United States
           Environmental Protection
           Agency
            Office of Research and
            Development
            Washington DC 2046O
EPA/600/R-95/061
April 1995
xvEPA
Pollution  Prevention
Research Within the
Federal Community

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                                            EPA/600/R-95/061
                                            April  1995
 POLLUTION PREVENTION RESEARCH WITHIN THE
               FEDERAL COMMUNITY
                          by
         N. Theresa Hoagland and James S. Bridges
           Pollution Prevention Research Branch
           Risk Reduction Engineering Laboratory
           U.S. Environmental Protection Agency
                 Cincinnati, Ohio 45268

                         and

              TRC Environmental Corporation
             Chapel Hill, North Carolina 27514
              EPA Contract No. 68-D2-0181
               Work Assignment No. 1/011
                    Project Officer

                 N. Theresa Hoagland
Waste Minimization, Destruction and Disposal Research Division
          Risk Reduction Engineering Laboratory
                Cincinnati, Ohio 45268
     RISK REDUCTION ENGINEERING LABORATORY
      OFFICE OF RESEARCH AND DEVELOPMENT
      U.S. ENVIRONMENTAL PROTECTION AGENCY
               CINCINNATI, OHIO 45268
                                         Printed on Recycled Paper

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

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                                          FOREWORD
               rapifd'y deve'ฐPing and changing technologies and industrial products and practices
  h             Hf1^ Lthe 'nCreaSed 9eneration ฐf materials that, if improperly dealt with can
 threaten both public health and the environment.  Thfe U.S. Environmental Protection Agency is
 charged by Congress with protecting the Nation's land, air, and water resources. Unde? a mandate of

          nVhlnmenKalhlaWS' LhS AgSnCy StriV6S t0 fฐrmulate and imP|e™e* actions leading to a
            balance between human activities and the ability of natural systems to support and nurture
            bas.s in support of the policies,  programs, and regulatbns of the EPA     respect to
            ? WasTtewate|; Pesticides' toxic substances, solid and hazardous wa^tel and PSuperfund-
 related act.yit.es  This pubhcat.on is one of  the products of that research and provides a vital
 communication link between the researcher  and user community.;


        h   re01  PฐiUtl0n Prevention ^arch Within the Federal Community, funded through the
        r?nDReSearCh  Bfanch' iS a major prฐJect in the area of Pollution Prevention Sn the
 thrnh Cฐmmu".lty Prฐ9ram to suPPฐrt and  Prฐmote pollution prevention in other Federaragencies
 through cooperative research, training, and demonstration projects.                     agencies


         '   ^H1^6 ""? ""^ ""'f11'0" ฐf summaries of P011"^"  prevention demonstrations,
            ,' f         ^ PrฐjeCtS conducted y the Pollution Prevention Research Branch at and or
 R.H,      P  t9efnciesA^anV  of the Precis described here were conducted under the Waste
 Reduction Evaluations At Federal Sites (WREAFS) program, funded in whole or in  part by ERA  Most

thJltrT   pCOndUCted/ฐr thS DePartment of Defense and Department of Energy were funded under
 nnn f ,   9lฐh ^nvironmental Research a^ Development Program (SERDP). Still other projects were
funded in whole or in part by the cooperating Federal agency            '      omer projects were
                    conjfined here wi" serve as a reference work and technology transfer to
       <  T         re,f U'tS and Prฐm0te the imP'ementation of pollution prevention actives  at
Federal facilities, as well as in other public agencies and the private sector
                                             in

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                                         ABSTRACT


      One of the primary ongoing programs for promotion and encouragement of pollution prevention
research is a cooperative program between the U.S. Environmental Protection Agency (EPA) and the
Federal community at large.  EPA's Waste Reduction Evaluations At Federal Sites (WREAFS)
Program supports pollution prevention research through joint assessments at selected Federal sites.
The three primary objectives of the WREAFS Program are to:  1) conduct pollution prevention
opportunity assessments (PPOAs) and case  studies; 2) conduct research and demonstration projects
jointly with other Federal activities; and 3) provide technology and information transfer of pollution
prevention (P2) results.

      This  report describes the WREAFS Program support of pollution prevention research throughout
the Federal community and provides an assessment of the status of implementation on all projects
which have been completed to date. These  include joint efforts with the U.S. Departments of Defense,
Transportation, Energy, Veterans Affairs, Interior, Agriculture, and Treasury1, the National Aeronautics
and Space Administration (NASA), the EPA, the U.S. Postal Service, and the White House.  There is
also an ongoing interagency project, the Tidewater Interagency Pollution Prevention Program (TPPP),
involving the Department of Defense and NASA.  Additionally, several projects are underway with the
Department of Defense, Department of Energy, Department of Transportation, U.S. Postal Service, and
EPA Office of Federal Enforcement.

      These projects identify case study and research opportunities to implement pollution prevention
for a range of military and  industrial operations including metal cleaning, solvent degreasmg, spray
painting vehicle and battery repair, ship bilge  cleaning, torpedo overhaul, buoy restoration, lens
grinding, hospital operations, laboratory analysis, mail processing, and other processes.

      This report was submitted in  partial fulfillment of contract number 68-D2-0181 under the
sponsorship of the U.S. Environmental Protection Agency. The report covers a period from January 1,
 1990 to September 30, 1994 and work was completed as of September 30, 1994.
     'A description of the Department of Treasury project is not included in this report.

