ2l
Cu 205 84-10,400 850 1,210
Zn 208 101-27,800 1,740 2,790
Nl 165 2-3,520 82 320
Pb 189 13-19,700 500 1,460
0(1 189 3-3,410 16 no
PCB>S 14 <0.01-23.1 3.9Q 515
Data are from numerous types of sludges (anaerobic, activated sludge lagoon etc) in 15
states: Michigan, New Hampshire, New Jersey, Illinois, Minnesota, and Ohio (2); California
Colorado, Georgia, Florida, New York, Pennsylvania, Texas, and Washington (3)- and
Wisconsin.
2 Oven-dry solids basis.
Use of wastewater and sewage treatment plant sludge has been tried at some golf courses with
proven success. As a second pollution prevention option, Fort Eustis could explore ways to use the
wastewater and sludge generated from the Fort Eustis sewage treatment plant as a supplemental fertilizer
for the golf course. This would not only serve to reduce the reliance on chemical fertilizers at the golf
course, but it would also help reduce levels of solid waste and point source nutrient discharges from the
sewage treatment plant. The primary disadvantages of these nutrient sources (odor, health concerns due
to pathogens, public perception) can be overcome through treatment technologies and public outreach
Removal of pathogenic organisms in wastewater can be achieved by disinfection or by natural processes
in biological treatment or storage ponds. Any objections from sludge use (e.g., odor, elimination of weed
seeds) are significantly minimized if headed or composted sludge is used. 8liminatlon « we*>
Since Fort Eustis has its own sewage treatment plant which accepts only domestic waste the
conversion of wastewater and sludge into usable fertilizer supplements for the golf course is a viable option
and we^l worth furtherinvestigation. Depending on the technologies selected and the additional equipment
needs (» any), it is likely that long-term cost savings could be achieved. Detailed cost analyse^e not
undertaken for this report because ail of the necessary background information was not available.
Several planning studies must be undertaken before Fort Eustis can fully investigate the feasibility
of using their wastewater and sludge as a fertilizer supplement on the golf course. The planning processes
for wastewater and sludge applications are outlined in Rgures 1 and 2, respectively. Of prime importance
126 •
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Waste
Characterization
Land Treatment
System Sufcabtty
Estimation of Land
Requirements
Phase 1
Site Identification
Land Treatment Not
Feasible Because of
Limiting Factors or
Project Requirements
Site Screening
Selection of Potential Sites
Land Application
Not Feasible if
There Are No
Potential Sites
Field Investigations
Phase 2
Development of
Preliminary Design
Criteria and Costs
Evaluation of
Alternatives
Plan Selection
Land Application
Not Feasible to-
Other Reasons or Other
Alternatives More
Cost Effective
Initiation of Land
Treatment Design
Figure 1. Planning Process for Wastewater Application (USEPA, 1981).
127
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Determine Sludge Characteristics;
Chemical Biological and Physical
I
Review Applicable Regulations and
Guidelines for Land Application of
Sludge, Federal, State and Local
I
Compare Sludge Characteristics to
Regulatory Requirements and Evaluate
Suitability of Sludge for a Land
Application Option
I
Estimate Land Area Required for
Sludge Application, and Availability
of Land Area Necessary
Assess Sludge Transport Modes
and Their Feasibility
Rgure 2. Planning Process for Sewage Sludge Application (USEPA, 1983).
128
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in these planning studies are a chemical/physical characterization of the wastewater and sludge and an
evaluation of the land for suitability. Also important is the evaluation of the various techniques that can be
used to apply and use the wastewater and/or sludge. These evaluations should be based on capital costs,
operation and maintenance costs (including energy consumption), and other nonmonetary factors such as
public acceptabiity, ease of implementation, environmental impacts, treatment consistency, and reliability.
Two Environmental Protection Agency documents (Process Design Manual: Land Treatment of Municipal
Wastewater and Process Design Manual: Land Application of Municipal Sludge) provide detailed information
on the various technologies and design/cost considerations for using wastewater and sludge.
FEASIBILITY
A feasibility analysis was conducted for each component of the pollution prevention options using
a modified Worksheet Number 13. Each option was rated qualitatively for a number of different criteria
because quantitative data were not available (Table 7). A brief discussion of each option is presented below.
Table 4, presented earlier in this report, provides further descriptions and limited cost information for some
of the components of the Watershed Nutrient Control Standards.
Nutrient Source
Slow-release fertilizers have a lower leaching potential than water soluble fertilizers and, therefore,
pose less risk to ground water. Slow-release formulations will also reduce surface losses if time of release
is synchronized with plant uptake and does not coincide with runoff producing events. Slow-release
fertilizers offer additional benefits, including: labor saving benefits since fewer applications are needed,
reduction in the risk of foliar bum, and a more even supply of nitrogen. Certain types of slow-release
formulations may have only a moderate to poor response in cool weather, while other slow-release
formulations are not affected by cooler temperatures; care must be taken to select the best formulation for
local climate conditions. Slow-release formulations may be slightly more expensive than water-soluble
sources, but the added cost may be offset by needing fewer applications. Use of split applications for water-
soluble formulations reduces waste by better matching fertilizer amount to actual plant needs, thus reducing
the leaching potential. Since phosphorus has the greatest potential for contributing to the eutrophication
of surface water, efforts should be made to reduce its application to the lowest amount indicated through
nutrient management planning.
Pesticide Source
The above principles also apply to pesticides. Pesticides with low mobility, high adsorption, and
low persistence have a reduced potential for leaching and runoff. Therefore, effort should be made to use
brands of pesticides with these characteristics.
Application Rate
Efficient fertilizer use can be determined through comprehensive nutrient management planning.
Using the minimum amount of fertilizer/pesticide needed reduces opportunities for water contamination by
surpluses. Reducing fertilizer and pesticide quantities also reduces costs and provides labor saving benefits.
If needs are estimated based on comprehensive nutrient management planning (e.g., soil testing, awareness
of plant requirements) and an assessment of pesticide damage potential and extent, there should be no
change in turfgrass quality.
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Timing of Application
Proper timing of fertilization and pesticide application can improve efficiencies at no added cost
or labor requirement By withholding pesticide applications until inspections suggest a problem has
occurred, savings in the amount (and cost) of pesticides used could be realized.
Spot Treat
Spot treating pest problems rather than treating large areas will reduce the amount of pesticides
used, as well as labor and costs. There should be no adverse benefit to the turfgrass.
Leave Vegetated Buffers Around Water Bodies
Vegetative buffer areas serve to slow the flow of surface runoff and act as a filter for pollutants
contained in that runoff. Having buffers can actually reduce the amount of nutrients and pesticides
entering water bodies by secondary infiltration, sediment deposition, reducing flow, and uptake by buffer
strip vegetation. Preserving existing buffer areas does not require additional costs. Rehabilitation of
damaged or absent buffer areas will involve additional costs; amounts vary depending on site-specific
conditions.
Practice Water Conservation
By reducing the amount of water used for irrigation, cost and labor benefits can be realized.
Reduced water also lessens the potential for surface runoff or subsurface infiltration. If irrigation is
determined using sensors to determine crop needs, there should be no negative impact on vegetation.
Additional costs (unknown) may be incurred if sensors are not already in place, but these should be
offset by savings in water usage.
Proper Mowing Techniques
Mowing is a stress-creating management activity for turfgrass. If grass is mowed too short, its
productivity is decreased, there is less growth of roots and rhizomes, and the turf becomes less tolerant
of environmental stresses, more disease prone, and more reliant on outside means (e.g., pesticides,
fertilizers, water) to remain healthy. By setting the mowing height as high as is acceptable and mowing
at times and intervals designed to minimize stress on the turfgrass, a healthier grass will result. This can
result in cost savings as mowing frequency and associated labor requirements may decrease. The need
for pesticides, fertilizers, and irrigation water may also decrease.
Leave Grass Dippings in Place
Research has shown that grass clippings can contribute nutrients to soil, thereby reducing
fertilization need. The reduction in fertilizer would result in comparable cost savings.
Aerate the Turfgrass
Aeration is an effective means of improving turfgrass quality. It increases air exchange, water
infiltration rates, water retention, root development, and thatch decomposition. By improving water
infiltration, water use efficiency is increased. This can result in a reduction in irrigation requirements.
Aeration does involve additional labor and equipment, but the benefits can result in healthier turfgrass
and reduced need for chemical inputs and irrigation.
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Investigate Alternatives to Nitrogen
Any techniques which result in a reduced need for nitrogen fertilization can result in water
quality benefits, as the best way to reduce the threat of surface or ground water contamination by
fertilizer-derived nitrate is to reduce the quantity of nitrogen fertilizer applied. Cost savings may be
realized by reducing overall fertilizer requirements, depending on the relative costs of the alternatives.
Ensure Application Equipment Works Properly
Properly calibrated and functioning equipment will ensure accurate delivery and placement of
materials and will minimize the chances of over- or under-fertilizing. Steps to check calibration and
equipment function do not require much extra labor or cost Cost savings may be realized as properly
functioning application devices will reduce waste.
Keep Detailed Records
Written records of fertilizer/pesticide application rates, times, etc. are essential in monitoring use
and to help ensure that overuse does not occur. The paper work will require a minimal amount of extra
time and start up costs to establish a record-keeping system, but will greatly reduce the risk (and
therefore, cost) of over-applying.
Work With the Virginia Cooperative Extension Service
The VCES has extensive expertise and educational materials aimed at environmentally-sound
turfgrass maintenance. Using VCES to develop golf course management programs involves low cost
(the VCES typically does not charge for these services) and substantial cost savings may be realized
through reduced fertilizer and pesticide needs.
Integrated Pest Management
Integrated pest management (1PM) uses a variety of management techniques with the goal of
improving plant health and productivity whHe minimizing environmental impacts. Many of the pesticide
management techniques identified in Exhibit 2 are components of IPM. Additional time should be
invested by the appropriate Fort Eustis personnel to learn more about IPM (e.g., attendance at training
sessions, working with VCES). Many of the goals of IPM involve reducing pesticide inputs. Therefore,
integrating IPM techniques into the golf course management program should result in long-term cost
savings by reducing inputs.
Use of Wastewater and Sludge as Fertilizer Supplement
Sewtgt treatment plant sludge and wastewater is nutrient-rich and can serve as an excellent
supplemental organic fertlber source. As an organic fertilizer, it has the advantage of being slow-
release. Also, ft is readly available at Fort Eustis and could be used to reduce reliance on chemical
fertilizers. As discussed In the Assessment section of this report, the potential negative impacts of
wastewater and sludge can be ameliorated through treatment technologies. Prior to making any
decisions regarding using the wastewater and sludge, Fort Eustis must undertake planning studies The
types of studies needed were briefly outlined in the Assessment Section of this report (principally in
Rgures 1 and 2). Upon completion of these planning studies (especially the sludge/wastewater
characterization and site assessment) and review of the existing wastewater evaluation report, Fort
Eustis wHI be in a better position to evaluate the feasibility of using wastewater and sludge as a fertilizer
supplement. Until then, it is difficult to make judgements about costs and/or savings from this pollution
prevention option.
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CROSSFEED TO OTHER TIPPP INSTALLATIONS
The golf course nutrient and pesticide management activities described in this report could
easily be implemented at other golf courses. Implementation of the second pollution prevention option -
use of sewage treatment plant wastewater and sludge could also be implemented at other facilities if a
sewage treatment plant handling domestic sewage (i.e., not industrial wastes) is located onsite. As in
the case of Fort Eustis, a number of planning studies would have to be completed before the full
feasibility of Option 2 could be evaluated.
MEASUREMENTS OF POLLUTION PREVENTION
Measuring the impacts of pollution prevention activities requires baseline data on wastes and
operating costs, as well as water quality information. Much of this background data were not available
from the Fort Eustis golf course. By immediately implementing a record-keeping system, Fort Eustis
could begin acquiring the needed cost and waste data. Water quality data could be obtained from a
carefully designed monitoring program to include surface and ground water. If monitoring stations were
established prior to implementing the pollution prevention options described in this paper, baseline data
could be obtained from which future changes in water quality could be measured.
A further measure of the impacts of pollution prevention activities on the golf course could be
obtained from a qualitative evaluation of the condition of the golf course grounds before and after
implementing the pollution prevention options. Some factors to include in the evaluation are: overall
growth and health of the turfgrass, weed and pest populations, and disease incidents. Changes in the
amount of noxious aquatic vegetation in surface water ponds on the golf course could serve as another
measure of nutrient pollution prevention results.
IMPLEMENTATION
Most of the measures described under Option 1 - Nutrient and Pesticide Management can be
implemented with few barriers. As described in the Assessment Section of this report, Fort Eustis staff
already employ a number of the recommended nutrient/pesticide management approaches. Some of
the measures that are not currently employed involve simple modifications in current approaches and
are readily implementable. These include: avoid applying excess fertilizer, wise mowing, equipment
calibration, and working with the VCES. Other measures are easily implemented after an evaluation of
current practices and/or research on alternative approaches is completed (see Table 2 for a more
detailed description of needed additional activities). These measures include: preparing a
comprehensive nutrient management plan; applying fertilizer near time of maximum plant uptake; timing
to avoid leaching losses from rainfall or irrigation; use of low- or no-phosphorous fertilizers; alternatives
to nitrogen; use of low mobility, high adsorption, and low persistence pesticides; IPM; recordkeeping;
and water conservation. The preservation and maintenance of vegetative buffer strips may present few,
or many, Implementation barriers depending on the existing condition of these buffers. An initial
evaluation of existing buffer areas should be undertaken to determine the extent of healthy buffer areas
and those needing rehabilitation. If significant amounts of rehabilitation are needed, barriers to
implementation would occur from cost, time, and labor to rebuild the buffer areas.
The above approaches could be implemented all at once, or phased in on various sections of
the golf course. For example, one green could be fertilized with a reduced phosphorus fertilizer, another
green could receive reduced levels of nitrogen fertilizer, and the remaining greens could continue to
receive the current treatment By phasing in some of the above recommendations on a limited basis,
the effects of the changes in management approach could be monitored in a controlled fashion. This
would allow time for any modifications or fine-tuning prior to using the measure course-wide.
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Option 2 - Use of Wastewater and Sludge as a Supplemental Fertilizer offers the most potential
barriers to the proposed pollution prevention options. It is difficult to fully estimate the extent of these
barriers without having the results of the initial planning studies described in the Assessment Section of this
report. The extent of barriers depends on the quality of the wastewater and sludge, as well as transportation
and application techniques. If sludge quality is good and requires little treatment, or if existing equipment
can be used for application, then the barriers to Option 2 are few. As treatment demands or equipment
needs increase, so do the barriers; this cannot be determined without the initial planning studies. One
barrier to using wastewater and sludge relates to the public perception of these materials. This barrier can
be overcome through effective public education and outreach programs.
RESEARCH, DEVELOPMENT AND DEMONSTRATION NEEDS
In order to make its golf course management program truly effective, and to provide the necessary
information to make decisions on pollution prevention approaches and performance, Fort Eustis should
undertake a few R&D studies. These are briefly outlined below:
• Nutrient and Pesticide Management - Fort Eustis should work with VCES to develop a
comprehensive nutrient management plan for the golf course. Some of the major goals of
this plan should be to reduce fertilizer inputs to the lowest possible level based on a full
understanding of all nutrient sources (e.g., grass clippings, soil nutrients) within the golf
course system compared to actual turfgrass nutrient needs. After determining actual
nutrient needs, Fort Eustis should examine its current fertilizer sources to see if more
environmentally-sound supplies could be used. This same type of product evaluation should
occur for the current pesticide program with the goal of selecting the product that best
meets the recommendations given in this report
Use Of Wastewater and Sewage Sludge as a Supplemental Fertilizer - A nnmhor nf planning
studies must be undertaken before this option can be fully explored. These studies are
described more fully in the Assessment Section of this report
• Test Plots - If Fort Eustis golf course personnel are wary about trying a new approach (e.g.,
using low-phosphorous fertUizer or using sewage sludge), they could establish various test
plots on the golf course to implement these approaches and monitor the results on a small
scale.
• Reduce Reliance on Aqua-shade - Currently, Fort Eustis golf course personnel use an
herbicide, aqua-shade, to reduce algal growth in the golf course ponds. This practice
masks signs of nutrient-enrichment (e.g., eutrophteation). In order to determine if eutrophic
conditions exist on the golf course, the use of aqua-shade should be suspended in at least
a few of the ponds. This will provide a qualitative means of assessing the extent of nutrient
loadings to surface water from the goif course.
RECOMMENDATIONS/CONCLUSIONS
A pollution prevention opportunity assessment was performed on the golf course at Fort Eustis in
September, 1991. More specific data on the types of management practices currently used, especially
fertilizer and pesticide formulations and application rates/loadings, is needed to refine the pollution
prevention activities proposed in this report Two broad based pollution prevention options were identified:
Option 1 - Nutrient and Pesticide Management; and Option 2 - Adoption of Option 1 and Substitute
an Organic Fertilizer. Option 1 consists of afdopting guidelines prepared by the USGA and VCES and
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enhancing them with the "Watershed Nutrient Control Standards." Option 2 consists of substituting fertilizer
derived from the Fort Eustis Sewage Treatment Plant (i.e., sludge and wastewater).
Fort Eustis already employs a number of recommended nutrient and pesticide management
practices and is encouraged to continue these practices. A number of additional nutrient and management
practices were also identified which could be easily implemented or considered by Fort Eustis as a
supplement to the on-going program. The only recommended pollution prevention option that requires
significant additional study prior to implementation is Option 2 - Substitute Organic Fertilizer (i.e., sludge and
wastewater) Derived From the Fort Eustis Sewage Treatment Plant. The feasibility of this option should
definitely be explored, as wastewater and sewage sludge offer viable alternatives to chemical fertilizers and
can be obtained relatively easily onslte. Using wastewater and sludge from the sewage treatment plant
would also greatly reduce thekamount of waste needing to be disposed or discharged from that facility.
Depending on the results of the feasibility study (e.g., equipment needs), it is very likely that a cost savings
(from reduced chemical fertilizer needs and/or reduced treatment/disposal expenses) could occur. The
other added benefit of using wastewater and sludge is that its use could extend beyond the golf course to
other areas of the grounds maintenance program (e.g., fertilizer for landscaping projects).
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REFERENCES
1. Bontfant, B. 1991. Personal Communication With Vice President of Natural Uwn Company.
2. Carr, A., M. Smith, L Gilkeson, J. Smillie, and B. Wolf. 1991. Chemical-Free Yard and Garden.
Emmaus, Pennsylvania: Rodale Press.
3. Cook, A. September 26, 1991. Guidebook for the PC Gardener. Washington Post Northern
Virginia Soil and Water Conservation District, Lake Barcroft Watershed Improvement District
Northern Virginia Planning District Commission, and Virginia Cooperative Extension Service
(Fairfax Office). 1991. Newsletter entitled "Please Don't Feed Our Streams - How to Feed Your
Lawn Without Overloading the Bay".
4. Schultz, W. 1989. The Chemical-Free Lawn. Emmaus, Pennsylvania: Rodale Press. Spectrum
Research, Inc. 1990. Environmental Issues Related to Golf Course Construction and
Management: A Literature Search and Review. A Final Report Submitted to the United States
Golf Association: Green Section.
5. Starr and DeRoo. 1981. The Fate of Nitrogen Fertlizer Applied to Turfgrass. Crop Science, v.
21. U.S. Environmental Protection Agency. 1983. Process Design Manual: Land Application of
Municipal Sludge. EPA-625/1-83-016.
6. U.S. Environmental Protection Agency, U.S. Army Corps of Engineers, U.S. Department of
Interior, and U.S. Department of Agriculture. 1981. Process Design Manual for Land Treatment
of Municipal Wastewater. EPA 625/1 -81 -013.
7. Virginia Cooperative Extension. 1991. Ecological Turf Tips to Protect the Chesapeake Bay, ETT
Number 3, "Nutrient Management for Lawn Service Companies."
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August 27, 1992
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
ROADS AND RUNWAYS AT
LANGLEY AIR FORCE BASE
by
J. Houlihan
Science Applications International Corporation
Falls Church, Virginia
Cincinnati, Ohio 45203
EPA Contract No. 68-C8-0062, WA 3-70
SAIC Project No. 01-0832-03-1021-010
Project Officer
Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
139
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INTRODUCTION
A pollution prevention opportunity assessment (PPOA) was conducted on the runway and road
operations at Langley Air Force Base. The assessment was conducted for the EPA's Risk Reduction
Engineering Laboratory under the purview of the WREAFS program to support the Tidewater Interagency
Pollution Prevention Program (TIPPP). A procedure described in the EPA Waste Minimization Opportunity
Assessment Manual (EPA/625/7-88/003) was used to conduct the study. The manual provides detailed
worksheets and a process/option evaluation method for use in industrial settings.
A PPOA consists of four systematic steps: Planning and Organization, Assessment, Feasibility
Analysis, and Implementation. Of the 19 worksheets in the manual, none were used in this PPOA; a
questionnaire was prepared and used to obtain data from Langley (see Appendix A). The implementation
of the recommended options presented in this report is at the discretion of the host facility.
PROCESS REVIEW
This section describes road and runway operations conducted at Langley Air Force Base and the
associated waste streams from these operations.
Runway Operations
The runway area includes the active runway as well as the runway apron and associated areas
where aircraft fueling, taxiing, parking, servicing, and washing occurs. All areas are paved. The active
runaway dimensions are approximately 3,048 meters by 46 meters. The major operations are aircraft fueling,
aircraft washing, runway maintenance, and runway de-icing. Aircraft and support vehicle maintenance and
repair do not take place on the runway area and were not evaluated as part of this assessment. The large
expanse of paved area generates large volumes of stormwater runoff. Stormwater from the runway drains
directly to storm sewers. A brief description of runway operations and associated wastes follows.
Aircraft Fueling
Aircraft are fueled with JP-4 by tank trucks or fixed fueling stations. JP-4 is one type of petroleum,
oil and lubricant (POL) product used at Air Force bases. All POL materials have the potential to contaminate
the environment if improperly used or managed. Potential waste streams from fueling operations are fugitive
emissions during fueling and fuel spills. Stormwater can become contaminated by fuel spilled on exposed
paved surfaces and from fuel dripped from aircraft due to overfills.
Aircraft Washing
Aircraft are washed in a designated area designed with wash racks that allow easy access to the
aircraft and permit drainage of washwater. Aircraft are washed with pressurized water and Citri-Kleen*. an
alkali cleaning agent, and then rinsed with fresh water. Washwater is collected in a sump, passes through
an oil/water separator, and is discharged to the storm sewer. The washwater has not been characterized
(ECAMP/NPDES) but may contain oil, grease, Citri-Kleen*. detergents, and surfactants. It is unknown
whether organic solvents, such as 1,1,1-trichloroethane, are used to spot clean aircraft.
Runwav Maintenance
Routine maintenance is performed to keep the active runway and runway area operational.
Runways are repaired with concrete and asphalt. Concrete and asphalt are lost from runways due to wear-
and-tear from weather conditions and vehicular traffic. Annual concrete use is 70 yds3 of 3000 psi concrete
and 30 yds3 of 5000 psi concrete. Annual asphalt usage is 200-300 tons per year. Runway joints are sealed
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with a self-leveling rubberized sealant. How much of the concrete and asphalt is actually lost into
stormwater discharges is unknown. Wear of vehicular tires may result in some particulate rubber being
discharged into stormwater runoff.
De-icing
An electronic ice detection system is used to detect icy conditions on the active runway. Runways
are de-iced using urea. The urea de-icing agent can contaminate ice melt or stormwater runoff with
potentially high concentrations of nitrogen, an aquatic plant nutrient and one of the major pollutants of
concern for the Chesapeake Bay system.
Aircraft Taxiing. Takeoff and Landing
Aircraft taxiing, takeoff, and landing generate engine emissions. Particulate emissions deposited
on paved surfaces can contaminate stormwater.
Support Vehicle
Support vehicles such as trucks are operated in the runway area. Support vehicles can leak
automotive fluids onto paved areas where such fluids may contaminate stormwater.
Roadway Operations
Langley Air Force Base is served by a network of roads. The area covered by paved or unpaved
roads is unknown. The major operations investigated are road de-icing and road maintenance.
Roadway De-icing
Sand is spread on roadways as a de-icing agent. Sand can be transported as suspended solids
in ice melt runoff or stormwater runoff to surface waters. High suspended solid concentrations can degrade
water quality and harm aquatic biota by physically covering aquatic habitats and reducing availability of light
to aquatic vegetation.
Roadway Maintenance
Roads are paved and unsealed. Maintenance operations include periodic surface maintenance,
filling potholes, and line painting. The specific type of paint used on roads was not known to the Air force
staff interviewed for this assessment. Stormwater runoff from roads can be contaminated with oil and grease
and toxic metals from routine vehicle traffic. Some roadway paints contain lead which, when eroded due
to weather and traffic, may contaminate stormwater.
ASSESSMENT
An inspection of runway and road processes was conducted by the assessment team in September
1991. Pollution prevention worksheets found in the ORD Waste Minimization Opportunity Assessment
Manual were not appropriate for this assessment. Instead, Air Force personnel were requested to provide
process and facility information by completing a pre-assessment questionnaire. A copy of the pre-
assessment questionnaire is found in Appendix A.
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Data Gaps
Sufficient quantitative data on processes and the facility were not available. Air Force personnel
did not initially provide the information requested in the pre-assessment questionnaire. Available data were
collected through interviews with Air Force personnel during the site visit. The assessment team did not fully
tour the runway nor associated runway areas due to security and safety concerns raised by Air Force
personnel. The lack of a complete set of quantitative data does not allow the most basic questions to be
answered, such as:
• Which wastes are of most concern?
• What are waste management costs?
• Which processes or wastes should be targeted for pollution prevention?
Particular data that need to be collected to answer these questions are:
Identification of all operations generating wastes
Identification of all existing waste management and pollution prevention practices
Chemical composition of input materials that generate wastes
Amount of raw materials used
Costs of raw materials
Quantity of raw materials lost
Mechanisms or pathways by which the material is lost
Quantity of waste generated
Chemical components in each waste stream
Cost of waste management
Which wastes are classified as hazardous or nonhazardous
Quantity of input material(s) entering each waste stream
Current Waste Management Practices
Runways are vacuumed daily using a Tempo™ sweeper. The runway border areas are vegetated
and reseeded to prevent erosion and slow stormwater runoff to allow settling of suspended contaminants
and biological uptake of nutrients. Washwater discharges from aircraft washing passes through an oil/water
separator before being discharged to the storm sewer. The oil/water separator may be ineffective in
removing oil because surfactants in detergents chemically stabilize free and dispersed oil. Fuel spills are
contained using vacuum skimmers and booms. A Spill Prevention and Response Plan is in place. A leak
detection system exists for underground fuel storage tanks. An oil boom is installed at the stormwater sewer
outlet to absorb floating oil and grease from stormwater discharged from the runway area. The oil boom
may be ineffective during periods of high stormwater flow. It is also not known whether the boom is
periodically replaced when the capacity to absorb oil is diminished.
Pollution Prevention Options
A number of potential pollution prevention options were identified for runway and road operating
processes.
Reduce fugitive VOC emissions during aircraft fueling by:
• Installing vapor recovery systems on fuel delivery equipment
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Reduce contamination of stormwater from aircraft washing by:
• Evaluating washing frequency
• Recycling and reusing washwater
Reduce contamination of stormwater from de-icing operations by:
• Using alternative de-icing material
• Installing heating elements under the runway
Reduce contamination of stormwater from dripping or leaking engine fuel and liquids from aircraft
and support vehicles by:
• Routinely checking for leaks
• Placing drip pans under leaking engines until the leak is fixed
• Installing overfill protection pans
Reduce emissions from aircraft engines by:
• Using natural gas or electric powered tugs to move planes out to runways
No options were identified for roadway operations due to the lack of data. Installing a heating
element system under the runway was not considered further given the high capital costs, disruption to
runway activities during installation, and low number of days per year the system would be needed. All of
the other options were further evaluated for feasibility.
FEASIBILITY
A feasibility analysis for each pollution prevention option was conducted using a modified Worksheet
Number 13 (see Table 1). Each option was rated qualitatively for a number of different criteria since
quantitative data were not available. The feasibility analysis results identified these pollution prevention
options as promising areas for reducing or eliminating wastes. A more rigorous feasibility analysis, based
on the data described in the Data Gaps section, should be completed for each option prior to
implementation. A brief description of each pollution prevention option is presented below.
Fueling Vapor Recovery
Installing an emission recovery system on the second stage fuel delivery equipment would reduce
fuel loss from fugitive emissions. The system prevents emissions by sealing the fuel nozzle and the fuel
tank.
Aircraft Washing
The frequency of aircraft washing should be evaluated to ensure that aircraft are only washed when
required. Washing aircraft on an as-needed will reduce the amount of water and cleaning agent required
and limit wastewater generation.
Washwater could be collected, filtered, and reused for aircraft washing. New cleaning agent and
water would be added as needed. Recycling washwater will reduce the amount of water and cleaning agent
used and eliminate the discharge of washwater to the storm sewer.
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TABLE 1. QUALITATIVE ANALYSIS OF POLLUTION PREVENTION OPTIONS
Criteria
Additional space
required
Waste reduction
Safety hazard reduction
Input material cost
reduction
Extent of current use in
industry
Personnel training
Additional labor
requirements
Utility requirements/
availability
Special expertise
requirements
Adverse environmental
impacts
Fuel Vapor
Recovery
System
No
High
Yes
Yes
High
Required
No
None
None
None
Recycle Aircraft
Washwater
Possibly
High
N/A
Yes
High
Required
No
Electricity
None
Potential sludge
disposal issues
Alternative De-icing
Material
Possibly
Eliminate nitrogen
N/A
Undetermined
Moderate
None
No
None
None
NaCI - salinity
Sand - turbidity
Tugs to Move
Aircraft
Yes- Tug
storage
Yes
Unknown
Unknown
Moderate
Required
No
None
None
Unknown
Alternative Oe-icing Material
An alternative de-icing material will eliminate the nitrogen contamination of stormwater. Alternatives
to urea include road salt (NaCI), ice-melt (CaCI), and sand. These alternative materials are widely used as
de-icing agents on roads. However, they have potential environmental drawbacks. Road salt increases the
salinity of ice melt water or stormwater runoff. High salinity is harmful or fatal to certain types of vegetation
and freshwater organisms. CaCI increases the chloride content of stormwater runoff. Both NaCI and CaCI
can have adverse impact on paved surfaces. Sand can be transported as suspended solids in ice melt
runoff or stormwater runoff to surface waters. High suspended solid concentrations can degrade water
quality and harm aquatic habitats. However, a settling tank can be installed before discharging stormwater
to surface water to minimize suspended solids.
Eliminating Engine Drips and Leaks
Eliminating engine drips and leaks involves visually checking aircraft and support vehicles for leaking
fluids. Drip pans should be placed to catch dripping fluids for recycling or proper disposal until the leak can
be fixed. This simple option will eliminate potential sources of stormwater contamination unless the drip pan
is allowed to overflow in a thunderstorm. The option can be implemented without additional staffing, special
training, or increased capital investment or operating costs. This option was not evaluated using Table 1
criteria.
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Aircraft Engine Emission Reduction
Using natural-gas-powered tugs to move planes out to runways instead of taxiing will reduce
localized air emissions and dry deposition of combustion particulates that can contaminate stormwater.
Various energy-efficient innovations are currently being explored that will warm engines while reducing air
emissions.
CROSSFEED TO OTHER TIPPP INSTALLATIONS
A fuel recovery system and recycling of washwater could be applicable to other TIPPP operations
that have fueling or vehicle washing operations. Other recommendations may be applicable to some of the
other TIPPP sites.
MEASUREMENT OF POLLUTION PREVENTION
Measuring the impact of pollution prevention requires baseline data on wastes and operating costs.
These data were not available.
IMPLEMENTATION PLAN
Inspecting aircraft and vehicles for leaks and placing drip pans to prevent engine fluids from
contaminating stormwater should be implemented immediately. The decision to implement the other options
should be made after a more formal feasibility analysis based on quantitative process and waste data. The
major questions that should be answered prior to implementing each option are:
• Compatibility of the option with existing operating procedures
• Capital cost and operation and maintenance costs
• Production switchover interval
Specific implementation issues for three options follow.
Recycling Aircraft Wash Wastewater
• Testing the cleaning effectiveness of washwater after multiple uses
• Testing wastewater sludge to determine its chemical composition and disposal or
recycling options
Alternative De-icing Agents
• The effectiveness of alternative de-icing materials; investigate if switching material requires
changing Standard Operating Procedures
• Determine if new delivery equipment is required
Tug System
• Space requirements for tug storage
• Special training or personnel expertise required for maintenance
• Alternative auxiliary equipment for tugs such as natural gas fueling systems or battery
charging equipment
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RESEARCH DEVELOPMENT AND DEMONSTRATION NEEDS
The options presented in the preceding section will require onsite testing, refinement, some
improvisation, and a desire to integrate the options into the procedures of the base. Little or no major
research development and demonstration (RD&D) barriers have to be overcome, since the options are
commercially available and simply need to be proven and accepted at Langley.
RECOMMENDATIONS/CONCLUSIONS
The aircraft and support vehicle leak detection program should be implemented immediately. A
thorough analysis of the other four pollution prevention options should be performed. A follow up pollution
prevention opportunity assessment supported by quantitative data should be conducted to identify other
pollution prevention options.
A pollution prevention opportunity assessment was performed on runway and road operations at
Langley Air Force Base. The lack of data on wastes, input materials, and operations limited the options
identified by this assessment. Five potential pollution prevention options were identified:
• Aircraft fuel vapor recovery system
• Recycling aircraft washwater
• Alternative de-icing material
• Tug system to move aircraft
• Aircraft and support vehicle leak detection program
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REFERENCES
1. Ellison, Wayne. U.S. EPA Region 10, Personal Communication 2-11-92.
2. Duster, Dave. Operations Manager, Denver International Airport, Denver Colorado, Personal
Communication 2-11-92.
3. U.S. Department of Transportation, Federal Aviation Administration. Management of Airport
Industrial Waste, 2/11/91. (150/5320-15).
4. Washington State Department of Ecology. Stormwater Management Manual, Urban Land Use
BMPs. Public Review Draft, June 1991.
5. Novotny, V., and Chesters, G. Handbook of Nonpoint Pollution Sources and Management. New
York, Van Nostrand Reinhold. 1981.
147
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August 7, 1992
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
SOLID WASTE SOURCE REDUCTION
AT THE FT. EUSTIS COMMISSARY
by
Jennifer Marron
Science Applications International Corporation
Cincinnati, Ohio 45203
EPA Contract No. 68-C8-0062, WA 3-70
SAIC Project No. 01-0832-03-1021-010
Project Officer
Mr. Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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INTRODUCTION
Solid waste management is a pressing issue in most communities. Many concerned citizens want
to do their part to alleviate the landfill crisis, but they are often confused about how to act. With an
abundance of advertising claims, a lack of information about what is recyclable and where it can be
recycled, and a lack of alternatives to heavily packaged products, consumers understandably have
become frustrated. They want to use their consuming dollars to show their commitment to the
environment, but they are unsure of what to buy. To alleviate this confusion, facilities such as the Ft.
Eustis Commissary need to take the lead in helping consumers to act on their desire to purchase more
environmentally sound products.
This report outlines a suggested strategy for making the Ft. Eustis Commissary a model "green"
commissary. The strategy focuses on minimizing the commissary's generation of in-house waste and
offering consumers a choice of products that contain fewer toxic materials and/or less packaging. As
part of this strategy, it is recommended that the commissary also function as a community recycling
center where recyclable materials, such as glass bottles and aluminum cans, are collected.
On September 17, 1991, the U.S. EPA performed a pollution prevention opportunity assessment of
the Ft. Eustis Commissary. EPA was supported in this effort by LL Col. James Howell (Food and Safety
and Quality Assurance, Ft. Lee) and Mr. Fisher (Ft. Eustis Commissary Director) at Ft. Eustis. Following
the assessment, it was decided that, as part of the Tidewater Interagency Pollution Prevention Program
(TIPPP), the Ft. Eustis Commissary would participate in a demonstration project showing how
commissaries can become "green" without decreasing profitability. (In some cases, waste education
activities may actually increase profitability.) The program can be implemented in incremental stages, so
that the normal operations of the commissary are not disrupted.