                                               iv

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                                      CONTENTS
   Section
       —                                                                      Page
   Disclaimer	
   Foreword .....;.;...     .           • • • • •		jj
   Abstract	'-'.'.'.'.'.'.'.'.'/.'.'.'.'.'.' '	 . ...	  jji
   Figures . . .  .....	  jv
   Tables		^ ................   	:	•" '	-"	' ' '	xl!
   List of Acronyms	           	'	xii
  1      BACKGROUND	...'.'.'	' ' ' '		xiil
        1.1    INTRODUCTION	'	•	  1
        1.2    WREAFS PROGRAM PROCEDURES	•""•'':'."."".	:' '  V  J
        1.3    COMPLETED POLLUTION PREVENTION PROJECTS .' .' '. '. '. '. ','.'-. '. '. '. '•,' .' •.';•.'.""  3

     DEPARTMENT OF DEFENSE
 2      PHILADELPHIA NAVAL SHIPYARD
        2.1    FACILITY DESCRIPTION		  4

        2.2    AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	'  4
             2.2.1   Aluminum Cleaning and Spray Painting . .                    ........
             2.2.2   Spray Painting of Steel Parts Including Structural Columns " "	" " '  5
             2.2.3   Citric Acid Bilge Derusting Operations in Drydock                         K
       2.3    POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS	   5
             2.3.1  Awareness and Training for Personnel and Procedure-Related'Options' " " '   5
             2.3.2  Dragout Reduction and Bath Maintenance ....                   	  fi
             2.3.3  Two-Stage Rinsing  ....          .          ••••-.		 . .  o
       2.4    RESEARCH, DEVELOPMENT, AND DEMONSTRATION "  " "	  R
       2.5    STATUS OF IMPLEMENTATION                    	'	  ฃ
                                          	•	  D

 3     NAVAL UNDERSEA WARFARE CENTER, KEYPORT DIVISION                        7
       3.1    FACILITY DESCRIPTION	        	'	' ' '  '

       I'l    DnFM^MPoiLUTIฐN PREVENT|ON OPPORTUNITY EVALUATIONS .'	  7
       3.3    POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS      	  8
             3.3.1   Volume Reduction of Otto Fuel-Contaminated Clothing         	  ซ
             3.3.2   Automated Cleaning of Parts and Fuel Tanks              	  a
             3.3.3   Automated Fuel Tank Draining	     '	' ' '	.' ' '   g
             3.3.4   Modification of the Deep Sink Draining Schedule	•••••••	
             3.3.5   Recycling of Mineral Spirits                     	'	   Q
       3.4    RESEARCH, DEVELOPMENT, AND DEMONSTRATION	'	   Q
       3.5    STATUS OF IMPLEMENTATION 		'	   g

4     JINKER AIR FORCE BASE OKLAHOMA CITY AIR LOGISTICS CENTER	       10


      4.2    AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	   10

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      4.3    POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS 	  10
            4.3.1   Ozone-Depleting Substance Alternatives	  11
            4.3.2   Plating Alternatives	.• • •  •  ^
            4.3.3   Component Cleaning Alternatives . ,	• •  •  ""
            4.3.4   Depainting/Painting Alternatives	  11
      4.4    RESEARCH, DEVELOPMENT, AND DEMONSTRATION  	  11
            4.4.1   Brush Plating Implementation and Evaluation	•  12
            4.4.2   Cleaning Alternatives Implementation and Evaluation	  12
            4.4.3   MEK Recovery/Reuse	  }2
      4.5    STATUS OF IMPLEMENTATION  .	  ™
            4.5.1   Ozone Depleting Substance Alternatives	  13
            4.5.2   Plating Alternatives	•	  ™
            4.5.3   Depainting/Painting Alternatives	  13

5     SCOTT AIR FORCE BASE	  f
      5.1     FACILITY DESCRIPTION	  }b
      5.2     AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	  15
             5.2.1   Nondestructive Inspection	  ^
             5.2.2   Painting/Depainting/Parts Cleaning Operations 	• • • •  1ฐ
             5.2.3   Printed Circuit Board Manufacture 	  17
      5.3     POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS  	  17
             5.3.1   Nondestructive Inspection      	•	  ^7
             5.3.2   Painting/Paint Removal/Parts Cleaning	  1'
             5.3.3   Printed Circuit Board Manufacture	  18
      5.4     STATUS OF IMPLEMENTATION  	  18

6     AIR FORCE PLANT NUMBER 6	  ]jj
      6.1     FACILITY  DESCRIPTION	  ™
      6 2    AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	   19
      63    POLLUTION PREVENTION  OPTIONS AND RECOMMENDATIONS  	   19
      6.4    RESEARCH, DEVELOPMENT, AND DEMONSTRATION	  20
      6.5    STATUS OF IMPLEMENTATION	   20

7     FORT RILEY	i	• •   *]
      7.1     FACILITY  DESCRIPTION	   21
      7.2    AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	   21
             7.2.1   Battery Repair Shop	   21
             722  Automotive Subassembly Rebuild Shop	   21
      7.3    POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS  	   22
             7.3.1   Recycling of Waste Battery Acid	   22
             7.3.2  Recirculation of Washer Wastewater	   22
      7.4    RESEARCH, DEVELOPMENT, AND DEMONSTRATION   	   22
      7.5    STATUS OF IMPLEMENTATION  	• •   23
                                          vi

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 8     FITZSIMMONS ARMY MEDICAL CENTER OPTICAL FABRICATION LABORATORY .....  24

       8.2    AREAS OF POLLUTION PREVENTION OPPORTUNJTY EVALUATIONS	  25
       8.3    POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS     	  25
             8.3.1   Glass Fines	                            	  ,c
             8.3.2   Alkaline Wastewaters	'	" "	'  ' ' '  **
       8.4    RESEARCH, DEVELOPMENT, AND DEMONSTRATION	'	  ol
       8.5    STATUS OF IMPLEMENTATION	....'.'.'.'.•'.'. '. '. '.'.'  ' ' V  " '  35

 9      FORT CARSON EVANS COMMUNITY HOSPITAL                                  ov
       9.1    FACILITY DESCRIPTION .......       " '	'	" ' ' '	  iL
       9.2    AREAS OF POLLUTION PREVENTION OPPORTUNITY  EVALUATIONS	  27
             9.2.1  Tissue Processing	                             	  ,'
             9.2.2  Slide Staining		  *'
       9.3    POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS " '	  28
             9.3.1  Solvent Substitution^	                           ' '		  fฐ
             9.3.2  Solvent Recovery	      " "	.•••••..		  tx>
      9.4    RESEARCH, DEVELOPMENT, AND DEMONSTRATION •••'.;•.•••••	  f
      9.5    STATUS OF IMPLEMENTATION  .....              '.'."'.'•'	  ^
             9.5.1  Solvent Substitution	          '	"••'.•;	  ~ฐ
            9.5.2  Solvent Recovery		' ' '  f:
                                            	•••*••......	  ^y