In an effort to assist the Defense Commissary Agency in using the Ft. Eustis Commissary as a test
case for developing a model "green" commissary, the following pollution prevention activities are
proposed:
• minimize the amount of in-house waste generated by the commissary;
• work with distributors to reduce the amount of packaging used to ship products to the
commissary;
• implement/test product classifications that might allow the commissary to rank the
environmental "greenness" of products;
• identify marketing/display strategies to encourage customers to purchase "green" products;
• identify activities to eliminate, reduce, or properly dispose of, household hazardous waste;
• support existing installation recycling programs by: (1) informing patrons about these programs;
(2) establishing centralized collection areas for consumers who live outside of the installation;
and (3) helping to develop markets by selling products made from, or packaged in, recycled
materials.
The implementation of these activities is discussed in greater detail in the sections following
"Process Reviews," which describe the pattern of waste generation associated with the normal
operations of the Ft. Eustis Commissary.
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PROCESS REVIEWS
The municipal solid waste (MSW) generated by the Ft. Eustis Commissary can be divided into two
distinct waste streams: waste that is a by-product of the normal operations of the commissary and waste
that is generated by the commissary's customers.
Commissary Wastes
The operation of the Ft. Eustis Commissary can be divided into four process areas:
• loading dock/delivery area
• fresh food processing area
• check-out lanes
• commissary office
Loading dock/delivery area
All products that are sold at the commissary are received and unpacked at the loading dock.
Wastes generated in this area include: coated and uncoated cardboard, shrinkwrap, plastic strapping,
broken pallets, damaged crates and broken glass containers. The Food Marketing Institute (FMI)
estimates that corrugated cardboard comprises 84 percent of the waste stream of large supermarket
chains and 46 percent of the waste stream of small supermarket chains. One supermarket chain,
Mannaford Bros. Co., estimates that 30 percent of its corrugated cardboard is unrecyclable because it is
either waxed (6.5 percent) or wet (23.4 percent).
Fresh food processing area
All fresh foods must be inspected, and in some cases packaged, before they are put on display.
Wastes generated as a consequence of preparing fresh fruits, vegetables, meats, poultry, fish, deli items,
and bakery products include: produce wastes; meat trimmings; unsold prepared foods like salads; stale
bread and other outdated bakery products; used cooking oil; and plastic waste such as shrink wrap,
polystyrene trays and plastic containers. Other wastes generated in this area include used cleaning
products such as paper towels, sponges, and containers for cleaners like ammonia and window cleaner.
If the commissary sells flowers, floral wastes are also generated in this process area
Check-out lanes
Customer purchases are registered, paid for, and bagged in the check-out lane. The check-out
lane also provides customers with the opportunity to pick up some last minute items like magazines and
snack foods.
Commissary office
The office is where paper work pertaining to the operation of the commissary is accomplished.
Typical office wastes such as waste paper, laser printer and photocopier cartridges, aluminum cans,
bottles and newspapers are generated in the commissary office.
Consumer Wastes
All of the products purchased at the commissary ultimately become part of the wastes generated
by consumers at home. The consumer waste stream contains considerably less produce and meat
wastes and more packaging wastes, than the commissary waste stream. According to the U.S. EPA, 30
15'0
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percent of ail MSW (by weight and by volume) is packaging. This includes paper, paperboard, plastic
bags, and containers, film plastics, aluminum and bi-metal cans, glass, register tape, magazines, and the
packaging from single serving size products (e.g., potato chips, chewing gum). Food wastes comprise
just 7 percent by weight, and 3 percent by volume, of the municipal solid waste stream.
To more precisely measure the amount of municipal solid waste generated by the commissary's
customers, a standard per capita generation rate can be applied to the number of people living at
Ft. Eustis and/or near the installation. In 1988, the U.S. EPA estimated the per capita generation rate in
the U.S. to be 4.0 pounds per person per day of MSW. This rate is expected to increase to 4.2 pounds
per person per day by 1995.
Part of this 4.0 pounds per person per day is household hazardous wastes that are supplied by the
commissary and eventually become part of the municipal solid waste stream. Typical household
hazardous wastes are shown in Table 1.
TABLE 1. HOUSEHOLD HAZARDOUS WASTES FROM ITEMS SOLD AT THE COMMISSARY
furniture polishes
furniture stains
floor waxes
car waxes
spray dust cleaners
drain cleaners
toilet bowl cleaners
oven cleaners
spot and stain removers
aerosols
shoe polishes
self-lighting charcoal
charcoal lighter fluid
butane lighters
motor oil
paints
glues
batteries
ASSESSMENT
The Ft. Eustis Commissary is located on a military installation in eastern Virginia. This new
commissary became fully operational in September 1991. The facility is very large, and currently uses
only one third of its warehouse space. The Ft. Eustis Commissary is used by Ft. Eustis residents and
military personnel that live near the installation. This clientele may be more receptive to pollution
prevention efforts than other supermarket shoppers. Ft. Eustis residents are accustomed to recycling,
since the installation already has an established collection program (as required by DoD directive) for
cardboard, paper, metals, aluminum cans, and glass.
The commissary purchases its goods through commercial food distributors and manufacturers.
The deli and bakery at the Ft. Eustis Commissary are controlled by operators.
Data Gaps
Except for the amount of fruit and vegetable wastes generated daily at the Ft. Eustis Commissary,
very little hard data on the faclity's waste generation was available. Consequently, the following
pollution prevention analysis is based on a general understanding of supermarket and consumer wastes
and some specific statistics compiled by the U.S. EPA and the Grocery Industry Committee on Solid
Waste.
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Pollution Prevention Activities
The commissary is already engaged in several on-going and planned pollution prevention activities.
On-going activities
• Reusable plastic crates. The commissary already receives some products, such as cartons of
milk, in reusable plastic crates.
• Cardboard recycling. The commissary is baling its uncoated corrugated cardboard boxes and
selling them to a local recycler.
• Discourage double-bagging. The commissary is discouraging double-bagging unless
specifically requested by the customer.
Proposed activities
• Cardboard boxes made from recycled paper. The commissary is planning to request that its
distributors use cardboard boxes with recycled content to ship products to the commissary.
• Paper bags made from post-consumer waste paper. The commissary is planning to request
that its distributor supply brown kraft paper bags with recycled content.
Following an on-site visit to the Ft. Eustis commissary in September 1991, several additional
activities for reducing commissary and consumer wastes were identified.
For commissary wastes:
Reduce the amount of in-house waste generated at the commissary by:
• using less packaging to ship products to the commissary.
• using reusable shipping containers.
Recycle commissary wastes by:
recycling shrinkwrap.
recycling plastic strapping.
recycling used pallets and wood vegetable crates.
composting food wastes.
recycling meat scraps.
For consumer wastes:
Reduce the amount and toxteity of wastes generated by consumers at home by:
• stocking the largest container size of popular products.
• stocking alternative non-toxic cleaning products.
• installing bulk distribution units for some products.
• selling fruits and vegetables loose, not packaged.
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• selling meats, poultry and fish 'deli-style," not packaged.
• selling reusable canvas bags.
Encourage consumers to recycle and to buy products that are recyclable and/or that come in
packaging with recycled content by:
• establishing a drop-off center at the commissary.
• offering consumers a choice between paper and plastic bags, and an option to return either to
the store.
FEASIBILITY
A feasibility analysis for each pollution prevention option was conducted using a modified
worksheet Number 13. Each option was rated qualitatively (see descriptions below), then evaluated
quantitatively according to 14 criteria (see Tables 2 and 3). The following pollution prevention activities
are listed in descending order of importance.
For commissary wastes:
• Reduce the amount of packaging used to ship products to the commissary. Distributors use
large amounts of corrugated cardboard and plastic shrinkwrap to package products for
shipping. For many items, such as cartons of milk and fruit, it is possible to use reusable
plastic crates or baskets instead. The commissary should encourage its distributors to ship
other products in reusable containers.
• Return used crates and pallets to the distributor for reuse. This is very easy to do, since
distributors are always in a position to backhaul materials from the commissary. Given the large
amount of available storage space at the Ft. Eustis Commissary, it should be possible to store
enough pallets to fill a distributor's truck for backhaul ing. Not all pallets can be reused or
repaired. These used pallets should be returned to the distributor for recycling or sent to a
local end-user, such as a wood chipping operation. Doing so will reduce the commissary's
landfill tipping fees.
• Recycle coated corrugated cardboard. Corrugated cardboard is one of the most highly sought
after recyclables. Therefore, it is likely that end-users exist for even the lower grade coated
cardboard. Finding a market for the coated cardboard would save money by reducing the
amount the commissary pays in landfill tipping fees.
• Recycle shrinkwrap. In recent years, shrinkwrapping products together rather than boxing them
has become very popular. It is easy to do and saves in shipping costs, since the plastic wrap is
much lighter than corrugated cardboard. Shrinkwrap is also used to wrap pallet loads of
products to contain them during shipping. This plastic material represents a significant part of
the commissary's waste stream. It is recyclable, as evidenced by the shrinkwrap recycling
programs in place at other supermarkets, including Giant (Maryland) and Hannaford Bros. Co.'s
Shop 'n Save (Portland, ME).
• Recycle plastic strapping. Plastic strapping is commonly used to attach stacked corrugated
boxes to pallets. It should be collected separately and sent to a plastic resin recycler, who may
turn it back into plastic strapping.
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Compost food wastes. Food wastes include fruit and vegetable scraps, stale bakery products
and unsold prepared foods. These wastes are valuable and should be recycled into a soil
amendment whenever possible. Food contaminated paper products such as paper towels and
napkins can be composted along with these wastes. The commissary generates a significant
amount of food wastes. Composting these wastes would result in a savings in the form of
avoided landfill disposal costs.
Supermarkets around the country are involved in food waste composting programs, including
Star Market (Boston, MA) and Hannaford Bros. Co.'s Shop 'n Save (Portland, ME). Star Market
is working with the Massachusetts Department of Environmental Protection on an experimental
composting program; food wastes are collected from the stores once or twice a week and
brought to a nursery where they are composted and used for potting soil. Shop 'n Save has
found two agricultural composting sites near its Portland store that are willing to take food
wastes as long as the store absorbs the cost of transportation. Shop 'n Save claims that
composting its food scraps has resulted in a 50 percent decrease in the amount of waste that it
sends to the local landfill.
In contrast to Star Market and Shop 'n Save, Puget Consumers Co-op (Seattle, WA) operates a
composting facility behind one of its stores. This is a good option for Ft. Eustis, since the
resulting compost could be used for landscaping at the installation and/or offered to customers.
Recycle meat scraps. Meat trimmings, bone and outdated fish can be sent to a local rendering
plant. Meat fat and bone contain tallow which is used in the manufacture of soap.
For consumer wastes:
Stock the largest size container of popular products. This gives customers the option to
reduce the amount of packaging waste that they generate at home. Single-serving containers
and other small packages are a major source of packaging waste. Many products are available
in large sizes and can be easily supplied by a distributor.
Stock alternative, non-toxic cleaning products. This will help to reduce the amount of
household hazardous waste generated by the installation and local community. By
accompanying displays of alternative cleaning products with explanatory brochures, this activity
will also serve an important public education function. Several ordinary supermarket products
can be used for cleaning, such as baking soda and vinegar.
Install bulk distribution units for certain products such as cereals and laundry detergent. This
will reduce the amount of packaging waste generated by customers at home. Several products,
such as coffee beans and nuts, are already sold in bulk in most stores. Although it should not
be difficult to find a distributor that can provide the necessary dispensers and an array of
products suitable for bulk distribution, customer generally do not like bulk for many foods.
Army personnel also believe that buying in such larger quantities could create a sanitation
problem.
Sell fruits and vegetables loose, not packaged in polystyrene and plastic wrap. This will reduce
the amount of packaging waste generated by customers at home. Since many fruits and
vegetables are already sold both in bulk and packaged, this activity simply requires the
elimination of the packaging option. This may save money by reducing the amount of time
commissary employees spend wrapping fruits and vegetables.
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• Sell meats, poultry and fish 'deli-style;' that is, upon request, rather than packaged and set out
in a display. This will reduce the amount of plastic packaging discarded; however, it may
increase the amount of unrecyclabie paper discarded by customers at home, since paper will
be used to package meats for transporting home. Another problem that may arise is the
possible inability to meet customer demand at lunch for meats and poultry.
• Sell reusable canvas bags that customers can bring to the commissary to be used instead of
paper or plastic bags. This is being done in supermarkets throughout the U.S. There are many
manufacturers of canvas bags, thus it should be easy to acquire them at a reasonable price.
However, before this can be implemented it must be authorized.
• Offer customers a choice between paper and plastic bags. Such a choice mirrors those that
customers face throughout the commissary. Offering a choice between paper and plastic bags
draws the customer's attention to the fact that they are choosing a form of packaging for their
groceries. Presenting this choice may remind consumers that it is more environmentally sound
to bring their own canvas bags. There are no costs associated with this pollution prevention
activity.
• Stock and label products packaged in recycled or recyclable packaging. It is more difficult to
accurately identify recycled packaging, thus this activity would require some research.
However, it would be of enormous benefit to the commissary's customers, who need assistance
In sorting through the numerous and contradictory packaging claims made by manufacturers.
• Establish a drop-off center for recyclables at the commissary. This activity involves the
collection of recyclables at the commissary, either in the warehouse or outside in the parking
lot. It would enhance Ft. Eustis1 recycling program by providing a drop-off center at a
frequently visited location. To do so requires adequate space, staffing, and promotion. Many
supermarkets in the United States have drop-off centers for newspapers, bottles and cans in
their parking lots.
CROSSFEED TO OTHER TIPPP INSTALLATIONS
The commissary and consumer pollution prevention activities described above could be
implemented at other commissaries that are interested in reducing the amount of solid and household
hazardous waste that they and their customers generate. Some of the options could also be applied to
other facilities that deal with food products, such as cafeterias and hospitals.
MEASUREMENT OF POLLUTION PREVENTION
Measurement of the efficacy of pollution prevention methods is very important in demonstrating
success and gaining support and funding for follow-up projects. A system of recordkeeping, for
example to detal customer preference for paper versus plastic bags and how many of each were
returned to the store form recycling, is a necessary part of quantifying waste reduction.
Several options presented in this report will be successful only if consumers participate in the
program and continue to buy the product Quantifying recycling programs and negotiating specific
packaging options from the suppliers to the commissary are relatively easy.
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IMPLEMENTATION
This section reviews the pollution prevention strategies discussed above in terms of any barriers to
their implementation.
No Barriers
Offer customers a choice between paper and plastic bags. This pollution prevention activity
should be implemented immediately, as there are no costs associated with it and it requires
virtually no change in current commissary operating procedures.
Discourage the practice of double-bagging unless it is specifically requested by the customer.
This pollution prevention activity should be implemented immediately, as there are no costs
associated with it and it requires virtually no change in current commissary operating
procedures.
Sell reusable canvas bags that customers can bring to the commissary to be used instead of
paper or plastic bags. There are so many different types of canvas bags on the market, that it
should be easy to find a suitable bag at a reasonable price. Several manufacturers should be
contacted and samples requested. If the commissary chooses to implement this option, they
should consider selling the bags at cost to encourage consumers to buy and use them.
Although the commissary would not make any money in such an enterprise, savings would
result from not needing to purchase as many paper and plastic bags.
Sell fruits and vegetables loose, not packaged. This option should be implemented
immediately for all produce items that have not been packaged prior to delivery. There are no
capital costs associated with this activity, which should save money by no longer requiring that
commissary employees spend time wrapping fruits and vegetables.
Stock the largest size container of popular products. Making more shelf room for larger
packages should not be a problem, since the Ft. Eustis commissary has more space than it can
currently use. A potential problem with implementing this pollution prevention strategy is
consumer acceptance. Often, large product sizes do not sell well because people find them
cumbersome and difficult to use. This could be remedied by stocking large sizes that come
with built in handles and allowing customers to take their shopping carts all the way to the car.
Few Barriers
Reduce the amount of packaging used to ship products to the commissary. This may be
difficult now that procurement for all commissaries is arranged through the American Logistics
Agency, so that any change in distribution will affect more stores than just the Ft. Eustis
Commissary. However, it is should be pursued since It is one of the pollution prevention
actMtftt that is likely to have the greatest impact on reducing the amount of in-house waste
generated by the commissary.
Return used crates and pallets to the distributor for reuse. Storing pallets and crates until a
sufficient number have accumulated to justify the distributor's backhauling them could pose
some problems. Although Ft. Eustis has ample storage space, standard commissary operating
procedures may prohibit the accumulation of items inside the facility. If so, an arrangement
should be worked out with the distributor whereby the pallets and crates are taken back each
time a new shipment of goods is delivered. Used pallets that cannot be reused or repaired
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should be recycled. Used pallets can be made into wood chips or burned for fuel. Therefore,
implementing this activity will require some research to find a local end-user for the pallets
and/or some time to set up a system for distributing broken pallets to the commissary's
customers who can take them home to bum in their fireplaces or stoves.
• Recycle coated corrugated cardboard. The mechanisms for collecting and baling cardboard
are already in place at the commissary. Thus, the only hurdle to implementing this pollution
prevention activity is finding a market for the coated cardboard. This will take some time, but
should be possible given the commissary's location in the Southeast (where many of the
recycled linerboard manufacturers are located).
• Recycle shrinkwrap. Finding a mechanism for collecting the plastic wrap should be easy, given
the commissary's experience with collecting cardboard and the installation's experience with
collecting other recydaWes such as bottles and cans. What may prove difficult is finding a
market for the collected shrinkwrap. Before this activity is implemented, a thorough
investigation of local markets for recycled film plastics should be made.
• Recycle plastic strapping. Plastic strapping can be collected at the same time that corrugated
cardboard and shrinkwrap are collected for recycling. Finding a market for recycled plastic
strapping is likely to be more difficult than for the other two materials. If an end-user for
shrinkwrap is found, they may also be able to take the strapping.
• Stock alternative, non-toxic cleaning products. This strategy requires some creativity and
supporting literature. Alternative products, such as baking soda and vinegar, need to be
displayed beside common household cleaners, with pamphlets explaining their use. Other non-
toxic cleaners should be ordered, which will require approval from the American Logistics
Agency.
• Stock and label products packaged in recycled or recyclable packaging. Industry is presently
packaging and marking materials that have recycled content which greatly aids in stocking.
• Establish a drop-off center for recyclables at the commissary. This option should be viewed as
an extension of the installation's recycling program, with the commissary being a new drop-off
location. Maintaining the drop-off will require a small investment in containers and some
staffing, but these costs should not be prohibitive.
Several Barriers
• Install bulk distribution units for certain products such as cereals and laundry detergent Due
to the large size of Ft Eustis' new commissary, finding aisle space to house bulk distribution
units should not be difficult However, retrofitting shelves to accommodate the units could be
costly. Thus, the implementation of this pollution prevention activity depends on the availability
of funds. Another important consideration is consumer acceptance. The supermarket chain
Shop 'n Save (Portland, ME) tried bulk distribution for a wide range of products from jello to
detergent, but found that consumers did not like it. Changing negative customer attitudes
regarding buying in bulk will also be necessary in order to implement
• Sell standard size reusable containers for use in conjunction with a bulk distribution system.
The primary barrier to the implementation of this option is cost. Having containers specially
made and possibly selling them at cost to customers (to encourage them to use the bulk
distribution system) could be expensive. In addition, consumers might not like the containers
-------
and/or find It troublesome to remember to bring them to the commissary.
• Sell meats, poultry and fish 'deli-style;' that is, upon request, rather than packaged and set out
in a display. Implementation depends on the willingness of the meat contractor to change the
way these foods are sold. It also may require extra staffing, although this should be balanced
by the time saved by not wrapping all meat products.
• Compost food wastes. It is easier to implement this pollution prevention option if the food
wastes are collected and taken to an off-site composting facility. Ft. Eustis is located in a rural
area where It should be possible to find an agricultural establishment interested in using their
food wastes (If not to compost, then perhaps to feed to animals like pigs). The alternative is to
establish an on-site composting facility at the commissary. This would require considerably
more time and effort since an appropriate composting pad would need to be built and the
process would have to be monitored. In addition, the commissary would need to obtain a
permit from the State of Virginia to operate a composting facility.
To make the model commissary program truly effective, more research and data gathering should
be done regarding the generation of wastes by the Ft. Eustis commissary and its customers Once this
has been accomplished, there are two other research efforts that would facilitate the implementation of
the pollution prevention strategies. These efforts are listed below:
• Perform a customer survey. Before implementing a bulk distribution system, do a survey of
commissary customers to find out whether or not they would like the opportunity to purchase
foods in bulk. Ask customers what products they think are good candidates for bulk
distribution.
• Energy efficiency assessment. In any follow-up evaluation of pollution prevention opportunities
at the Ft. Eustis Commissary, include an energy efficiency assessment that evaluates the
facility's lighting, refrigeration, cooling and heating systems.
RECOMMENDATIONS/CONCLUSIONS
A pollution prevention opportunity assessment was performed on the commissary at Ft Eustis on
September 17, 1991. More specific data on the generation of wastes by the commissary and its
customers is needed to refine the pollution prevention activities proposed in this report. Four broad
pollution prevention options were identified:
• reduce the amount of in-house waste generated at the commissary.
• recycle commissary wastes.
• reduce the amount and toxictty of wastes generated by customers at home.
• encourage customers to recycle, and to buy products that are recyclable and/or that come in
packaging with recycled content.
The five pollution preventions options that were identified as having no barriers should be
implemented immediately:
160
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offer customers a choice between paper and plastic bags.
discourage double-bagging.
sell reusable canvas bags.
sell fruits and vegetables loose, not packaged.
stock the largest size containers of popular products.
The other eighteen pollution prevention options should be thoroughly analyzed. In particular, Ft.
Eustis should seriously consider implementing the following long-term options that could significantly
reduce the amount and toxicity of wastes generated by the commissary and its customers:
• compost food wastes.
• ship products to the commissary in reusable containers.
• install bulk distribution units for dry products.
• establish a recyclaWes drop-off center.
• stock alternative, non-toxic cleaning products.
l&l
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REFERENCES
1. Callfomlans Against Waste. Buy Recycled Campaign. 1987
2. Central States Education Center. Buy a Better Environment When You Shop. 1988
3. Central States Education Center. Toward a Model Community.
4. City of Berkeley Recycling Division. Precyde. Do It Right from the Start!
5. Biocyde. Composting and Recycling Around the World. Vol. 32, No. 6. June 1991.
6. Biocyde. Composting Commercial Food Waste. Vol. 31, No. 2. February 1990.
7. Coundl for Solid Waste Solutions. The Blueprint for Plastics Recyding. 1991
8. CouncP on Economic Priorities. The Quick and Easy Guide to Socially Responsible Supermarket
Shopping. 1990
9. Dahab, Mohamed F., Holly C. Johnson, and Dewey R. Andersen. Case Study: Solid Waste
Management: A Study of Grocery Stores in Nebraska. Pollution Prevention Review Vol 2 No 1
Winter 1991/92.
10. Elkington, J., J., Hailes, and J. Makower. The Green Consumer. 1990.
11. Environment Canada. Environmentally Friendly Products Program. July 1988.
12. Food Marketing institute. Solid Waste Management in the Food Industry. 1990.
13. Franklin Associates, Ltd. Characterization of Municipal Solid Waste in the U.S.: 1990 Update.
June 1990.
14. Biocyde. Garbage at the Grocery. Vol. 1, No. 1. September/October 1989.
15. League of Women Voters. Recyding Guide. 1991.
16. Marineili, Janet Garbage at the Grocery. Garbage Magazine. September/October 1989.
17. Marineili, Janet The Packaging Challenge. Garbage Magazine. May/June 1990.
18. National Restaurant Association. Managing Solid Wastes: Answers for the Foodservice Operator.
19. Outerbridge, Thomas and Joan Melcher. Setting up an Office Recyding Program. 1987.
162
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20. Progressive Grocer Executive Report. Reclaiming the Environment: How You Can Help.
September 1991.
21. Prince, Jackie. Environmental Defense Fund. The Supermarket Diet: Watching Our Waste.
December 1990.
22. Schwartz, Joe. Shopping for a Model Community. Garbage Magazine. May/June 1990.
23. Seldman, Neil and Bill Perkins. Designing the Waste Stream. Institute for Local Setf-Rellance,
1988.
24. Skajan, Jan. Foodwaste Recycling in Denmark. Biocyde. Vol. 30, No. 11. November 1989.
25. Testin, R.F. and P.J. Vergano. Packaging in America in the 1990s. August 1990.
26. USEPA, Office of Solid Waste and Emergency Response. Decision-Makers Guide to Solid Waste
Management November 1989.
27. USEPA, Office of Solid Waste and Emergency Response. Methods to Manage and Control Plastic
Wastes. February 1990.
28. Watson, Tom. Product Labeling Efforts Are on the March Worldwide. Resource Recycling. Vol. 8,
No. 6. October 1989.
29. Wirka, Jeanne. Wrapped in Plastics: The Environmental Case for Reducing Plastics Packaging.
Environmental Action Foundation, 1988.
30. WorldWatch Institute. Packaging: Discarding the Throwaway Society.
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August 11, 1992
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
PAINTING PROCESS AT
THE FT. EUST1S ARMY FACILITY
by
Susan Roman
Science Applications International Corporation
Falls Church, Virginia
Cincinnati, Ohio 45203
EPA Contract No. 68-C8-0062, WA 3-70
SAIC Project No. 01-0832-03-1021-010
Project Officer
Mr. Kenneth R. Stone
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
164
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INTRODUCTION
Purpose
The purpose of this project was to conduct a Pollution Prevention Opportunity Assessment (PPOA)
for painting processes at the Ft. Eustis Army Base near Norfolk, Virginia. The assessment was conducted
for the EPA's Risk Reduction Engineering Laboratory under the purview of the Waste Reduction Evaluation
at Federal Sites (WREAFS) of the Pollution Prevention Research Branch. A procedure described in the EPA
Waste Minimization Opportunity Assessment Manual (EPA/625/7-88/003) was used to conduct the study.
The manual provides detailed worksheets and a process/option evaluation method for use in industrial
settings.
Approach
The PPOA consisted of four systematic steps: Planning and Organization, Assessment, Feasibility
Analysis, and Implementation. Rgure 1 presents the Waste Minimization Opportunity Assessment (WMOA)
process. Of the 19 worksheets in the WMOA manual, selected sheets were completed for the processes
and pollution prevention options considered. The detailed worksheets used are presented in Appendix A.
The implementation of the recommended options presented in this report is at the discretion of the host
facility.
PROCESS REVIEW
The U.S. Army's large transportation vehicles undergo overhaul and refurbishment at Fort Eustis.
This overhaul and refurbishment is the responsibility of a contractor, Northrop Worldwide Aircraft Service's
Fort Eustis Division (Northrop). The operation is conducted under the Directorate of Logistics (DOL) by the
Maintenance Department of the Installation Maintenance Office in the Tactical Vehicle Shop (Building 1411).
The focus of this assessment is on the painting operations conducted as part of the overhaul and
refurbishment of vehicles for continued service.
Personnel and Work Load
The painting operation employs four persons continually: one painter and three persons who do
the sanding and masking. Generally painting is done five days per week in a single shift per day.
Occasionally work is done on Saturday if there is a need to catch-up on the work load. During times of
heavy work loads additional personnel are employed in the painting operation (up to nine persons total).
A total of 1400 vehicles are painted on a rotating basis in this painting operation. Approximately
20 to 30 vehicles are painted per month for a total of 240 to 360 vehicles painted per year. Just prior to
Desert Shield/Desert Storm there was an increase in the amount of painting done because vehicles were
being prepared for shipment overseas. Currently vehicles that have come back from Desert Storm are being
stripped and repainted.
Spray Painting Operation
The paint booth is approximately 50 feet long, 20 feet wide, and 25 feet high and is believed to be
38 years old (the building was constructed in 1963 and all sources indicate that the paint booth was installed
when the building was constructed). Almost all of the painting is done within the paint booth which is
equipped with a water curtain to capture paint overspray. Touch-up painting is occasionally done outside
of Building 1411 with a paint brush (prior approval must be obtained for this procedure). The booth is totally
enclosed because the painting operation is hazardous. The paint that is used is a Chemical Agent Resistant
Coating (CARC). The CARC paint is extremely hazardous in liquid form but is non-hazardous when dry.
165
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The CARC paint is solvent-based and is applied using standard spray painting methods. The paint
is mixed with paint thinner (cellulose nitrate) in the paint pot and then applied with hand-held spray guns
and pressure. There are two spray guns in use in this painting operation. One is a large paint gun that is
operated at 20 to 25 psi and the other is a small paint gun that is operated at 40 to 55 psi.
All of the painting is done in either the desert sand or jungle green camouflage colors. Cleaning
of the painting equipment between colors is not necessary because of this camouflage pattern. Cleaning
of the painting equipment and lines is performed at the end of the shift with the paint thinner recommended
for use with CARC paint by the manufacturer.
The raw materials used in the CARC painting operation include CARC paint, paint thinner, municipal
water, and personal protective equipment. Due to the hazardous properties of the CARC paint (Material
Safety Data Sheets (MSDS's) were provided) personal protective equipment must be worn while painting.
Personal protective equipment consists of airline respirators, half-mask respirators, disposable coveralls,
rubber gloves, and industrial footwear. Table 1 lists the raw materials used in the CARC painting operation,
annual consumption rates, and costs (all costs have been rounded to the nearest whole dollar amount).
In preparation for the paint application, the vehicle is sandblasted to remove heavy corrosion or
surface sanded by hand. Sandblasting is currently conducted outside of Building 1411 in an open area and
the blasted material is deposited on the ground. Soil sampling conducted by the facility in September 1990
indicated high levels of lead and chromium in the soH surrounding building 1411 where the sandblasting is
conducted. Toxicity Characteristic Leachate Procedure (TCLP) tests were also conducted and it was
determined that the soil would not be considered a hazardous waste at the present time. Measures to
prevent further contamination have been instituted by the Fort An indoor sandblasting facility should be
installed and operational by June of 1992.
Following the sanding procedure the vehicle is masked by hand with standard masking tape and
brown paper. Then the vehicle is driven into the paint booth, painted with a base coat and additional colors
to form the camouflage pattern, is allowed to air dry and the masking removed. During the spray painting
operation, paint overspray is captured by the water curtains in the paint booth and the floor of the booth
is covered with paper to keep it from being coated with paint Figure 1 is a work flow diagram of the CARC
painting operation.
Wastes generated at Fort Eustis are handled in two ways. Non-hazardous wastes are placed in
dumpsters located throughout the base and are picked up and taken to the city landfill. Hazardous wastes
are handled by the Defense Reutlization and Marketing Office (DRMO). The DRMO collects hazardous
wastes from operations throughout the Fort and holds them at the Hazardous Waste Disposal Accumulation
Facility (Building 1637) to await disposal. The DRMO contracts with a Treatment, Storage and Disposal
Facility (TSDF) in Alabama to dispose of these wastes. The wastes are shipped in bulk whenever sufficient
quantity has been collected but always within 90 days of generation.
Waste Generation in the Spray Painting Operation
The CARC painting operation generates numerous hazardous and non-hazardous wastes. This
assessment focused on the hazardous wastes generated in the CARC painting operation including
wastewater, liquid CARC paint, CARC paint residue, used paint thinner, and contaminated trash. Table 2
lists the hazardous wastes generated in the CARC painting operation, annual generation rates and disposal
costs. The method of generation of each waste stream is described in the remainder of this section.
The paint booth contains two water curtains, one on each side of the booth opposite the booth
entrance. They operate continuously during the work shift Each water curtain circulates 1200 gallons of
water. Approximately 500 gallons of water is added on a weekly basis to make up for evaporation losses.
166-
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Once per month, the water curtains are thoroughly cleaned. This procedure Involves draining the water,
scraping out the accumulated paint residue, and refilling the water curtain. The used water is pumped into
a wastewater holding tank (336 gallon capacity) outside of Building 1411. From this tank, the water is
immediately transferred to 55 gallon drums and taken to Building 1637 to await disposal.
The CARC paint residue (scraped off during the monthly cleaning of the booth) is the result of paint
overspray which has built up as a hard coating on the surfaces of the water curtain. The CARC paint
residue is drummed along with any contaminated trash (paper, wood or rubber that has been contaminated
during the CARC painting operation) and taken to Building 1637 to await disposal.
At the end of the day, unused paint consisting of 60 percent paint and 40 percent paint thinner is
emptied into a 55 gallon drum stored In a three-sided enclosure outside of building 1411. In addition, the
spray painting equipment is cleaned with paint thinner and this waste consisting of 75 percent thinner and
25 percent paint is also emptied into a 55 gallon drum outside of Building 1411. When a drum becomes
full it is removed to Building 1637 to await disposal. Wastes were prioritized during this assessment based
on regulatory compliance, the quantity of waste generated, the disposal cost, potential liability, waste
hazards, safety hazards and the availability and viability of an option to reduce or eliminate the waste. The
waste with the highest priority (shown in Table 2) is the wastewater, followed by the liquid CARC paint, the
used paint thinner, CARC paint residue, and the contaminated trash.
ASSESSMENT
Options were identified in this assessment that would reduce or eliminate the hazardous wastes
generated In the CARC painting operation. The options identified are:
• Option 1 - Booth Maintenance System;
• Option 2 - Improve Transfer Efficiency;
• Option 3 - Recovery of Paint Thinner;
• Option 4 - Installation of a New Paint Booth.
Each option is described briefly in the next section. Table 3 is a comparison of ail four options
including the waste streams and raw materials affected as well as the requirements of each option.
Additional options may be applicable to this painting operation but due to scope limitations only four options
were identified.
FEASIBILITY
Option 1 - Booth Maintenance System
The water circulated in the water curtains is municipal water with no additional chemicals added
When overspray is captured by the water curtains, It immediately adheres to the surfaces and builds up a
coating of paint There are chemicals available that can be added to the water in the water curtains that
will keep the paint from adhering to the surfaces by dispersing ft in the water. Then at the time of the
monthly cleaning, additional chemicals may be added that will flocculate the paint enabling ft to be removed
easily. The water may then be reused instead of being discharged after additional dispersant is added.
Option 2 - Improve Transfer Efficiency
Transfer efficiency refers to the percentage of paint that leaves the paint gun and is actually
deposited on the vehicle's surface. A higher transfer efficiency means more paint is reaching the surface
of the vehicle. High volume-low pressure (HVLP) spray painting equipment can achieve transfer efficiencies
170
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up to 90 percent and is currently in use in many industrial applications. The facility currently uses standard
spray painting equipment and operates in a pressure range from 20 to 55 psi. By converting to a HVLP
spray paini.ng system improved transfer efficiencies may be achieved. An improved transfer efficiency would
decrease raw material usage, decrease CARC paint residue resulting from overspray, and decrease the time
cpent in cleaning out the water curtains.
Transfer efficiencies of spray painting operations are also operator dependent and this is related to the
air pressure used. High pressures generally reduce the transfer efficiency and operators will increase the
pressure to reduce the painting time. Operators should be instructed to use specific air pressures in the
painting operation.
Option 3 - Recovery of Paint Thinner
Currently, used paint thinner consisting of 75 percent thinner and 25 percent paint is disposed of as a
hazardous waste. Recovery of this paint thinner can be achieved with the installation of a recovery still
Used paint thinner can then be distilled for reuse. The waste stream would not be totally eliminated because
the still would generate still bottoms that would need to be disposed. However, the generation rate of still
bottoms would be less than the current generation rate of used paint thinner. This would reduce the amount
of used paint thinner disposed and decrease the amount of virgin paint thinner used in the painting
operation. In addition, the cleaning equipment cleaning procedures can be modified to reduce the
generation of used paint thinner.
Option 4 - Installation of a New Paint Booth
The current paint booth system is used for operations up to truck-sized pieces of equipment The
current system, as discussed previously, is inadequate to protect workers as well as meet minimum air
emissions standards. In addition, the current facility is not of sufficient size to accommodate the large
pieces of field equipment (e.g., cranes, trailers, artHlery pieces, etc.) that are routinely painted at Ft Eustis
As such, Ft. Eustis personnel currently paint such equipment in an uncontained but well ventilated area
Releases to the environment are thus uncontrolled and unmonltored. Thus, in considering reduction
alternatives for painting operations, Ft. Eustis must focus on two similar operations: routine small-scale
painting operations and large-scale painting.
With respect to small-scale painting operations, Ft. Eustis has several opportunities to reduce emissions
the simplest of which may be to replace the current waterfall paint booth system with a dry filtration booth
One specific opportunity exists in that Langley Air Force Base currently has a dry booth (of comparable size
to Eustis s wet system) that might be moved to Ft. Eustis to replace its current system. This is technically
feasible since the booth at Langley is a building insert that can be disassembled and moved Further at
this time, both installations seem willing to discuss the concept but have not formerly identified what
conditions would have to exist to accomplish such a property transfer. Further, the Langiey AFB staff who
currently hoW the paint booth, would need a substitute technology for their small-scale operations1 If such
a transfer could be accomplished, the paint booth could remedy some, but not all, of Ft Eustis waste
generation and release issues associated with painting operations.