1 ฐ    ^M™MENT ฐF VETERANS AFFAIRS CINCINNATI-FORT THOMAS MEDICAL
      OtNTER	
      10.1   FACILITY DESCRIPTION	'  ' " " '	   !?ฐ
      10.2   AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS  " '	   30
            10.2.1  Laboratory Services	                     	   ^
            10.2.2  Surgery Department  .... .-. .........'"''''	  3}
            10.2.3  Surgical Intensive Care Unit           	•••••-	  JT
            10.2.4  Five (5) South: Patient Floors  . .'.'.:.'.'.'.'.'.'.'.'.''..	'	  t]
            10.2.5  Medical Intensive Care Unit/Cardiac Care Unit    "''•'''	'  ' '  ,,,
            10.2.6  Hemodialysis 	                   " '.."' '	'  ' '  „
            10.2.7  Outpatient Clinic ...	  „
      10.3   POLLUTION PREVENTION OPTIONS  AND RECOMMENDATIONS "	  3?
            10.3.1  Reuse of Disposables	             '	  ff
            10.3.2  Wovens Versus Nonwovens          ••-..-..		  jj
            10.3.3  Product Substitution ...        	  „
      10.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION ••••-••••/•••.;	  *ป
      10.5   STATUS OF IMPLEMENTATION                   •     '	  17
                                       	  34
 11    DEPARTMENT OF  TRANSPORTATION                              .

                                       NEW YฐRK GOVERNORs -SLAND  	   35

      11.2  AREAS OF  POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	   35
           11.2.1 Management Activities	            	' ' '   3ฐ
           11.2.2 Technical Evaluation for Pollution Prevention	" '   OR
     11.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS "	   37
           11.3.1 - Low Pressure Spray Guns	   	   37
                                       VII

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            11.3.2  Plastic Shot	  37
            11.3.3  On-Site Still for Solvent Recovery	  37
      11.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION  	- - -  37
      11.5   STATUS OF IMPLEMENTATION  	•	  38

 12   U.S. COAST GUARD BASE KETCHlKAN	39
      12 1   FACILITY DESCRIPTION	  39
      12.2   AREAS OF  POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	  39
            12.2.1  Buoy Maintenance	;	  39
            12.2.2  Vessel Maintenance	  39
      12.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS  	  40
            12.3.1  Blasting Waste . . .;			  40
            12.3.2  Painting Vessels and Buoys	  40
            12.3.3  Solvents	: • •	  41
            12.3.4  Bilge Waste	  ^
            12.3.5  Waste Oil	  **
            12.3.6  Antifreeze/Coolant.!	•	  •ฃ
      12.4   STATUS OF IMPLEMENTATION	  42

13    DEPARTMENT OF  ENERGY SANDIA NATIONAL LABORATORIES		  44
      13 1   FACILITY DESCRIPTION	  44
      13.2   AREAS OF  POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	  44
            13.2.1  Geochemistry Laboratory	  44
            13 2.2 Manufacturing and Fabrication Repair Laboratory	  45
      13.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS  	  45
            13.3.1  Geochemistry Laboratory	  46
            13 3.2 Manufacturing and Fabrication Repair Laboratory  	  47
      13.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION  	  47
      13.5   STATUS OF IMPLEMENTATION  	  47

  14   DEPARTMENT OF  AGRICULTURE BELTSVILLE AGRICULTURAL RESEARCH CENTER .  49
      14.1   FACILITY DESCRIPTION .;	   49
      14.2  AREAS OF POLLUTION PREVENTION OPPORTUNITY  EVALUATIONS	   49
            14.2.1 General Hazardous Materials Handling and Usage  	• •  49
            14.2.2 Total Kjeldahl Nitrogen Analysis	•	  49
            1423 High Performance Liquid Chromatography Analysis	  50
      14.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS  	  50
            14.3.1 General Hazardous'Materials Handling and Usage  	  50
            14.3.2 Total Kjeldahl Nitrogen Analysis	,	  51
            14 3.3 High Performance Liquid Chromatography Analysis	  51
      14.4  RESEARCH, DEVELOPMENT, AND DEMONSTRATION  	  52
      14!5  STATUS OF IMPLEMENTATION	  5z

 15    DEPARTMENT OF INTERIOR BUREAU OF MINES ALBANY RESEARCH CENTER .....  53
      15.1  FACILITY DESCRIPTION ,	  53
      152  AREAS OF POLLUTION  PREVENTION OPPORTUNITY EVALUATIONS	  53
      •\5.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS  	  53
            15.3.1  Inventory Control	  53
                                         VIII

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             15.3.2  Solvent Extraction Research  . .	           54
             15.3.3  Corrosion Research	         	   54
       15.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION     	  	   55
       15.5  STATUS OF IMPLEMENTATION	 .'.l ..-...'.'.'.'.'.'.'.'.'.'.'.'.'.'.',',]   55

 16    U.S. POSTAL SERVICE BUFFALO GENERAL MAIL AND VEHICLE MAINTENANCE
       FACILITIES	                               .. .               cR
       16.1   FACILITY DESCRIPTION ..........'.'.'.'.'.'.'.'.'.	''"'.'	   55
       16.2   AREAS FOR POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	   56
             16.2.1  Mail Processing	                          • • •   ^
             16.2.2  Vehicle Maintenance Facility 		   57
       16.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS	   57
             16.3.1  General Mail Facility	........'.	   57
             16.3.2 Vehicle Maintenance Facility	                  	    58
       16.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION	   59
       16.5   STATUS OF IMPLEMENTATION	      ...'.'.'.'.'.'.'.       59
             16.5.1 General Mail Facility	        '.'.'''•	  60
             16.5.2 Vehicle Maintenance Facility	  61
             16.5.3 Northeast Area Pollution Prevention Initiatives	 '..'.'.'.'.  62