Specifically, even if Ft Eustis had a functional dry system to replace the current waterfall technology
they would still need a larger system to accommodate large-scale painting operation, as such even though
replacement of the current would resolve some problems it would do nothing to ease or'eliminate the
1 Langley AFB currently uses the booth for very small-scale painting operations (wood work small
pieces of equipment, etc.). The current booth is oversized for current uses.
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CROSSFEED NEEDS TO OTHER TIPPP INSTALLATIONS
Painting operations are conducted to some extent by all four TIPP participants. Improving paint transfer
efficiency and examination of the booth maintenance program and waterfall curtain systems are directly
relevant to any other painting operation of simUar or larger size.
The Langiey Air Force Base painting hanger provides tangible evidence of improvements in painting
systems and overspray controls and a state-of-the-art system that should be evaluated at the other three
bases. Further, depending on the workload and frequency of use, the new Langiey paint hanger might be
used to schedule some work from the TIPPP participants to overall reduce generation of wastes.
IMPLEMENTATION PLAN
The four options identified in this assessment to reduce/eliminate the wastes generated in the spray
painting operation have all been used in other industrial applications. Therefore, they can be readily
implemented once a particular option is chosen. Options with tow capital costs that reduce waste
generation and raw material usage are usually chosen immediately for implementation. Table 4 lists the
advantages and disadvantages of each option.
Implementation procedures for the pollution prevention options can be conducted in both short-term
and long-term time frames. For each option in this assessment, short-term and long-term implementation
procedures have been identified. Table 5 shows the short-term and long-term implementation procedures
for each option.
Implementation of Option 1 - Booth maintenance system can begin immediately because no new
equipment is required. Vendors of booth maintenance chemicals can be contacted and arrangements made
to have a representative come to the Fort to give a demonstration. More than one vendor should be
contacted and several different systems evaluated in this manner to identify the appropriate booth
maintenance system for this painting operation.
The remaining three options require new equipment or modifications to existing equipment However,
there are still procedures that can be instituted immediately to begin achieving waste reductions.
MEASUREMENT OF POLLUTION PREVENTION
The success of the pollution prevention options identified in this assessment can be measured by 1)
monitoring of waste quantities generated; 2) monitoring raw material usage; 3) monitoring of operator time
required; 4) monitoring the quality of the finished product; and 5) tracking costs. An option would be
considered a success if it:
• reduced both waste generation and raw material usage;
• did not require significant time expenditures by the operator;
• did not adversely affect the quality of the finished product;
• had a reasonable payback period in terms of capital investment to annual operating cost savings.
RESEARCH DEVELOPMENT & DEMONSTRATION NEEDS
Two options identified in this assessment are very viable but may present potential problems at this
facility. These are Option 1 - Booth Maintenance System and Option 3 - Recovery of Paint Thinner. The
CARC paint is extremely hazardous and the implementation of Option 1 - Booth Maintenance System could
possible bring incompatible chemicals in contact with one another. The implementation of Option 3 -
173
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requires a location for the recovery still, an operator, and disposal of the still bottoms. These options would
require further research before they could be implemented.
RECOMMENDATIONS/CONCLUSIONS
A pollution prevention opportunity assessment was conducted at Ft. Eustis Army base near Norfolk,
Virginia in September 1991. The assessment focused on the painting operation conducted at the base, and
resulted in the identification of four major options to reduce or eliminate waste generation.
Although the option requires some refinement and onsite testing, a painting booth maintenance system
appears capable of reducing waste generation. New HVLP paint guns would immediately reduce paint loss,
and would require limited operator training. Recovery of used paint thinner (Option 3) and a new paint
booth (Option 4) are viable, but require larger capital cost; payback is a function of the scale of painting
requirements.
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APPENDIX A
WASTE MINIMIZATION ASSESSMENT WORKSHEETS
The worksheets that follow are designed to facilitate the WM assessment procedure. Table A-1 lists the
worksheets, according to the particular phase of the program, and a brief description of the purpose of the
worksheets.
TABLE A-1. UST OF WASTE MINIMIZATION ASSESSMENT WORKSHEETS
Phase Number and Title
Purpose/Remarks
1. Assessment Overview
Planning and Organization
(Section 2)
2. Program Organization
3. Assessment Team Make-up
Assessment Phase
(Section 3)
4. Site Description
5. Personnel
6. Process Information
7. Input Materials Summary
8. Products Summary
9. Individual Waste Stream
Characterization
Summarizes the overall assessment procedure.
Records key members in the WMA program task force
and the WM assessment teams. Also records the
relevant organization.
Lists names of assessment team members as well as
duties. Includes a list of potential departments to
consider when selecting the teams.
Lists background information about the facility, including
location, products, and operations.
Records information about the personnel who work in
the area to be assessed.
This is a checklist of useful process information to look
for before starting the assessment.
Records input material information for a specific
production or process area This includes name,
supplier, hazardous component or properties, cost,
delivery and shelf-life information, and possible
substitutes.
Identifies hazardous components, production rate,
revenues, and other information about products.
Records source, hazard, generation rate, disposal cost,
and method of treatment or disposal for each waste
stream.
(continued)
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TABLE 1. (continued)
Phase Number and Title
Purpose/Remarks
Assessment Phase (continued)
(Section 3)
10. Waste Stream Summary
11. Option Generation
12. Options Description
13. Options Evaluation by
Weighted Sum Method
Feasibility Analysis Phase
(Section 4)
14. Technical Feasibility
15. Cost Information
16. Profitability Worksheet #1
Payback Period
17. Profitability Worksheet #2
Cash Row for NPV and IRR
Implementation
(Section 5)
18. Project Summary
19. Option Performance
Summarizes ail of the information collected for each
waste stream. This sheet is also used to prioritize waste
streams to assess.
Records options proposed during brainstorming or
nominal group techniques sessions. Includes the
rationale for proposing each options.
Describes and summarizes information about a
proposed option. Also notes approval of promising
options.
Used for screening options using the weighted sum
method.
Detailed checklist for performing a technical evaluation
of a WM option. This worksheet is divided into sections
for equipment-related options, personnel/procedural-
related options, and materials-related options.
Detaled list of capital and operating cost information for
use In the economic evaluation of an option.
Detailed list of capital and operating cost information
developed form Worksheet 15, this worksheet is used to
calculate the payback period.
This worksheet is used to develop cash flows for
calculating NPV or IRR.
Summarizes important tasks to be performed during the
implementation of an option. This includes deliverable,
responsible person, budget, and schedule.
Records material balance information for evaluating the
performance of an implemented option.
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APPENDIX B
TIPPP POLLUTION PREVENTION FACT SHEETS
Nine fact sheets were produced under the TIPPP to develop and demonstrate innovative pollution
prevention opportunities at Federal facilities. These fact sheets include:
01. Metal Working
02. Painting Operations
03. Laboratory Wastes
04. Solvents
05. Electroplating
06. Depainting Operations
07. Municipal Solid Waste
08. Land Management Practices
09. Chemical Material Management
The information contained in the following fact sheets, while accurate in 1992 may no longer be
current. Many of the operations may have changed during the past three years.
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NASA
Issue:
This Fact Sheet has been produced under the Tidewater Interagency Pollution Prevention Program
(TIPPP), a cooperative effort between EPA, DoD, and NASA to develop and demonstrate innovative
pollution prevention opportunities at Federal facilities.
Application*: Metal shaping and surface preparation are two types of metal working operations that might be used
to form a metal object, part, or piece. Shaping operations take raw materials and alter their form to make the
intermediate and final product shapes and may include:
casting
drilling
machining
polishing
shaping
cladding
extruding
reaming
stamping
drawing
grinding
planing
rolling
threading
Surface preparation is an integral step in the metal manufacturing industry and is typically used in all metal manu-
facturing processes. Virtually all fabricated metal products require some form of physical and/™- rh^ni^i mrfacf
preparation prior to finishing to remove unwanted surface materials or to alter the chemical or physical characteris-
tics of the surface. Some surface preparation operations may also be desired prior to some final shaping operations.
As a result of initial and intermediate shaping processes, metal surfaces usually become oxidized or coated with
grease and machining oils, which may interfere wid) the finishing processes. Some products may require only the
removal of rough surfaces and/or edges. Surface preparation operations may include:
• acid cleaning • alkaline cleaning
• emulsion degreasing • etching
• mechanical treatment • paint stripping
• pickling • ultrasonic degreasing
• vapor degreasing • wiping
Installation
Langley AFB
Norfolk Natal But
FortEuatfe
NASALangteyCtr
Estimated Volume of Waste Disposed
N/A
Coolant 163,900 Ibs/yT
N/A
N/A
Key Locations
N/A
Bldg. 932. 941, 942, 972, 981. 993
N/A
N/A
Note: NIA * Not currently avaUabUlappiicabU
Environmental Concera*: Metal shaping and surface preparation cjperaiiora may resul in liquid-, gas-, and solid-
phase wastes that may present a threat to hunian healm ami ttw environment Specifically, metal working operations
usually result in two types of was* including scrap metal and spent metarworking fluids/oils. Surface preparation
operations primarily generate wastes contaminated with solvents ai>d/or ro^
operation. Both waste types may contain heavy metals (lead, chromhim, cadmura, nkkel, etj, various haloge-
nated and non-halogenated organic constituents (1.1,1-trichloroethane, methylene chloride, benzene, toluene, poly
nuclear aromatics, and others, depending on machining fluids and solvents used), and surfactants. Further, surface
preparation may result in the release of volatile organic solvents that may pose a threat through direct exposure to
workers and the surrounding environment
February 1992
Pollution Prevention Fact Sheet
180
No. 01
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NASA 4>EPA
OKD**OffT
Known Solutions/References: Various options have been identified that may result in the reduction of waste
associated with these types of operations. The following is a list of options describing prevention techniques that
apply to one, some, or all of the operations discussed above. The references presented following each option
describe, in detail, applicable pollution prevention techniques, associated costs of implementation, and p^^tial
source reduction gains,
Training and Supervision - Training to instruct operators in water conservation, materials segregation techniques
and process monitoring.
References: 2,4,5,7,10,11,12
Planning and Sequencing • Pre-inspection of parts to identify reject workpieces prior to processing.
References: 6,10,12
Process Modification - Changing current processes to improve efficiency of operations and to decrease pollution
potential. This includes reduction of atmospheric emissions using such techniques as increasing free board height,
installing refrigeration coils to condense vapors, rotating workpieces before removal to drip solvents back to
reservoir, implementing reduced drag-out techniques, increased drainage, proper racking, use of counter-current
cleaning to maximize use of cleaning solvent prior to disposal or recycle.
References: 4,6,7,9,10,11,12
Raw Material Substitutions - Identifying and using less toxic materials. This includes using alternatives for
chlorinated hydrocarbon cleaning solvents, such as aliphatic hydrocarbons, dibasic acid esters, N-methyl-2-
pyrrolidone and lenenes.
References: 2.4.5.6,7,9,10.11.12,14
Waste SegrcgatiMi - Segregating waste streams to recover and recycte metals, and to avoid contamination of other
wastes with potentially toxic constituents.
References: 1,7,10,12,14
Recycling aid RIMI - Devjsjaf methods to maimwift use of rinse waters and other materials, such as solvents.
St*A methods mchide use erf activated artMtt,cx^^
waste waters using evaporation, on-aite recycling of solvents by distillation, filtration and gravity separation.
References: 23,4,6,7.10,11.12,14
Loss Prevention a»d Howkf rping Controls - Preventive maintenance on equipment to minimize leaks and spills.
Establishment of solvent check-out procedures through stop foreman.
References: 10,12
Metal Recovery • Recovery of predous metals and metal sabs from sludges and spent process baths through such
procedures as evaporation, reverse osmosis, ion exchange, electrolvtk recovery and electrolysis.
Reference*: 1 JA&SJ.9.HU2
Material! HandUng and Storage - Pre-inspection of materials, proper storage of chemicals to prevent degradation,
inventory control
References: 6.7,9.10
February 1992 Pollution Prevention Fact Sheet NO. o i
181
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Norfolk Nmimltftt
NASA ®EPA
LMffejr Air Font Ban
Fort Snail
Ltutflfy Rtttartk Ctxltr
References
1. Bradd, Byron B., and Zwierzykowski, Michal, ETICAM. Waste Minimiiaiion - Thff fim{ Process Technol
ogy '88 Symposium Proceedings, Supplement I for the US Air Force, Tyndall AFB. Florida. August 1988.
I Services. Hazardous Waste Reduction Facts. Metal P\nn\\\n9
3. Energy Pathways Inc. and Pollution Probe Foundation (prepared for Industrial Programs Branch Conservation
t?tt!e!S^t EnvmDnmenl Can*fc)- Catalogue Of Successful Fhanin.,* Waae ReA.rfmn/Pccvcling pmiarr.
March 1987.
4. HMS Environmental Inc. (for the Washington State Department of Ecology, Office of Waste Reduction)
Summary Renort - Metal Plating Industry Waste Reduction Audi* June 1989.
5.
6. Jacobs Engineering Group Inc. (prepared for Toxic Substances Control Program, California Department of
Health Services). Waste Audit Study. Fabric^ M^ Products Tnrf..«^y 1989.
7. New Jersey Department of Environmental Protection, Division of Hazardous Waste Management Fabricated
Metal Manufacturing and Meal Finishing. Hazardous Waste Advisement Program, Bureau of Regulation and
Classification.
8. USEPA, Air and Energy Engineering Research Laboratory. Project Summary Novel VaDor-Den<*it«l
Lubricants for Metal-forming Process December 1987. (EPA/600/52-87/060)
9. USEPA, Effluent Guidelines and Permits Division. Guidance Manual for Etetmnlarina ^ Metal Finishing
Pretreatment ^^njajdjjt February 1984. r
10. USEPA, Risk Reduction Engineering Laboratory and California Department of Heal* Services. Guideline
Pollution Prevention: The Fabricated Metal Products Industry July 1990. (EPA 62V7-90/006)
11. USEPA, Region m. Pollution Prevention Program. Opportunity in, frfftaj Fhiitfimg October 1990.
12. USEPA, Office of Research and Devetoproem aiidte Office
-------
NASA &EPA
Norfolk N*»4Btm
LM|fc? Air Fort* J«M
Fort Emit
Lfuflty Ktmtvtk Ctmtr
Issue: Painting Operations
This Fact Sheet has been produced under the Tidewater Interagency Pollution Prevention Program
(TIPPP), a cooperative effort between EPA, DoD, and NASA to develop and demonstrate innovative
pollution prevention opportunities at Federal facilities.
Applications: Painting operations are conducted at all of the installations to some extent These operations can
range from small "spot" painting to full scale painting operations. Typically, equipment painted includes:
• trucks • ships
• jeeps • aircraft carriers
• gun turrets • helicopters
• tanks • airplanes
Installation
Langley AFB
Norfolk Naval
Base
Fort Eustis
NASA Langley Ctr
Estimated Volume of Waste Disposed
Sludge
Solvent
Paint
Thinner
Waste Paint
Thinner
1 drum/wk
1 dnim/mo
2,400 Ibs/yr
3,150 Ibs/yr
293,700 Ibs/yr
330 Ibs/yr
1,650 Ibs/yr
64,900 Ibs/yr
1,650 Ibs/yr
715gal/yr
5gal/yr
Key Locations
Bldg. 781
Bldg. 781
Shop 901
Shop 935
Shop 936
Shop 971
Shop 901
Shop 935
Shop 971
Bldg. 141 1 and various locations
Bldg. 640
Environmental Coacern: These painting operations can be conducted on an around-the-clock basis, thus generat-
ing large amounts of painting wastes including unused paints, paint sludges, and solvents. Paint, which may contain
high levels of heavy metals including lead, cadmium, mercury, chromium, copper, and titanium, can cause signifi-
cant damage to human health as well as contaminate potable water sources (ground and surface waters). Painting
operations may also include the use of chlorinated solvents which create solvent- and paint-bearing sludges as well
as release volatile organic compounds to the air creating health and safety hazards for the workers.
Known Solutions/References: Various options have been identified that may result in the reduction of waste
associated with these types of operations. The following is a list of options describing prevention techniques that
apply to one, some, or all of the operations discussed above. The references presented following each option
describe, in detail applicable pollution prevention techniques, associated costs of implementation, and potential
source reduction gains.
February 1992
Pollution Prevention Fact Sheet
183
No. 02
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NASA
Air Assisted Airless Spray Equipment - A coaling application technique in which paint is delivered to a spray gun
under very high pressure. No air is required since the pressure at which the coating is delivered to the nozzle is
sufficient to atomize it
References: 2830
High-Volume Low-pressure Spray Painting (HVLP) - A compressed air paint spraying system utilized to reduce
overspray.
References: 13,5
Electrostatic - A coating application technique in which an electrostatic charge is given to the workpiece and the
gun nozzle is given the opposite charge. The spray is attracted to the woric surface to the extent that some of the
overspray curves back and coats the reverse side of the work-
References: 1,2830
Dip Tanks - A technique in which a workpiece is inserted into a tank of coating, removed, and allowed to drain
back in the tank. Excess paint may be removed electrostatically or by a doctor blade or squeegee.
Reference: 28
Cyclone Separator and Paint Detackifying Compound - This system is used to rteduce paint sludge generation.
The cyclone separator and paint detackifying compound are used to dewaier and concentrate solids in the paint
sludge.
Reference: 6
UNICARB™ - A coating technique which applies coating by using supercritical carbon dioxide. Supercritical
carbon dioxide produces vigorous atomization and allows for high quality coating without the use of volatile organic
solvents.
Reference: 7
Product Substitution - The substitution of water-based paints for solvent-based paints. Water-based paints reduce
worker exposure to solvent vapors and allows cleanup with only water.
References: 1.6,7,9,10,15,21,25,2830
Recycling - This process channels hazardous wastes back into the production process. Organic solvents which
become contaminated through industrial use without being consumed in the manufacturing process may be recov-
ered, reused, and recycled.
References: 1,2,4,5,6,8,9.11.15,16,19,20.22.23.24,25,28
Incineration - The combustion of organic wastes used to dispose of still bottom wastes resulting from the use of
organic solvent!.