       INTERAGENCY
  17    THE WHITE HOUSE COMPLEX	                                       65
       17.1   FACILITY DESCRIPTION		......''..	  65
       17.2   AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS    	  65
       17.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS  .   	  66
             17.3.1  Paint shops	                  	  66
             17.3.2  Grounds Maintenance	                   	  	  66
             17.3.3  HVAC/Chiller Operations	      66
             17.3.4  Office Operations	        '.'.'.'.'.'.'.	  67
             17.3.5  General Operations	 .           	  	  67
       17.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION	  67
       17.5   STATUS OF IMPLEMENTATION		      '.'.'.'.'.""'      67
             17.5.1 Water conservation	  ••••••••	  ^
             17.5.2 Pest Management	  68
             17.5.3 Eliminating Chlorofluorocarbons (CFCs)   ..............    	  68
             17.5.4 Energy-efficient appliances	'.'.'.'.'.'.'.'.'.".'.'.'.'.	  68

18    TIDEWATER INTERAGENCY POLLUTION PREVENTION PROGRAM (TIPPP)             69
      18.1    FACILITY DESCRIPTION ..                                   	  *q
             18.1.1 Fort Eustis  	'.'.'.'.'.'.'.'.'.'.'.'.'.'.''	  69
             18.1.2 Langley Air Force Base (LAFB)	'..'.'.'.	  69
             18.1.3 NASA Langley Research Center (LaRC)	   69
             18.1.4 Naval Base Norfolk  	         "	   70
      18.2   AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS	   70
      18.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS    	   70
            18.3.1 Chemical Material Management	        	   70
            18.3.2 Land Management  	             	• • • .	
            18.3.3 Municipal Solid Waste  	     	'	  73
                                        IX

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             18.3.4 Laboratory Wastes   	  74
             18.3.5 Electroplating  .	  75
             18.3.6 Painting Operations   . .	  76
             18.3.7 Metal Working   ,	  78
             18.3.8 Solvents	  79
             18.3.9 Depainting Operations	  80
      18.4   STATUS OF IMPLEMENTATION	  81
             18.4.1 Fort Eustis	. .	  81
             18.4.2 Langley Air Force! Base (LAFB)	  83
             18.4.3 NASA Langley Research Center (LaRC)   .	  84
             18.4.4 Naval  Base Norfolk  	-90

19    NASA LANGLEY RESEARCH CENTER PHOTO LABS  	95
      19.1   FACILITY DESCRIPTION	95
      19.2   AREAS OF POLLUTION  PREVENTION OPPORTUNITY EVALUATIONS	95
      19.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS 	95
             19.3.1 General Processing  	95
             19.3.2 Silver  Recovery  	96
      19.4   STATUS OF IMPLEMENTATION  	96
             19.4.1 General Processing  	  96
             19.4.2 Silver  Recovery  	  96

20    ONGOING AND PROPOSED WREAFS PROJECTS  	'. . 98
      20.1   U.S. DEPARTMENT OF  DEFENSE	98
             20.1.1 Naval  Ophthalmic Support and Training Activity (NOSTRA) 	98
             20.1.2 Naval  Station Mayport	98
             20.1.3 U.S. Air Force Center for Environmental  Excellence	98
             20.1.4 U.S. Army Corps ;of Engineers (USAGE)	98
             20.1.5 Fort Eustis Army Transportation Center  	98
      20.2   U.S. DEPARTMENT OF  TRANSPORTATION	99
             20.2.1 U.S. Coast Guard Air Training Center	99
             20.2.2 U.S. Coast Guard Technology Assessments	99
      20.3   U.S. DEPARTMENT OF  ENERGY	99
             20.3.1  LCA Research and Development Demonstration 	99
             20.3.2 Complex-wide LCA Design Case Studies 	99
      20.4   U.S. DEPARTMENT OF  INTERIOR	99
             20.4.1  Bureau of Indian  Affairs	99
      20.5   U.S. POSTAL SERVICE	100
             20.5.1  Pollution Prevention Opportunity Assessments  	100
      20.6   U.S. ENVIRONMENTAL  PROTECTION AGENCY	100
             20.6.1  Office of Federal Facility Enforcement (OFFE)14 F2P2 Manual  	100
             20.6.2  Office of Federal Facility Enforcement - FMECI Support	100
      20.7   NATIONAL AERONAUTICS AND SPACE ADMINISTRATION 	100
             20.7.1  NASA Langley Research Center - Dry Powder Towpreg	100
             20.7.2  NASA Langley Research Center - Pollution Prevention Program
                    Implementation	100
      20.8   OTHER POLLUTION PREVENTION  RESEARCH INVOLVING FEDERAL
             AGENCIES	101

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      20.9
      20.8.1  Newark Air Force Base	                   101
      20.8.2  Naval Aviation Depot	'.'.'.'.'.'.'.'.'.'.'.'.'.'.''''	     101
      20.8.3  Tooele Army Depot	       '.'.'.'.'.'.'.	101
      20.8.4  U.S. Department of Agriculture, Forest Products Laboratory	  	101
      SUMMARY AND CONCLUSIONS	 .......   .'.,' '.'.'.'/.'.'."•  101
21

22
REFERENCES
                                                                          102
P2 PUBLICATIONS AND ORDERING FORM	 . . .	            103
                                        XI

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                                         FIGURES
Number

 1           Pollution Prevention Program Overview
                                         TABLES
Number

  1

  2
                                                                                     Page
Comparison of Estimated :and Actual Return from Source Reduction
 and Recycling at the Buffalo General Mail Facility  	
Waste Prevention and Recycling Operations in Place at USPS
 Northeast Area Vehicle Maintenance Facilities	
60

64
                                             xii

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                                    LIST OF ACRONYMS
 ADC
 AFB
 AFESC
 ALC
 AOAC
 APOE
 ASD
 ATON
 BARC
 BMPs
 CARC
 ecu
 CFC
 CFC-113
 COMNAVBASE
 CRADA
 DCRA
 DEG
 DOD
 DOE
 DRMO
 ECH
 EM
 EPA
 F2P2
 FAMC
 FFEO
 FMECI

 FORSCOM
 FY
 GL
 GMF
 HOPE
 HMMWV
 HPLC
 HVAC
 HVLP
IAG
IV
KAFB
LAFB
 Alaska Department of Conservation
 Air Force Base
 Air Force Engineering Service Center
 Air Logistics Center
 Association of Official Analytical Chemists
 Aerial Port of Embarkation
 Aeronautical Systems Division
 aids to navigation
 Beltsville Agricultural Research Center
 Best  Management Practices
 Chemical Agent Resistant Coating
 Cardiac Care Unit
 chlorofluorocarbon
 trichlorotrifluoroethane
 Commander, Naval Base
 cooperative research and development agreement
 Department of Consumer and Regulatory Affairs
 diethylene glycol
 Department of Defense
 Department of Energy
 Defense Reutilization and Marketing Office
 Evans Community Hospital
 electromechanical metallizing
 Environmental  Protection Agency
 Federal Facilities  Pollution Prevention
 Fitzsimmons Army Medical Center
 Federal Facilities  Enforcement Office
 Federal Facilities  Multi-Media  Enforcement/Compliance
 Initiative
 Forces Command
fiscal  year
Geochemical Laboratory
General Mail Facility
high density polyethylene
High Mobility Multipurpose Wheeled Vehicle
high performance liquid chromatography
heating, ventilating, and air conditioning
high volume/low pressure
interagency agreement
intravenous
Kirkland Air Force Base
Langley Air Force Base
                                           XIII

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                             LIST OF ACRONYMS (continued)
LaRC
LARPS
LCA
LCA RD&D
LCCA
LHE
LMSC
MEK
MFRL
MICU
NASA
NAVSTA
NADEP
NAWC
NDI
NMP
NTF
NOSTRA
NUWC KPT DIV
OC-ALC
OCC
ODC
ODS
OEOB
OFL
OLA
ORD
P2
PMB
PNSY
PPOA
QA/QC
R&D
RCRA
RREL
RRRP
SEM
SEPS
SERDP
SFE
SICU
SIMA
SNL
SOW
SPE
Langley Research Center
Large Aircraft Robotic Paint Stripper
life cycle assessment
Life Cycle Assessment Research and Development
life cycle cost assessment
Low Hydrogen Embrittlement
Lockheed Missile and Space Company
methyl ethyl ketone     ,
Manufacturing and Fabrication Repair Laboratory
Medical Intensive Care Unit
National Aeronautics and Space Administration
Naval Station     :
Naval Aviation Depot
Naval Air Warfare Center
nondestructive inspection
N-methyl-2-pyrrolidone
National Transonic Facility
Naval Ophthalmic Support  and Training Activity
Naval Undersea Warfare Center, Keyport Division
Oklahoma City Air Logistics Center
old  corrugated cardboard
Ozone Depleting Compounds
Ozone Depleting Substances
Old Executive Office Building
Optical Fabrication Laboratory
Optical Laboratories Association
Office of Research and Development
pollution prevention
plastic media blasting
Philadelphia Naval Shipyard
pollution prevention opportunity assessment
quality assurance/quality control
research and development
Resource Conservation and Recovery Act
Risk Reduction Engineering Laboratory
Resource Recovery and Recycling Program
scanning electron microscope
Supplemental  Environmental  Projects
Strategic Environmental Research and Development Program
supercritical fluid extraction
Surgical Intensive:Care Unit
Shore Intermediate Maintenance Activity
Sandia National Laboratories
statement of work
solid phase extraction
                                            XIV

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                              LIST OF ACRONYMS (continued)
SALTS
TCA
TCE
TEA
TIPPP
TKN
TRADOC
TSDF
UBBM
USAGE
USCG
USPS
UV
VMF
VOC
WREAFS
Streamlined Alternative Logistics Transmission System
1,1,1-trichloroethane
tricnloroethylene
triethanolamine
Tidewater Interagency Pollution  Prevention Program
total Kjeldahl nitrogen
Training and Doctrine Command
treatment, storage, and disposal facility
undeliverable bulk business mail
U.S. Army Corps of Engineers
U.S. Coast Guard
U.S Postal Service
ultraviolet
Vehicle Maintenance Facility
volatile organic compound(s)
Waste Reduction  Evaluations at  Federal Sites
                                           xv

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                                          SECTION 1
                                        BACKGROUND
 1.1    INTRODUCTION
       The objectives of the Waste Reduction Evaluations At Federal Sites (WREAFS) Program are to
 identify new technologies and techniques for reducing wastes from industrial and other processes
 performed by Federal agencies and to enhance the adoption of pollution prevention through
 technology transfer.  New techniques and technologies for reducing waste generation are identified
 through Pollution Prevention Opportunity Assessments (PPOAs) and are evaluated through joint
 research, development, and demonstration (RD&D) projects. The information and data from these
 projects are then provided to both the public and private sectors through various technology transfer
 mechanisms, including project reports, project summaries, conference presentations, and workshops.

       As a result of joint PPOAs, RD&D projects are identified with recommendations for pollution
 prevention under the implementation phase.  The demonstration projects are often conducted under
 interagency agreements with joint funding by EPA  and the cooperating Federal agency.  Pollution
 prevention workshops and other technology transfer methods are used to communicate the results of
 these  projects to the Federal community, other public agencies, and the private sector.

 1.2    WREAFS PROGRAM PROCEDURES

       The PPOAs are conducted by an assessment team that  is composed of personnel from EPA,
 the Federal facility cooperating in the program,  and others who can provide technology and
 processing expertise.  The assessments follow  the procedures  described in the EPA Report Facility
 Pollution Prevention  Guide  (EPA/600/R-92/088) (1). (Single copies are available at no charge from
 the U.S. EPA CERI Publications Unit, 26 West  Martin Luther King  Drive, Cincinnati, Ohio 45268.)
 This guide provides a systematic procedure for identifying ways to reduce or eliminate waste
 generation.  The development of this procedure was supported by  the Risk Reduction Engineering
 Laboratory (RREL), U.S. Environmental Protection  Agency, Cincinnati, Ohio.