Reference: 7
Process Redesign/Equipment Modification - Includes the aJteratk» of the existmgpr^
equipment or the implementation of new technologies or changes in operating practices affecting the process (Le.,
housekeeping or maintenance).
References: 6,7,9,14,17,21,25
Segregation - Separation of a solvent waste stream from other solvent and non-solvent waste streams. Utilization
of water can aid in future recovery efforts.
References: 7,9,13,25
February 1992 Pollution Prevention Fact Sheet NO. 02
184
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NASA &EPA
*i U*tlfjA*rort*am. FonEnau Lanflfj AMMTC* C
Heat Recovery - Spent solvents may be used as supplementary fuels, particularly in high-temperature industrial
processes.
References: 6,15,22,25
Housekeeping Changes/Training - Procedural changes and procurement modification to reduce waste of raw
materials. For example, only purchase the amount needed to complete the task to avoid the accumulation of excess
paints that may expire and require disposal
References: 1.3,5,6,7,9,13,14,15,17,25,26,30
References
1. Alaska Health Project, Waste Reduction Assistance Program. Qn-site Automobile Body Repair and Paint Shop.
August 1987.
2. Brent, S. A Workbook: Pollution Prevention bv Source Reduction in Textile Wet Processing. University of
North Carolina. 1988.
3. Bridges, J.S. Waste Minimization Assessments at Selected POP Facilities. Proceedings of International
Conference on Pollution Prevention: Clean Technologies and Clean Products, Washington, D.C. June 1990.
4. Cushnie, G. Waste Reduction Evaluations at the Philadelphia Naval Shipyard and Fort Rilev. Kansas. Proceed-
ings of International Conference on Pollution Prevention: Clean Technologies and Clean Products, Washington,
D.C. June 1990.
5. Department of Energy, Office of Technology Development, Environmental Restoration and Waste Manage-
ment, First Animal Inttms^00^ Workshop on Solvent Substitution. Phoenix, Arizona, December 1990.
6. Energy Pathways, Inc. and Pollution Probe Foundation for Environment-Canada, Industrial Programs Branch,
Conservation and Protection. Catalogue of SuccesrfnlHjuantousWaiSic^ Protects.
7. Environmental Resources Management, Inc. A Study of Hazardous Wastr Reduction and Recycling in Four
in New Jersey. 1987.
8. Georgia Hazardous Waste Management Authority. Georgia Department of Natml Resources. A Comnrehen-
1JVC HflMfdfflU Wflfitt Mjyuyemcnt Facility for Georgia. 1987.
9. Hazardous Waste Reduction Program of Oregon. Department of Environmental Quality. Guidelines for Waste
Reduction and Recycling - Solvents. 1989.
10. Huisingh, D., eL al. for The Institute for Self Reliance, Washington, D.C. Proven Profit from Pollution Preven-
tion. 1985.
11. Industrial Finishing. "Solvent Recovery Beneficial for Haworth." November 1983.
12. Kaminiski, JJL, Ed. "Hazardous Waste Minimization within the Department of Defense. "Thft ynfffFfflftnaJ
JfMirnfll P^ ^"r ^llufo" Control and Waste M*nagffl1ynf VoL 38. August 1988.
13. Minnesota Office of Waste Management, MnTAP Program. SfaTTrfflW S*"™- Solvent Management. Printing
Press. 1988.
14. Minnesota Office of Waste Management. MnTAP Program. Fact Sheet - Reducing Solvent From Vapor
De greasers. 1990.
15. North Carolina Department of Environment, Health, and Natural Resources. Pollution Prevention - Managing
and Recycling Solvents in the Furniture Industry. 1986.
16. North Carolina Department of Environment, Health and Natural Resources, Pollution Prevention Program.
Pollution Prevention Tips - Small Solvent Recovery Systems. 1987.
17. North Carolina Department of Environment, Health and Natural Resources, Pollution Prevention Program.
Pollution Prevention Tins - Solvent Loss Control - Things You Can Do Now. 1989.
February 1992 Pollution Prevention Fact Sheet NO. 02
185
-------
Norfolk N**IB**
l**t\r> Air Fort* Bmi
Laafby Xtittrck Ctaur
18. Randall. P.M. Prototype Evaluation Initiatives in a New Jersey Vehicle Maintenance and Renair Farilfry
Proceedings of International Conferesice on Pollution Prevention: Clean Technologies and Clean Products,
Washington, D.C. June 1990.
19. Semiconductor Industry Association for the State of California Department of Health Services. Waste Genera-
lion and Disposition Practices and Currently Applied Waste MinimiMri/m Technimu* witffip. for
tor Industry. 1987.
20. Sudell, G.W., Enviresponse, Inc. for USEPA, Region X. Evaluation of the B.E.S.T.*
Sludge Treatment Technology Twenty-Four Hour Test
21. Thailand Development Research Institute Foundation, submitted to United Nations Environment Program.
Clean Technologies for the Paper and Pute Industry the Textile Industry, and the Metal Cnariny and Finishing
Industry in Thailand. 1986.
22. United Nations Economic and Social Counsel, Compendium on Low and Non-Waste Technology. PJantJbr
Processing Used Solvents.
23. USEPA, Risk Reduction Engineering Laboratory, Cincinnati. Waste
Audit Reort-
on Minimization of Solvent and Electmpty^g W«ffi|ffif «f a POP Installation. (EPA/600/S2-88/010)
24. USEPA, Risk Reduction Engineering Laboratory and California Department of Health Services Toxic Sub-
stance Control Division. Guide to Waste Minimizatinn in thg Phint Mannfiytiiring Indium/ (EPA>625/7 -90/005^
'23. USEPA, Hazardous Waste Engineering Research Laboratory, Office of Research and Development. Case
Minimization Of Solvent Waste from
1987. (EPA/60«ity>nt of Tnrtn«fri|| ffjMrrtji Wttttfi Practicftt
Paint and Allied PrQduCtt Industry. Contract Solvent Reclaiming QnenrioM and Factory Annlirarinn nf
Coatinfs. September 1975.
29. Vulliermci. B.. Vioeau. B.. and Gavend. G. The Chilians nf ICC an^t Colour Tnn^v Zem Stnrk l
and Zero Delay. Proceedings of IULTCS Conference. Philadelphia. 1989.
30. Waste Reduction Center for the Southeast, Ca« Summaries of Waste Reduction bv Industru* in
July 1989.
1 This laboratory it a predecessor of the Risk Reduction Engineering Laboratory in Cincinnati, Ohio.
For further Information on the T1PPP, ptoas* contact:
USEPA
Pollution Prevention Information Clearinghouse
Technical Information Service
c/o Science Applications International Corporation
7600-A Leesburg Pike
Falls Church, Virginia 22043
(703)821-4800
February 1992
Pollution Prevention Fact Sheet
186
No. 02
-------
Norfolk N**IB4*»
W>SA
f«M FortE*Mu
Issue: Laboratory Wastes
This Fact Sheet has been produced under the Tidewater Interagency Pollution Prevention Program
(TIPPP), a cooperative effort between EPA, DoD, and NASA to develop and demonstrate innovative
pollution prevention opportunities at Federal facilities.
Applications: Laboratory wastes may be generated by any operation that conducts chemical, engineering, lexico-
logical, biological, health-related, and/or any other types of research. Any type of scientific research may require
the use of hazardous chemicals and/or organisms. The chemical properties and quantities of laboratory waste
generated will depend on many variables, including the raw materials used, the nature of any chemical reactions, the
conditions of experiments, scale, physical changes in chemicals, etc. In most cases, laboratories will generate a
large variety of different wastes, usually in small quantities. These wastes are often generated on a one-time basis.
Although the number of source reduction and recycling options may be limited, such techniques may have broad
application to various classes of laboratory wastes.
Installation
Langley AFB
Norfolk Naval Base
Fort Eustis
NASA Langley Ctr
Estimated Volume of Waste Disposed
N/A
N/A
1,192 gal/yr
132 cyL exotic gasses; appr. 1000 gal lab wastes
Key Locations
N/A
N/A
BMg 576. 403. 409
many facilities on-site
Note: NJA: Not currently available or applicable
Environmental Coaceras: Laboratory wastes may pose a variety of hazards to both human health and the environ-
ment In the laboratory, wastes pose a threat to personnel who work with and near these toxins on a daily basis. Lab
wastes may also release toxic contaminants through various transport mechanisms (e,g. volatilization, leaching, etc.)
when discharged or disposed in the environment Such releases can contribute to the buildup of toxic materials in
the environment as well as impact human, wildlife, and flora recipients.
Due to the potential for variability, laboratory wastes present unique challenges for protective and environmentally
sound management. For example, laboratory wastes may pose different types of environmental risk because their
composition (and thus the threat posed) will depend entirely upon the nature of the research. Specifically, laboratory
wastes may contain mixtures of common organic solvents, exotic organic and organo-metaUic compounds, and/or
metal species (salts and complexes). In addition, laboratories may generate small quantities of numerous types of
wastes, or they may generate wastes on a one-time basis for a specific experiment. Such generation patterns may
complicate waste collection, disposal, and recycling possibilities.
Known Solution/References: Various options have been identified that may result in the reductionof waste associ-
ated with these types of operations. The following is a list of opticmdesCTibmgr^
some, or all of the operations discussed above. The references presented following each option describe, in detail,
applicable pollution prevention techniques, associated costs of implementation, and potential source reduction gains.
Inventory Management - Optimizing the use of supplies on hand, including control of dispensed chemicals and
checking for outdating of solvents and other chemicals.
References: 1.2,3,4,5,6
February 1992
Pollution Prevention Fact Sheet
No. 03
-------
NASA
F on Etuis
OK Dm* Of FT
Product Substitution - Replacing hazardous materials with less toxic or hazardous substances.
References: 13,4,6
Experiment Design - Improving current research practices and to increase the efficiency of experiments to decrease
waste generation. For example, laboratory experiments could be conducted on a smaller scale using smaller
quantities of raw materials.
References: 1,3,4,5,6
Recycling/Reuse/Recovery - Using methods to promote reuse of materials, such as recovery of solvents using such
techniques as distillation and/or metals extraction (in particular, silver and mercury).
References: 13,4,5,6
Volume Reduction - Reducing hazardous waste volumes by utilizing methods such as neutralization precipitation
and inacuvanon.
References: 13,4,5,6
Energy Recovery - Recovering energy, primarily from waste solvents in the form of fuel supplements.
References: 13.4,5
Waste Segregation - Separating waste streams to facilitate treatmentAlisposaL
References:
Reference!
1. American Chemkal Society, Department of Govenunent Relatk»s aiid Science I\>lky, Task Force on ROU
The Waste Maqyfrgej^njManuaJffgT^MyMnrvPermnnel Ann] 1990
2. Chemical Manufacturers Association. CMA Witt! Minimi7**"*1 ^Tf^Tr MffllMi 1989.
3. Feild, Rosaline A., Manaranmt Strategies and Technology far tte Minimir.,™ nf rtpnical w«t^ *™
Laboratflna. Duke University Medical Center, Division of Environmental Safety. September 1986.
4. North CarouMr*pnrtn»emrYC^fn'***!Waiitfst Seotemher 1986
5. NormCaroliMDepatinenirfEnvu^
Waste MapigeflMnt Strategist fpf Hoanitalt and ninirai Labonmies. 1987
6. USEPA,Ri*F^dnctkjnEngmeefiiigLaboMiory,a^
r"liHM •» ftfritfm Prnrntinn-1^^^^ "»«^i w«««> ^^. jme 1990. (EPA^25/7-9(voio)
7. USEPA.Ri*R«tacti«EngraeerrngLab(>ratory,^ Hospital PbUution Prevention Case Study
(EPA/60(VS2-91y024) ''
For further Information on the T1PPP, please contact:
USEPA
Pollution Prevention Information Clearinghouse
Technical Information Service
c/o Science Applications International Corporation
7600-A Leesburg Pike
Falls Church. Virginia 22043
(703)821-4800
February 1992
188
Pollution Prevention Fact Sheet
No. 03
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NASA
ftrf&Mit
Issue: Solvents (Halogenoted and Non-halogenated)
This Fact Sheet has been produced under the Tidewater Interagency Pollution Prevention Program
(T1PPP), a cooperative effort between EPA, DoD, and NASA to develop and demonstrate innovative
pollution prevention opportunities at Federal facilities.
Applications: Both hatogenated and non-halogenated organic solvents are used in a variety of operations at each of
the participating installations. Specifically, solvents are used in the following operation*
parts cleaning and stripping
degreasing
gluing
painting and coating
fiberglass repair
printing
dry cleaning
equipment maintenance
pesticide/fertilizer formulation
These operations can rely upon both hatogenated and non-halogenaied organic solvents and solvent mixtures that
contain such toxic constituents as benzene, toluene, methyl ethyl ketone, isobotyl ketone, perchloroethylene,
methylene chloride, 1,1,1 -trichloroethane, and others.
Installation
LangieyAFB
Norfolk Naval Base
Fort Eustis
NASALangteyCtr
Estimated Volume of Waste Disposed
Safety Kken
Others
4.810 gal/yr
4.735 gaJ/yr
2,400 Ibs/yr
63.1 14 Ibs/yr
U10.51bs/yr
Key Locations
Vetrick Maintenance,
Corrosion Control
Paint Shop, A/C Maintenance
Shops 961. 962, 993
Bldg. 141 1. 2413. 2750 and others
Various locations
Environmental Concern: Organic solvents may possess hazardous characteristics including flammabUity, toxic-
ity. and carcaaotjeflkity. They are often volatile, and thus create potential for refcase into the air and the surrounding
area. Solvents create health hazards for workers in addition ID a poteritial for industrial accidents due to the
solvent's capability to ignite. When used in any of the applications listed above, solvents can also pose a threat to
human health and die environment when discharged in water or tend.
Known Solutions/References: Various options have been identified mat may result in ne reduction of waste
associated with these typesof operations. The following is a list of options describing prevention techniques that
apply to one, some, or all of the operations discussed above. The references presented following each option
describe, in detail, applicable pollution prevention techniques, associated costs of implementation, and potential
source reduction gains.
February 1992
Pollution Prevention Fact Sheet
189
No. 04
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Norfolk N**lt*m LMffay Air f*»*<•» fort EMM Uu^tfyHttttrtkCtMtr
NASA &EFA
Substitution - Involves the substitution of a substance which is either less hazardous or produces a waste that is
less hazardous, but which does not jeopardize equivalent product quality. For example, the replacement of benzene
with aliphatic naphthas.
References: 2,3.5,6,10,15,20,21,22.24
Reformulation • Changing the product to reduce the volume or toxicity of the wastes produced. This may involve
altering or lowering certain product specifications (i.e., concentration), changing the chemical composition, or
changing the physical state.
References: 0,17
Process Redesign/Equipment Modification - Includes the alteration of the existing process designs to include new
equipment ande implementation of new technologies or changes in operating practices to reduce waste generation
(i.e., use of condensers to capture solvent emissions).
References: 2^,5,9,12,15,20,24
Housekeeping Changes/Process Control • Careful monitoring of the use of solvents for product production and
evaluation of current spill avoidance procedures can reduce solvent use.
References: 23,5,8,9,10,12,19,20
Segregation - Separation of solvent waste streams from other solvent and non-solvent waste streams. Utilization of
water can aid in recycling efforts and reduce the amount of solvent-bearing wastts. Segregation is particularly
important for halogenaied solvent wastes.
References: 5.8,20
Minimization- Standardization and consolidation of solvent use. For example, many solvents can be used for
more than one application. Further, solvents may be reused in the same application or in other applications. Such
reuse may result in solvent usage reductions.
Reference: 5
Heat Recovery - Noo-haJogenaied spent solvents may be used as supplementary fuels particularly in high-tempera-
ture industrial processes such as industrial boilers, rotary kilns and blast furnaces.
References: 2,10.16.20
Recycling/Reuse/Rccovery - Regularly used solvents may be recovered from waste streams by use of techniques
such as distillation, evaporation or steam stripping. Once recovered, solvents may be reused or recycled for indus-
trial processes.
References: 1,2,4,5,7.10,11,13,14,16,18.20,24
References
1. BrenL S_ A Workbook: BoflnrioB Prevention hv Source R^uction Bl TflltiJC Wet
North Carolina. 1988.
2. Energy Pathways, Inc. and Pollution Probe Foundation for Eimromnent
-------
NASA
Abbott AfeM/f«w Unffc?A«r'"Br*«tt fortCwM LMf^r XMMTC* CMMT OKD txd
5. Hazardous Waste Reduction Program of Oregon, Department of Environmental Quality. Guidelines
Reduction and Recycling - Solvents. 1989.
6. Huisingh, D., et al. for The Institute for Self Reliance, Washington, D.C. Proven Profit from Pollution Preven.
tion. 1983.
7. Industrial Finishing. "Solvent Recovery Beneficial for Haworth". November 1983.
8. Minnesota Office of Waste Management, MnTAP Program. Success Storv- Solvent Management Printing
Press. 1988.
9. Minnesota Office of Waste Management, MnTAP Program, fact Sheet - Reducing Solvent From Vane*
1990.
10. North Carolina Department of Environment, Health, and Natural Resources. Pollution Prevention
and Recycling Solvents in the Furniture Industry. 1986.
1 1 . North Carolina Department of Environment, Health and Natural Resources, Pollution Prevention Program.
Pollution Prevention TIM - Small Solvent RccovtfY SY8ttM 1987.
12. North Carolina Department of Environment, Health and Natural Resources, Pollution Prevention Program.
Pollution Prevention Tips - Solvejny Lp*i1 Control • Thinp You Can Do Now. 1989.
13. O-jni«nnHiirinr TnAnttrv Aonciarion for the Stale of CaKfemia Demrtmgnt of Health .Vrviraa
tion and Disposition Practices and Currenriv Applied Waste Muiimttarion TcchflJflUO WJtfl'n "
tor Industry. 1987.
14. Sudell, G.W.. Enviresponse, Inc. for USEPA, Region X. Evaluation nf fa B.pJjj.T.™ Solvent Extraction
Sludge Treapngnt Technology Twenty-Font Hoar Test.
15. Thailand Development Research Institute Foundation, submitted to United Nations Environment Program.
ner »*l Puln Industry, the Texrite Indian ». »id the Met^ ^^ * F»ni«hi
Industry in Thailand. 1986.
16. United Nations Economic and Social Counsel, Compendium on Low and Noil- Waste Techrwtogy.
Processing Used Solvena .