      Figure 1 illustrates the major steps in the pollution prevention program.  The steps consist of
 four major phases: (1) Planning and Organization,  which includes  organization and goal setting;  (2)
 Assessment, which includes a careful review of a facility's operations and waste streams and  the
 identification and screening  of potential options  to reduce waste; (3) Feasibility Analysis, including an
 evaluation of the technical and economic feasibility of the options selected and subsequent ranking  of
 options; and (4) Implementation, which involves procurement, installation,  implementation, and
 evaluation. WREAFS projects typically focus on steps (2) and (3).

      Many of the pollution  prevention opportunities identified during WREAFS projects involve low-
cost changes to equipment and procedures that can often be implemented by the facility without
extensive engineering evaluations.  Other pollution  prevention 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
                                              1

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

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 use of new procedures or equipment. In such cases, it may be necessary to conduct demonstration
 projects.

      Depending on the nature and state of development of the pollution prevention option selected
 for demonstration and evaluation, these projects may include:  (1) process design, (2) detailed design
 and specification, (3) system procurement, (4) installation and start-up, (5) monitoring, and (6)
 reporting.  Some projects may require bench-scale and/or pilot testing prior to, or as a part of, the
 demonstration project.  Other projects may utilize full-scale equipment directly on the production line.

 1.3   COMPLETED POLLUTION PREVENTION PROJECTS

      As of September 1994, eighteen WREAFS projects have been completed, eight at Department
 of Defense (DOD) facilities,  including two with the Navy, three with the Air Force and three with the
 Army; one with the Department of Veteran's Affairs; two with the Department of Transportation; one
 with the Department of Energy (DOE); one with  the Department of Agriculture; one with the
 Department of Interior; one with the U.S. Postal  Service (USPS); one with the White House Complex;
 one with the Department of Treasury; and an  interagency effort involving the EPA, Air Force, Army,
 Navy, and NASA. With these eighteen,  the project has been completed and pollution prevention
 options have been identified for implementation.  The degree to which the pollution prevention
 options have been implemented is highly variable.  A description  of each project follows, including a
 summary of the pollution prevention options recommended and a report on the status of
 implementation.

 NOTE: Although the following projects are described in the present tense, descriptions of facilities,
activities, processes, and pollution prevention  options reflect the situation at the time the PPOA was
conducted.  The status of implementation section, however, represents information that was current
as of September 1994.

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                                         SECTION 2

                                 DEPARTMENT OF DEFENSE
                              PHILADELPHIA NAVAL SHIPYARD

      The PPOA for this facility was completed in 1991.  At that time, the shipyard had an ongoing
program for pollution prevention.  Several industrial operations were selected for application of the
EPA pollution prevention procedures.  The shipyard has used these results as guidance for
evaluating other pollution prevention activities at the facility.

2.1   FACILITY DESCRIPTION

      The Philadelphia Naval Shipyard (PNSY), the nation's oldest continuously operating  naval
shipyard, is located  in  South Philadelphia on 1,000 acres of land.  Since its inception, 127 ships have
been constructed with  the last ship launched in 1971.  The PNSY now specializes in revitalizing and
repairing ships already in fleet. The Service Life Extension Program is the shipyard's largest
program and its comprehensive keel-up restoration and modernization overhaul  extend the life of an
aircraft carrier to 150 percent, at approximately one-third of the cost of a new carrier.

2.2   AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

      The industrial activities selected for this project included:  aluminum cleaning and spray
painting;  spray painting of steel parts including structural columns; and citric acid bilge derusting
operations in drydock.

2.2.1  Aluminum Cleaning and Spray Painting

      The aluminum cleaning is performed to  remove oil and other materials from the surfaces of
aluminum sheets prior to tungsten inert gas welding.  The cleaning line consists of two process and
two rinse tanks. Aluminum sheets are placed in a metal basket which is lowered into a process tank
for five minutes, followed by a tap-water rinse  in one of the rinse tanks.  Process tanks become
contaminated with floating  oil, suspended solids, and tapwater which is used to  replenish the solution
due to dragout losses.  The tanks are pumped after approximately three months of operation; spent
solution is disposed of by contract. Rinsate tanks are disposed of in a similar manner, usually every
two weeks.

      Spray painting involves solvent degreasing and a water curtain booth for painting.  Prior to
painting,  the parts are degreased with rags dipped in xylene. Parts are sprayed with a zinc chromate
primer, followed by a final  enamel paint coating.  Spraying is conducted in a water curtain booth.
Paint solids from overspray and sludge residues are removed and drummed.  An organic polymer
added to the booth water aids in precipitation of the paint overspray and helps reduce clogging of the
booth's water recycle spray nozzles and piping system. A second polymer is added after
approximately two weeks which coagulates the dispersed paint into a floating sludge which can be
removed by screening and then drummed for disposal.  Booth water is recycled for approximately six
months and then discharged into the sewer.

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 2.2.2  Spray Painting of Steel Parts Including Structural Columns

       Three booths are used for spray epoxy painting of steel surfaces:  (1) a large, shot
 blasting/painting booth with a dry air filtration system; (2) a shape abrader/spray booth for blasting
 and painting steel columns; and (3) a water curtain booth.  The water curtain booth consists of two
 18-foot-long water curtains and uses a booth water deflocculant for water maintenance.

 2.2.3  Citric Acid Bilge Derustinq Operations in Drvdock

       PNSY employs a relatively new citric acid/chemical process for cleaning ships' tanks, bilges,
 and void spaces, which replaces the more traditional mechanical methods of cleaning and derusting
 metal  surfaces.  A citric acid/triethanolamine (TEA) solution is used to remove oxides from the metal
 surfaces, and the surfaces are subsequently neutralized and  rinsed with dilute solutions.

       Grease and oil  are removed from the metal surfaces with  a degreaser, which is applied using a
 hand-held garden-type sprayer.  This solution is then washed down with a high-pressure water spray.
 Existing paint is then  stripped, followed by a second rinse.  Rust is subsequently removed with a
 hydroblast of hot, concentrated citric acid/TEA solution (ten percent citric acid, seven percent TEA).
 Solution runoff is collected  and recycled, and is ultimately pumped to a waste container for disposal.
 Following  derusting, a hot neutralizer (less than one percent citric acid, four percent TEA)  is sprayed
 onto the metal surface.  A one percent TEA solution is sprayed onto the surface for a final rinse. All
 run-off is pumped to a waste tank for disposal.

       A typical derusting/neutralization/rinse operation generates approximately 3,000 gallons of
 spent solution, which generally has a pH less than 4.0 and contains toxic metals.  The waste is
 removed by a contractor for treatment and disposal.

 2.3    POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

      After the assessment and feasibility analysis phases were completed, seven options were
 evaluated  and ranked. These options included: (1) dragout reduction and bath maintenance; (2)
 two-stage  rinse; (3) booth guard system, consisting of a three-phase cycle (biannual cleaning, normal
 operation, and biweekly paint removal); (4) paint sludge dewatering; (5) high volume/low pressure
 (HVLP) painting; (6) awareness and training for personnel and procedure-related options; and (7)
 recovery of concentrated citric acid solution.  Of these seven, three were assessed as feasible:  (1)
 awareness and training for personnel and procedure-related options;  (2) dragout reduction and bath
 maintenance; and (3) two-stage rinsing.

 2.3.1  Awareness and Training for Personnel and  Procedure-Related  Options

      Paint and paint  wastes comprise the second largest hazardous waste stream generated at the
shipyard.  Painting is a process in which the technique and habits of the operator may have
considerable influence on the amount of waste  generated. A  training program emphasizing operator
 involvement  and responsibility could reduce waste paint resulting from overspray, unused paint
remaining in cans, and paint solidification prior to use. This program would also help establish and
encourage effective lines of communication between  operators and supervisors.
                                              5

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2.3.2  Draqout Reduction and Bath Maintenance

      With this option, the use of a hand-held spray rinse applied over process tanks would eliminate
the use of the two rinse water tanks and would return 90 percent of the dragout to the process tank.
As a result, contaminants would accumulate in the process tanks at a faster rate and might interfere
with the cleaning process. A bath maintenance system employing an oil skimmer for floating oil and
grease removal, and a cartridge filter for suspended solids removal, would extend  the usable  life of
process tanks from three months to one year.

2.3.3  Two-Stage Rinsing

      Employing a two-stage rinse operated with the tanks in series rather than in parallel would
prolong the lives of the rinsing tanks. As one rinse tank becomes  contaminated, the rinse water
would be changed out.  The tank containing the fresh water would always be used as the final rinse.

2.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      Recovery of concentrated citric acid solution represents a viable candidate for further research,
development and demonstration. This would involve the implementation of equipment for recovery of
citric acid/TEA solution.  This process would  employ an electrodialytic membrane  unit for separation
and removal of dissolved metals.  This  technology has been applied to similar chemical solutions  but
its application to this waste has not been previously demonstrated.

2.5   STATUS OF IMPLEMENTATION

      Due to downsizing of the military, the Shipyard is ceasing industrial activity  in September 1995
and will fully close in September 1996.   For this reason, the PNSY has not implemented any of the
measures recommended in the PPOA.

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                                          SECTION 3

                                 DEPARTMENT OF DEFENSE
                  NAVAL UNDERSEA WARFARE CENTER, KEYPORT DIVISION

       Pollution prevention opportunities were identified in 1991 at two industrial units at the Naval
 Undersea Warfare Center, Keyport Division (NUWC KPT DIV) in  Keyport, Washington.  At that time,
 several departments were involved in an ongoing program to further the process of pollution
 prevention at NUWC KPT DIV.

 3.1    FACILITY DESCRIPTION

       NUWC KPT DIV is located within the central Puget Sound  area of northwestern Washington
 State. The property was acquired by the Navy in 1913 and first used as a quiet water range for
 torpedo testing.  Later, it was used for torpedo repair.  The facility acquired its name in  recognition of
 its mission in various undersea warfare weapons and systems engineering and development
 activities.

 3.2   AREAS OF POLLUTION  PREVENTION OPPORTUNITY EVALUATIONS

      The  principal activities currently conducted at NUWC KPT DIV are the design and testing of
 torpedoes.  These activities generate a variety of potentially  hazardous wastes, including waste fuel,
 oil, hydraulic fluid and grease, various metal and plating bath liquids, paint and thinner,  Freonฎ,
 alcohol, mineral spirits and other solvents, resins, acids and caustics, chromate and cyanide salts,
 pesticide residues, wastewater treatment sludge, waste dye, and detergent. The major  component of
 waste management involves the use of Otto  Fuel II (Otto fuel) which is used for propelling torpedoes.
 Otto fuel is composed of propylene glycol dinitrate with lesser amounts of 2-nitrodiphenylamine and
 di-n-butylsebacate.  Otto fuel is a monopropellant (i.e., it burns without oxygen).  All Otto fuel-
 contaminated solid waste is currently treated as an explosive, reactive waste.

      Two  torpedo maintenance shops, the Mark 48 torpedo shop and the Mark 46 torpedo shop,
were selected by the Navy for evaluation.  These two shops  have similar operations, processes, and
waste streams.  In the Mark 48 shop,  torpedoes are disassembled into large sections and sent to
appropriate depots on base where they are further disassembled into components, updated, cleaned
repainted, reconstructed, and reassembled. The hydraulic fluid and  fuel tanks are drained and
refilled in the Mark 48 shop; fuel tanks and other major sections are then reassembled.  The Mark 46
shop primarily houses defueling, disassembling,  cleaning, reassembling, and refueling activities.
Wastes generated at these sites include:  Otto fuel combustion byproducts consisting of cyanide-
containing liquid wastes and sludges; Otto fuel-contaminated solvents and oils generated during parts
cleaning; Otto fuel-contaminated wastewaters; Otto fuel-contaminated solids, primarily clothing and
rags; used oil; used hydraulic fluid; and diethylene glycol  (DEC) and Otto-fuel contaminated rinse
waters.  All the waste streams are classified Resource Conservation and Recovery Act (RCRA)
reactive wastes.