17. U.S. Department of Energy, Office of Technolofy DeveJopmeoi, En v»onnie«al Restoration and Waste
Management, Fi«t Annual IntefnatioMl Wortahoo on Solwnt SiirHritntina. Phoenix, December 1990.
18. USFPA. F«f^ Rfductiffli P«g»i^*ring IJ«hnrMoryT Cintannaii. W^sjB_Mjnjn3JatJpn_Ajy'i of S
-------
NASA 4>EPA
23. VuJUoin* B.. VuteauJJ.. and 1 Gavcnd , a TTie Challenge nf TOT rh.^, r»^ m^^y 7^« Q^ ,
and Zero Delay Proceedings of IULTCS Conference, Philadelphia. 1989. — -™- "•""•
11"* Cenier for *" souihcisL CMB *"•""*• ^ w^ R^.^^ K. Tnft,l
ff1
For further Information on the T1PPP, please contact:
USEPA
Pollution Prevention Information CJearinghouse
Technical Information Service
c/o Science Appteattons International Corporation
7600-ALeesburgPlce
Fate Church. Virginia 22043
(703)821^4800
February 1992
Pollution Prevention Fact Sheet
192
No. 04
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LfKftfy Air Font tan
NASA &EPA
OXDmdOPFT
Issue: Electroplating
This Fact Sheet has been produced under the Tidewater Interagency Pollution Prevention Program
(TIPPP), a cooperative effort between EPA, DoD, and NASA to develop and demonstrate innovative
pollution prevention opportunities at Federal facilities.
Applications: Electroplating is the formation of a thin surface coating of one metal upon another by electrodeposi-
tion. Ferrous or nonferrous materials may be coated by a variety of common (copper, nickel, lead, chromium, brass,
bronze, zinc, tin, cadmium, iron, aluminum or combinations thereof) or precious (gold, silver, platinum, osmium,
indium, palladium, rhodium, indium, ruthenium, or combinations thereof) metals. In electroplating, metal ions
supplied by the dissolution of metal from anodes or other pieces are reduced onto the workpkces (cathodes).
Depending on the metals involved, electroplating cells may use acidic, alkaline, or neutral solutions. Plating
processes may be used to produce a variety of surface effects. In general, electroplating is used to produce:
• protective coatings on metal or plastic objects,
• surfaces that perform or act in specific ways under the conditions of use, and
• decorative finishes.
Electroplating operations are common to various military maintenance and parts manufacturing operations.
Installation
Langley AFB
Norfolk Naval Base
Fort Eustis
NASA Langley Ctr
Estimated Volume of Waste Disposed
N/A
Electroplating Solution
Electroplating (Misc.)
Hydrochloric Acid
Phosphoric Acid
Nitric Acid
Potassium Hydroxide
Sodium Hydroxide
7,455 Ibs/yr
1,175 Ibs/yT
1,635 Ibs/yT
1,065 Ibs/yr
1,630 Ibft/yr
4,780 Ibs/yr
2,480 Ibs/yr
N/A
N/A
Key Locations
N/A
BMg. 932, 971, 972, 973
N/A
N/A
Note: NIA * Not currently available/applicable
Environmental Concerns: The majority of metals and cyanide discharged into the Nation's waterways comes from
metal finishing facilities, primarily from electroplating processes. Electroplating operations can result in solid and
liquid wastestreams that contain the chemicals of concern. Liquid wastes result from workpiece rinsing and process
cleanup waters. In general, most surface finishing (and many surface preparation) operations contribute to liquid
wastestreams. Centralized wastewater treatment systems are common to this industry and can result in solid-phase
wastewater treatment sludges. In addition to these wastes, spent process solutions and quench baths are discarded
periodically when the concentration of contaminants inhibits proper function of the solution or bath. When dis-
carded, process baths usually consist of solid- and liquid-phase wastes that may contain high concentrations of the
constituents of concern, especially cyanide (free and complexed).
February 1992
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NASA &EPA
Hexavalent chromium plating systems, frequently used for electroplating, are hazardous. Similarly, cyanide plating
baths are a known environmental hazard. Hazardous sludges, spent process baths, backwash from plating tank filter
systems, and stripping solutions produced from the electroplating process commonly contain heavy metals and
cyanide and consequently pose potentially serious human health and environmental hazards through soil and
groundwater contamination.
Known Solutions/References: Various options have been identified that may result in the reduction of waste
associated withthese types ofoperations. ThefoUowing is a list of options describing prevention techniques that
apply to one, some, or all of the operations discussed above. The references presented following each option
describe, in detail applicable pollution prevention techniques, associated costs of implementation, and potential
source reduction gains. ^^
Training and Supervision - Educate plating shop personnel in the conservation of water during processing and
material segregation. *
References: 3.7,8,10,11,12
Production Planning and Sequencing - Pre-inspect parts to prevent processing of obvious rejects
References: 10,11 ^^*
Process or Equipment ModifkatioM
Employ counter-current rinsing to greatly reduce rinse water usage.
References: 10,11
Increase drain time to allow parts to drain 10 seconds or more after removal from bath.
References: 3,6,8,9.10,11,12
Add wetting agents to the plating baths to reduce solution adhesion to the parts.
Reference: 10
Increase bath temperature to reduce viscosity and improve drainage.
References: 10.11
Use spray rinsing to increase rinsing efficiency for non-complex pan configurations.
Reference: 10
Use air agitation in rinse tanks to improve rinsing efficiency.
Reference: 10
Change continuous treatment 10 a batch system to account for upsets in effluent levels.
References: 10,11
Reduce ban evaporation by covering the surface with non-reactive gases or materials. For example, a blanket
of polypropylene balls can be used to significantly reduce losses through evaporation.
References: 3,8,10.12
Continuously filter process baths to extend their life.
References: 10,11
If etching is done only to put a shine on the parts, some customers may agree to buy them uneiched, thus,
greatly reducing etch bath wastes.
Reference: 10
Use low concentration plating solutions rather than mid-point concentrations in order to reduce the total mass of
chemicals being dragged out
References: 3,4,10,11.12
February 1992 Pollution Prevention Fact Sheet No. 05
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Norfolk N*nUB*M
NASA &EPA
FonEtuii
Use the Kushner and Providence methods of double dragout, followed by treating or recycling the concentrated
dragout solution to minimize rinsewater use.
References: 10,11
Use electrolytic cells to recover metals from waste plating solutions. Applicable to recovery of gold, silver,
cobalt, nickel, cadmium, copper, and zinc from solutions with 100 mg/1 to 1,000 mg/1 of metal.
References: 1,3,5,9,10,11,12
Substitutions • Use less toxic materials whenever possible. Examples include:
• Substitute zinc for cadmium in alkali/saline environments.
• Substitute nitric or hydrochloric acid for cyanide in certain plating baths in order to produce a less
hazardous sludge.
• Substitute zinc chloride for zinc cyanide.
• Substitute a non-chlorinated stripper in place of methytene chloride.
• Replace hexavalent with thvalent chromium plating systems.
• Replace cyanide with non-cyanide plating baths.
References: 1,2,3,4,8,9,10,11,12
Waste Segregation and Separation - Wastewaters containing recoverable metals should be segregated from other
wastewater streams.
References: 1,4,10,11
Recycling
Use any combination of the following techniques to recycle materials:
• evaporation * reverse osmosis
• ion exchange • electrolysis
• chemical reaction • reclamation
References: 1,2,3.4,5,6,7,8,9,10,11,12
Specific recycling opportunities include:
Process chemicals 9
Regeneration of caustic etch solutions 11
Use of acid copper in the electroplating of plastics 10
Recover spent chromatic acid from anodizing 1
Filler and reconstitute plating baths instead of disposing of the bath when strength has decreased 10.11
References:
1.
cal Conf
American Hectroolaiers' Society 67th Annual Techni-
Milwaukee, WL, June 22-26, 1980.
2 Brown. Craig J. Begeneffrinn nf CflUffitif S
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NASA
fan Em*
6. North Carolina Department of Natural Resources and Community Development, Pollution Prevention Pays
Program- Water Conservation for Electropiaters; Counter-Currem Riminy 1985.
7. North Carolina Department of Natural Resources and Community Development, Pollution Prevention Pays
Program. Water Conservation for Electron!**™- Pi?T ^Vaier Reuse 1985.
8. Saltzberg. Edwant SAIC. Methoda To Minimize Wastes From the Electroplating Industry Symposium on
Waste Minimization Practices. Sacramento, CA. 1987.
For further information on the T1PPP, please contact:
USEPA
Pollution Prevention Information Clearinghouse
Technical Information Service
c/o Science Applications International Corporation
7600-A Leesburg Pike
Falls Church. Virginia 22043
(703)821-4800
February 1992
Pollution Prevention Fact Sheet
196
No. 05
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NASA «EPA
Port Emit
Issue: Depainting Operations
This Fact Sheet has been produced under the Tidewater Interagency Pollution Prevention Program
(TIPPP), a cooperative effort between EPA, DoD, and NASA to develop and demonstrate innovative
pollution prevention opportunities at Federal facilities.
Applications: All of the participating installations conduct depainting operations. These operations are conducted
in a variety of ways, from small "spot" removal operations to large blast media operations. Specifically, depainting
operations occur while preparing equipment for repainting. Depainting processes used by the installations include
stripping baths, beaded blast media, and spot removal using solvents. Types of equipment needing paint removal
include:
• trucks • aircraft carriers • aircraft • jeeps
• gun turrents • signs • tanks • trailors
Installation
Langkj AFB
Naval Base
Norfolk
FtEustis
NASA-
Langtey Ceater
Estimated Volume of Waste Disposed
Blasting Grit
Blasting Grit
Stripper
Sand Blast Residue
Stripper
Thinner
Solvent/Thinner
Paint Remover
1^-dkAtoro-tetrifluorocthane
Solvent/Paint Waste
1,1.1-trichloroethane
Thinner Dope
Thinner/Degreaser
Ciuorobnezene
Dichkvomethane
Spent Solvents
Paint Stripper
Idrum/yr
133,600 Ibs/yr
3.325 tbs/yr
2,850 Ibs/yr
4,000 Ibs/yr
32300 Ibs/yr
950 Ibs/yr
91.400 Ibs/yr
3001bf/yr
300 Ibs/yr
1300 Ibs/yr
562,600 Ibs/yr
6,195 Ibs/yr*
23*al/yr
5gal/yr
lOgal/yr
1 lecture bt/yr
220gal/yr
58gal/yr
15gal/yr
495gal/yr
5pints/yr
4ptnts/yr
326gal/yr
57gal/yr
Key Locations
BWg. 781
Shop 932
Shop 936
Shop 941
Shop 963
Shop 971
Shop 972
Shop 973
Bldg. 1411
N/A
* These numbers, based on 1991 figures, are not typical due to Operation Desert Storm.
February 1992
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NASA
Environmental Concerns: Dcpainting operations result in the generation of metal-based paint. Wasting grit, and
paint sludge wastes which pose a threat to human health and the environment Paint, which may contain high levels
of heavy metals including lead, cadmium, mercury, chromium, copper, and titanium can cause significant damage to
human health as well as contaminate potable water sources (ground and surface waten). Departing oarauofiTmay
also include the use of chlorinated solvents which create solvent- and paint-bearing sludges as well asrclease
volatile organic compounds to the air creating health and safety hazards for the workers.
Known Solutions/References: Various options have been identified that may result in the reduction of waste associ
atedwim these types of operations. ThefoltowiiigUalistoforxionsdescrib^
some,orall of the operations discussed above. The references presented following each option describe, in detail,
applicable pollution prevention techniques, associated <»sts of implemeiit^
Fluidized Bed Unit: Uses heated bed of fluidized aluminum oxide to remove paint The process reduces reliance on
chemical stripping.
Reference: 1
Increasing Solution Life: Extends life span of paint stripping bath, thus minimizing use of chemical striroinff
References: 1,2, 8, 9
Substitution: Replace less toxic cleaning media for solvents. For example, media substitution will often require a
switch from vapor degreasing to cold tank cleaning.
Reference: 2, 3, 5, 7, 10
Aqueous Cleaners: The cleaning action of aqueous cleaners relies mainly on displacement of soils. Water can be
used in conjunction with mechanical or ultrasonic agitation.
Reference: 8, 9
Emulsion Cleaners: Combine solvent cleaning with aqueous cleaning so the solvent is dispersed in the aqueous
phase with the aid of emulsifiers, surfactants, and coupling agents,
References: 8, 9
Mechanical/Thermal Methods: Alternatives include air blast systems, abrasive blast cleaning and dry striDoinff
These are effective m elinunating the need for solvents.
References: 1,8,9
Recycling and Reuse: Overall solvent consumption can be reduced by segregating solvent wastes for recycling or
References: 6, ft. 9
Reference!
1. Bartell, R., Mahannah. J.. and Dene. M. The Amw'« Ha^m^ WM* Minimi^^ pmyram
International Conference on Pollution Prevention: Ckan Technologies and Clean Products. June
3. Hayes, ME. Naturally Derived Biodegradable Cleaning A«ni*
jQivents.
4 "jgg11"- T'£- Industrial ProCCSS Modification tn Reduce Generation of H»«rtnfl« Waste at DnH f yj||^
Ptiasc I RCMri. Prepared for the DoD Environmental Leadership Project Office and U.S. Army Corps of
€ngineers by CH2M Hill, Washington, D.C, February 198«.
February 1992
No.
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NASA 4>EPA
FortEnMit
5.
6.
7.
8.
Hughes, T.H., K.E. Brooks, B.W. Norris, B.M. Wilson, and B.N. Roche. A Descriptive Survey of Related
Organic Solvents. University of Alabama, Tucaloosa, Alabama, August 1985.
Schwatz, S.I. Recycling of Hazardous Solvents: Economic and Policy Aspects. Solvent Waste Reduction
Alternatives Symposia Conference Proceedings. Los Angeles, CA. Sponsored by California Department of
Health Services.
U.S. Department of Energy, Office of Technology Development, Environmental Restoration and Waste
Management, First Anflujgj fnfejnarinn^l Wfyfojfrop OP Solvent Substitution. Phoenix, December 1990.
USEPA, Risk Reduction Engineering Laboratory, Office of Research and Development, Cincinnati. Guides to
Pollution Prevention: The Fabricated Metal Pro^yff Industry July 1990. (EPA/625/7-90/006)
9. USEPA, Office of Solid Waste and Emergency Response. Waste Minimization in Metals Parts Cleaning.
August 1989.
10. Waste Reduction Center for the Southeast Case Summarily of Waste Reduction bv Industries in the
July 1989.
For further information on the T1PPP, please contact:
USEPA
Pollution Prevention Information Clearinghouse
Technical Information Service
c/o Science Applications International Corporation
7600-A leesburg Pike
Fans Church. Virginia 22043
(703)821-4800
February 1992
Pollution Prevention Fact Sheet
199
No. 06
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NASA &EPA
Issue: Municipal Solid Waste
This Fact Sheet has been produced under the Tidewater Interagency Pollution Prevention Program
(TIPPP), a cooperative effort between EPA, DoD, and NASA to develop and demonstrate innovative
pollution prevention opportunities at Federal facilities.
Applications: Integrated solid waste management involves using a combination of techniques and programs to
manage the municipal and industrial solid waste stream. This is based on the fact that the waste stream consists of
distinct components that can be managed and disposed of separately. Source reduction, recycling, combustion and
Installation
LangleyAFB
Naval Base
Norfolk
FortEustai
SfASA-
Langley Center
Estimated
Volume of Waste Disposed
Scrap Metal
Tool Boxes
Tires
1340,160 Ibs/yr
7,260 Ibs/yr
5,060 Ibs/yr
Non-regulated Waae 19 1,264 !b«/yr
Trash
Post
Housing
NHRoto
WTP/Roto
Metal
Rubber
392.700.000 Ibs/yr
^963.261 foa/vr
3^85360 ftt/yr
663.190 fct/yr
330.400 Ibs/yr
2^gO Ibs/yr
Estimated Volume of Materials Recycled
Scrap Metal
Wood
Copper
Textile
Brass
Petroleum
Aluminum Cans
Stainless Sled
Scrap Metal
Wood
Copper
Brass
Aluminum Cans
Stainless Sled
Paper
Glass
Sled
Cardboard
Plastic
AAmunuBi
Paint Solvents
Tow
High Temperature ADovs
Scrap Metal
Alum mum Cans
Glass
Used Oil
Scrap Metal
Computer Paper
400,000 Ibs/yr
14*400 Ibs/yr
126^000 Ibs/yr
80JOOO Ibs/yr
60,000 Ibsyyr
20,000 lb%y
20,000 Ibs/yr
10,000 Ibs/yr
2£78tons/yr
4.038 lons/yr
32 tons/XT
IStons/yr
2tons/yr
35tons^r
6 tons/yr
4t809tons/Vr
1,750 tons/yr
15tonsyyr
160 tons/yr
23 tons/yr
26 tons/yr
2tons/yr
1^14,000 Ibs/yr
27j0001bsyyr
93^400 tt«^r
67JOOO Ibs/yr
6JOOoal/Vr
303.010 Ibs/yr
125.460 Ibs/yr
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No, 07
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NASA «EPA
Norfolk N*»4I»M l**tl*y Air Fort* Bmi ForiE** L**
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U^Uy Air Fore. B»
PonE*i*
NASA
LatfUy *«,««* C.-Ur
OKD^OFfT
References
1- America Recycles: AnOvyryj^ GSD&M. November 8,1989.
2. Belluck. David A.. Beniamin S*l1v I Compreheasive Crroundw^r Upnimrimr Fnr Fnm^frfnl Pntiri
>raoAn»a/l a» »iw» ACTC\lr»*/~v t n/vn »i .- . ^ ......
4
7.
kee, Wisconsin. July 16-18,1990.
3. Charnews. Raymond G._ R Solid WM Mm? r
For further Information on the TIPPP, please contact:
USEPA
Pollution Prevention Information Clearinghouse
Technical Information Service
c/o Science Applications International Corporation
7600-A Leesburg Pike
Falls Church, Virginia 22043
(703)821-4800
February 1992
Pollution Prevention Fact Sheet
202
No. 07
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NASA &EPA
OKDiHtOPPT
Issue: Land Management Practices
This Fact Sheet has been produced under the Tidewater Interagency Pollution Prevention Program
(TIPPP), a cooperative effort between EPA, DoD, and NASA to develop and demonstrate innovative
pollution prevention opportunities at Federal facilities.
Applications: Land management practices are an effective way to reduce the amount of nonpoint source nutrient, sediment,
and toxic pollutants from entering the Chesapeake Bay ecosystem. Land management practices are applicable to different
types of land use including:
fanning
construction
silviculture
dredge material disposal
road construction
runways & flightlines
golf courses
pest and weed control areas
housing areas
Environmental Concerns: The Chesapeake, Bay system is plagued by poor water quality, declining fish and wildlife
resources, and degraded ecologically sensitive areas such as wetlands. The exact causes of these problems are not completely
understood, but it is clear that changes in the Chesapeake Bay ecosystem are directly linked to increased nutrient loadings.
Land management practices significantly influence nonpoint source pollution and stormwater runoff— the major sources of
nutrients and a significant source of sediment, and toxic pollutants to the Chesapeake Bay system. Nonpoint source pollution
is pollution from diffuse sources, such as runoff from the land, that carrying natural and manmade pollutants. Nutrient over-
enrichment contributes significantly to an array of interrelated problems in the Chesapeake Bay ecosystem, including:
• algal blooms and eutrophication,
• decreased dissolved oxygen levels throughout the Bay,
• decline in Baywide abundance of submerged aquatic vegetation, and
• decline in the abundance of fish and waierfowl.
Toxic pollutants in urban runoff (e.g., metals, pesticides, oil and grease) also negatively impact the Bay's fish and wildlife
resources, and water quality. Stormwater enters the Bay either directly through stormdrains or indirectly through tributaries
so it is important to prevent pollutants from contaminating stormwater. The four installations participating in the TIPPP all
border on, or contribute runoff to, tributaries that ultimately drain into the Chesapeake Bay. While the exact impact of these
installations on the Chesapeake Bay is unclear, the general effect of such communities can be detrimental and may include
loss of vegetation and sensitive wetlands, the alteration of natural drainage patterns, and hydrologic changes to streams and
waterways.
Nutrient
Phosphorus
Nitrogen
Land Use
Nonpoint source
Point Sources (sewage treatment plants)
Nonpoint Source
Point Sources (sewage treatment plants)
Percentage
68%
32%
82%
18%
February 1992
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No. 08
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ld SlUdy "d "*« ** ™™nmemal impacts of
land management prances and daily operations on surrounding rivers and the Chesapeake Bay SpecificallV-nPPP
is envisioned to investigate the following types of operations: ^ ^P^uicauy, i urr
FlJghtUncs and Runway Management: IT* largest potential source of contaminants to stormwater from
flightlines and runways are fueling operations, vehicle maintenance/washing, and deicing practices. Best manaae-
mem practices for fuel operations strive to eliminate fuel coming into direct contact with stormwater runoffbT
managing fuel spills covering chemical storage areas from the rain, and collecting and treating contaminated
stormwater runoff Vehicle maintenance/washing best management practices prevent washwater from flowin*
directly rnto stormdrains, streams or waterbodies; use tow phosphorus content detergents or cleaning agents and
prevent and control spiUs of vehicle fluids (e.g.. oil, radiator coolant). Best manageLnt practices foriicL^gents
have the goal of using the least environmentally disruptive deicing agent; applying deicing chemicals to only those
areas requiring deicing; and evaluating storage, application, and excess deicing chemical management operationTto
minimize the contamination of stormwater and environmental damage. Deicing is less of an isL to TTPPP due to
relatively mild winters in the Tidewater area.
Reference: 9
Erosion and Sediment Control: Best management practices involve structural and nonstructural practices to limit
the amount of soil erosion and prevent sediment from entering the water. This includes preventingErosion bv
avoiding activities on steep slopes or areas with highly ercxiible soib, ami limiting the ^
impervious surface area. Establishing and marntainrng r*«niu* vegetatwe ^
on vacant land, steep slopes, and around wetlands and waterbodies; planting critical e^
vegetation^ving undisturbed vegetative buffer strips adjacent to streams, wetlands and waterbodies. Minimizing
sod loss from the field, development site or roadway by planting a cover of grass or spreading straw to maintain soil
cover. Constructing terraces and grassed waterways to limit erosion from charnielizewater flow Constructing
stnjcurcstofetarnsedimemtosssuchassedm^^ ' *
References: 3,7,8,9
i^fi!^! J^T T" *!***** ?** a «*«*» of practices that limit the amount of nutrients applied to and
lost from the turf. It involves collecting information to determine the soil's nutrient concentration and die
vegetation's nutrient requirements prior to fertilization and «Uy ar^ymg the miiumimi a^
Practices include the proper rale of fertilizer application and optimiim ti^^ *
loss of fertilizers to runoff. It also includes investigating organic alternatives to chemical fertilizers such as waste-
water, sewage sludge, or compost
References: 3, 7,9
Pesticide Manatement: The most effective approach to reducing environmental impact of pesticides is to use less
pesaadei Only use pesticides when there is a net economic gain, ^ when a pest population^ approachinTthe
level at wh*h coatrol measures are necessary to prevent a decline in net returns. Wn«^ia^re;«»ssar7
select the pesticide wim me least toxicity, teachability, persistence, and volatility that will still do the job Apply
pesticides in such a way as to minimize their movement into water or wetlands and exposure to workers and
nontarget wildlife such as birds. Avoid spraying on windy days or right before a rain, do not spray directly onto
waterbodies or wetlands. Many pesticides bind to soil and clay particles. Practices that reducTsoU erosion are also
enective at retainm? rw>«tinH^« nn »K« »«M»^I ,>_... ^^
effective at retaining pesticides on the treated area.
References: 3,4,6,7,9
February 1992 Pollution Prevention Fact Sheet
No. 08
204
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NASA
Norfolk Nm^iB^t U*ii*y Air font §** FonEmlu LaaflfyKtMrnnkCtnur ORDmrtOPFT
Forestry Management Practkes: The goal of forestry best management practices is to plan, design, and operate
logging and silviculture practices to minimize erosion, pesticide use, hydrologic disruption to streams, wetlands and
other waterbodies. This involves designating special management areas immediately adjacent to streams, wetlands
or waterbodies where road building, logging, and related activities are prohibited. Building roads so as to minimize
disturbances, controlling erosion near streams, and investigating alternatives to widespread pesticide use.
References: 3,7,9
Road Construction and Maintenance: The goal is to build and maintain roads in a manner that causes minimum
erosion and disturbance to streams, wetlands, and environmentally sensitive areas. Locate roads away from wet-
lands, critical habitat areas and drainage channels. Minimize cut and fill Size road culverts at waterbody crossings
to minimize hydrologic disturbances such as restricting tidal flow to a wetland. Limit the amount of bare earth
exposed to erosive forces, and the amount of natural vegetation that is disturbed. Prevent direct runoff of
stormwater from roadways into wetlands, streams and waterbodies. Consider sweeping and vacuuming road
surfaces to remove accumulated dust, debris and pollutants. Consider mowing more frequently and using spot
application of herbicides versus large scale herbicide application. Evaluate cement sealers used on non-asphalt
surfaces to find the least environmental harmful sealer.
References: 3,7,9,13
Urban Runoff in Developing Areas: Institute practices that maintain natural hydrology at both the watershed and
site levels by minimizing impervious surface areas, protecting natural vegetation, and training natural drainageways
to the maximum extent possible. Minimize disturbances of unstable areas by locating development away from
critical areas such as steep slopes, highly credible soils, and wetlands. Protect natural resources which contribute to
beneficial water quality impacts such as wetlands, forest areas, and riparian areas. Where possible retain buffer
areas of natural vegetation contiguous to these resources.
References: 3,7,9,10,11
Housing Areas: Undertake practices that reduce lawn care nutrient and pesticide use, and manage pet wastes.
Consider using alternatives to commercial fertilizers such as compost If commercial fertilizers are used never
exceed the recommended application rates. Over fertilizing results in a higher percentage of nutrients leaving the
lawn as runoff. Consider alternatives to widespread pesticide use such as mechanical weeding. If pesticides are
required use organic pesticides versus synthetic chemical pesticides, and use spot applications of pesticides versus
broad application. Collect and compost grass clippings, leaves, branches and other yard waste. Manage pet waste to
prevent it from directly entering storm drains or water bodies.
References: 3,7,9
Wetland and Riparian Area Protection: Preserving wetlands and riparian areas is vital to the Chesapeake Bay's
survival Wetlands function as a natural filter and regulator of nutrients and sediments entering the Bay, as nesting
and nursery areai for fish and wildlife, as flood control structures, and home to a multitude of creatures. The best
way to protect wetlands is to leave them undisturbed. Avoid any impacts to wetlands such as building, dredging,
draining, or other activity, that changes the hydrologic conditions or directly disturbs a wetland. Riparian areas are
uplands or floodplain areas immediately adjacent to wetlands, streams, rivers or other waterbodies. Riparian areas
perform similar functions as wetlands. Minimize all disturbances in riparian zones. Loss of riparian zones allows
nonpoint source runoff to directly enter the wetland or waterbody. When conditions are appropriate, restore
wetlands and riparian areas instead of building structural nonpoint source management measures. Restore the
natural hydrology (e.g., drainage patterns) and native plants in riparian areas when possible.
References: 1.2,3,5,7,9,12
February 1992 Pollution Prevention Fact Sheet NO. 08
205
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Norfolk N»~li~.
L~tliyMrr*n»i*.
FortEii*
NASA
Laxity AMMHT* C.*,r
References
1. Broome, S.W Seneca, E.D., and I Woodhouse Jr., W.W. Planting Marsh On*** for Err*™ c™^
Sea Grant College Publication, 1981.
2' ^l^/^-i^y1; V"" Sheridan; ^Managing riparian mrottim rn ronrml nonpoim mllnrinn.
Journal of Soil and Water Conservation, 1985.
3. Metropolitan Washington Council of Governments. Controlling I Jrhan Runoff: A Pn^i M«n.H fnr ?]m_
nine and Designing Urban BMPS. Washington, D.C., 1987.
4. National Research Council, Board of Agriculture. Alternative agriculture National Academy Press Washing
ton, D.C, 1989. ' *
5 New York State Department of Environmental Conservation. Stream Corridor Management: A Basir gofer.
ence Manual Albany, NY, 1986.
nQ^^ TY
7. Novotny, V., and Chesters, G. Handbook of Nonnoint Pnllnrim Sources and Manaf -nw^ New York, Von
Norstrond Reinhokt 1981.
8. U.S. Department of Agriculture, Agricultural Stabilization and Conservation Service. Practice names
used bv USDA-ASrs Washington, D.C., 1989. -.—
9. USEPA, Office Of Water. PrQDQSed Guidance Sncrifving Mana^nv.nt MCZSM* f»r Sn.TCes of Nonn
Pollution in Coastfll Watery Draft, Washington, D.C., May 1991.
10. USEPA. Urban Runoff and SrnrmwatffT MflnflfPment Handbook. Oiicagn 1990
1 1. USEPA, Urban Targeting and BMP Selection Chicago, 1990.
12. USEPA, Office of Water. Best Managcmeni Practices Giiidanc^. Dischame nf n^ged or F.H M^^
-™~
Washington, D.C, 1979. (EPA/440/3-79/028)
13. VirgmiaE^epartnKjmofQxiscrvatwnaiKlReac^ Best Manage-
ment Practices Handbook - Hvdrotegk Modification* Richmond, VA. 1979.
For further information on the TIPPP, please contact:
USEPA
Pdutton Prevention Information Clearinghouse
Technical Information Service
c/o Science Applications International Corporation
7600-A Leesburg Pike
Falls Church. Virginia 22043
(703)821-4800
February 1992
Pollution Prevention Fact Sheet
206
No. 08
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NASA AEPA
Issue: Chemical Material Management
This Fact Sheet has been produced under the Tidewater Intel-agency Pollution Prevention Program
(TIPPP), a cooperative effort between EPA, DoD, and NASA to develop and demonstrate innovative
pollution prevention opportunities at Federal facilities.
Applications: One of the greatest environmental concerns associated with the operation of a military installation is
the use, misuse, treatment, and disposal of materials that contain hazardous and toxic chemicals. Improper use and
handling of chemicals (i.e., improper storage or use, stockpiling, etc.) can result in otherwise useful chemicals to be
disposed of as hazardous waste. This not only wastes raw materials, but it needlessly adds to the liability, cost, and
potential environmental damage from having to treat, store and dispose of hazardous wastes. In general, the misuse
and mishandling of such materials is preventable through techniques including automated chemical materials
management Chemical materials management is a series of tools to control the procurement, distribution, and use
of chemicals. Such tracking can assist the installation in:
• identifying less hazardous or non-hazardous material substitutes,
• reducing the amounts of materials that exceed expiration dates or shelf-lives. In addition, materials
management may provide an opportunity to document inadequacies in current procurement practices,
• ensuring that the appropriate chemical is used for the right job.
• ensuring chemicals are used and disposed of or recycled in a safe and proper manner,
• maintaining chemicals in proper storage to protect the container and chemical integrity, to reduce leaks
and segregate incompatible chemicals,
• ensuring that recertified products are not mistakenly disposed of as a waste,
• preventing unsafe storing and unauthorized stockpiling of chemicals that may lead to permit violations,
unsafe working conditions, and out-dated chemicals, and
• bom>wing and handling of dwanical5ainongenipk)yeesn«
Environmental Concerns: When materials are stockpiled and exceed recommended shelf-lives, the resulting
expired material is usually disposed of as a hazardous waste. In some cases, the material may be recertified or sold.
When disposed (or treated and disposed), toxic materials may be released to the environment Hazardous waste
disposal win also result in increased waste management costs and may also result in long-term liability for the
installation. If sold, the installation loses control of the toxic-bearing material which may also result in environmen-
tal release through improper use or subsequent improper disposal.
Known Solutions/References: Inadequate tracking, improper use, and/or incomplete training in the use of materi-
als can exacerbate the issues discussed above. With respect to military installations, the use of a chemical "Mrtfriah
management practices could streamline materials requisition and transfer to the point where excess or stockpiled
materials are minimized. By minimizing stockpiles and encouraging proper use of materials, the military could
reduce the amounts of expired shelf-life and unusable materials that are disposed of as waste. Further, the command
would reduce costs associated with wasting such raw materials.
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Specifically, chemical materials management practices allow the installation to ensure that chemicals are purchased,
issued, and used to meet process requirements, protect worker health and the environment, and limit the amount of
unused materials requiring disposal. This provides more control over the entire life cycle of the chemical — from
when it is first ordered for use to its safe and environmentally sound recycling or management Various activities
can be an integral pan of chemical material management Some of these elements are described below.
Procurement - For the military, procurement presents the greatest opportunity to reduce the amounts of chemicals
and materials that are purchased and subsequently disposed of without full use. Several aspects of procurement
result in waste including:
• requiring manufacturers to provide shelf-lives for materials without specifying criteria for developing
such shelf-lives,
• allowing customers the opportunity to reject usable chemicals that have been recertified with extended
shelf-lives,
• requiring supply operations to maintain stocks of materials that expire. In some instances, supply
operations might use computerized ordering systems (available from most retailers) that can provide
quick delivery of materials in usually 24 to 48 hours, and
• ordering chemicals without previous use rales ami without verifymgtne appropriateness of tte
for the specified activity.
By studying various aspects of the procurement, the installation can evaluate the use of every chemical ordered, with
the goal of determining if a less hazardous chemical substitute which meets process requirements could be used. By
requiring the users of chemicals to justify use, the installations can erwinr chetnicab are purcr^sed only for a
specific task in required quantities. With automating ordering, the installation can reduce the amounts of expired
materials and, at the same time, meet all of supply demands of the installation.
Employee Training - Train employees to correctly and safely use chemicals, what to do in case of spills, and how
to properly recycle or dispose of chemicals. Properly trained employees help ensure that the right chemical is used
for the right job and that useful chemicals are not needlessly disposed erf as a hazantous waste trffough improper use
storage or disposal
Inventory Control • Strict inventory control is an integral part of chemical material management Routinely check
the dale of materials to prevent them from outlasting meirshelflife. Practice first-in first-out inventory control, u^,
use older material before new raw materials. When possible, assign control over hazardous material supplies to a
limited number of individuals trained to handle hazardous materials and who understand the first-in fust-out
inventory policy. Limiting access to supplies also prompts eoBtoyees to conserve nw materials.
Chemical Storage - Routinely check the chemical storage area for feakiiig cootaiix^ or rusted or d
containers mat have the potential to leak. Storing chemical drurns or containers off the grouriniakesitatifyiiig leaks
easier. Store chemicals to preserve their chemical integrity. For example, store organic solvents so they do not undergo
temperature extremes. Assign one person responsibility tor checking for k^o awl inaintaining the storage;
Use Proper Ubeb- Check to see that containers' contents are properly labeled and dated. Replace labels before
they deteriorate. Unlabeled chemicals often are disposed of unnecessarily.
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NASA &EPA
or a Ban
FonEttau
Laxity Ratarck Ct*ur
Return Empty Containers to the Supplier - Empty containers often contain hazardous residue. Investigate
returning empty containers to the supplier for recycling. Rather than disposing of out-of-date material, return it to
the supply center. Some chemicals can be recertified for use or recycled and reused. Some suppliers establish credit
for returned material toward the next purchase.
Chemical use tracking - Comprehensive chemical use tracking involves using a computer system to track the
procurement, storage, distribution, use, and disposal or recycling of each and every chemical used. Workers fill out
a request form for each chemical. The requestor must justify the chemical by describing the process for which the
chemical is intended, and the chemicals' proposed use. Before receiving the chemical, the requestor's hazardous
chemical training level, the chemical's intended use, the quantity requested, and the material's hazard are checked
against the computer database. Without authorization, the material can not be purchased and it will not be issued. If
authorized, instructions on how to use and recycle or dispose of the chemical are issued along with the chemical.
Consider installing a bar code system on hazardous material containers. Each container is issued a unique code that
records the chemical content, the recipient, the date it was issued, the chemical's intended use, and the chemical's
expiration date. This allows the chemical to be tracked from the time it is issued to its disposal.
Reference 1.
References
1. Chabot, Robert, J. rtordons Chemical Control in a Large Industrial Complex. JAPCA, Volume 38, No. 9,
September 1988.
USEPA
Pollution Prevention Information Clearinghouse
Technical Information Service
c/o Science Applications International Corporation
7600-A Leesburg Pike
Falls Church, Virginia 22043
(703)821-4800
February 1992
Pollution Prevention Fact Sheet
No. 09
•U.S. GOVERNMENT PRINTING OFFICE: i 994 _5 50-001 /00203 209
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