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3.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

      NUWC KPT DIV has performed well in the handling, storage and minimization of waste
materials on-base. During this assessment, no major pollution prevention options were identified that
NUWC KPT DIV has not already implemented or plans to implement.   However, the following five
options were identified to aid in the process:  (1) volume reduction of Otto fuel-contaminated clothing;
(2) automated cleaning of parts and fuel tanks; automated fuel tank draining; (3) modification of the
deep sink draining schedule; and recycling of mineral spirits.

3.3.1  Volume Reduction of Otto Fuel-Contaminated Clothing

      This option entails segregating used clothing and removing uncontaminated portions. Otto fuel
has a distinctive yellow color that facilitates identifying contaminated clothing.  Often, only small
areas of clothing are contaminated. Two methods could be used to deal with contaminated clothing:
(1) cut out contaminated sections of clothing and dispose of these sections as hazardous waste,
leaving the remainder of the clothing waste stream nonhazardous; and (2) use disposable sleeves
and leg  cuffs, allowing the remaining uncontaminated clothing to be salvaged.  These activities would
require a minimal capital outlay; savings would be realized in  reduced  disposal costs.

3.3.2  Automated Cleaning  of Parts and Fuel Tanks

      Automated cleaning of parts  and fuel tanks would result in  more efficient and faster cleaning,
smaller  amounts of hazardous waste liquids,  and smaller amounts of contaminated clothing. Three
dip tanks in the Mark 46 shop are to be replaced with automatic parts washers using biodegradable
cleaning liquids.  More extensive or complete automation of cleaning operations within the two shops
would aid in reducing wastes. This automation may include the use of an aqueous cleaning media in
an agitator or jet system, or an ultrasonic  cleaner.  While this option would  require capital outlay for
the purchase of a cleaning unit, it would allow for reduced disposal of cleaning solutions and reduced
raw materials purchased.  Payback period for this option is  0.4 years and is one of the two fastest
payback periods (total capital investment/net operating cost savings) represented  by these
recommendations.

3.3.3  Automated Fuel Tank Draining

      Automated fuel tank disassembly by robotics has been in use at the  Mark 46 shop since 1987,
resulting in more efficient and faster operations and smaller amounts of waste liquids and
contaminated clothing. During the  automated operations, fueling and  defueling are handled in a self-
contained closed unit, eliminating the need for frequent cleaning or decontamination and  decreasing
the occurrence of spills. At the time of the assessment, future plans at the  Mark 46 shop included the
use of a robot for rinsing fuel tanks, which would eliminate the need for nine pounds of DEC per tank
during cleaning. Similar equipment could be installed in the other shop and would have a relatively
short payback period due to decreased costs of labor, contaminated clothing disposal, and spill
cleanup.

3.3.4 Modification of the Deep Sink Draining Schedule

      Converting from automatic weekly draining  of the deep sinks to  an "as needed" schedule would
result in reduced cost due to a smaller purchasing volume of cleaning  solvents, reduced volume of

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 hazardous waste disposal and fewer manhours expended.  This option also has a very fast payback
 period, requiring schedule modification only and no capital outlay.

 3.3.5  Recycling of Mineral Spirits

       Mineral spirits used for parts cleaning are,currently treated as a RCRA hazardous waste
 combined with other liquid waste streams, and sent to an off-site treatment, storage, and disposal
 facility (TSDF) for incineration. This option proposes batch recycling of the mineral spirits generated
 in the Mark 48 shop, which would divert this stream from the general liquid waste stream. Otto fuel
 present in the spent mineral spirits would be destroyed through a heating process.  Hydrogen
 cyanide in the vent gas would be removed by a carbon adsorption unit, and the remaining liquid
 distilled to recover the mineral spirits.  Up to 86 percent of the spent solvent could be recovered
 through this recycling process. This option has a short payback period, involving moderate to high
 capital outlay for equipment but providing savings through decreased disposal costs and purchase of
 mineral spirits.

 3.4    RESEARCH, DEVELOPMENT, AND DEMONSTRATION

       The following five research needs were identified during the course of this assessment" (1)
 evaluate cost effectiveness of clothing with disposable sleeves and cuffs; (2) develop a test for
 determination of spent deep sink cleaning liquids; (3) evaluate the cost feasibility of using robotics for
 draining, defueling and rinsing torpedoes; (4) identify potential recycling options for waste hydraulic
 fluid; and  (5) evaluate current practices for used torpedo engine oil.
3.5
STATUS OF IMPLEMENTATION
      NUWC KPT DIV personnel have investigated two of the pollution prevention recommendations
identified in the PPOA:  (1) reduction of Otto fuel-contaminated clothing and (2) modification of the
deep sink draining schedule for the Mark 48 and Mark 46 shops.  NUWC KPT DIV concluded that the
first recommendation was highly labor-intensive, as it called  for physically cutting out contaminated
sections of clothing; this recommendation was not implemented.

      Rather than modify the deep sink draining schedules as recommended in the PPOA, a new
cleaner was developed in conjunction with  Exxon Corporation. This new product is an aliphatic
hydrocarbon cleaner known as Actreo  1171L Navy Cleaner.  The used cleaning solvent is sold as an
off-spec chemical product, thereby reducing disposal costs.  Additional savings have been achieved
by the installation of filters which extend the life of the solvent.  Currently, the tanks are emptied
twice a  month, but NUWC KPT DIV is  working to reduce this activity to once a month  in order to
reduce handling operations.

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                                        SECTION 4

                                DEPARTMENT OF DEFENSE
                                 TINKER AIR FORCE BASE
                         OKLAHOMA CITY AIR LOGISTICS CENTER

      The objective of this project was to identify and assess alternative processes that would enable
the Oklahoma City Air Logistics Center (OC-ALC) to minimize pollutant generation while meeting
overall mission objectives. This project, initiated  in 1991, was funded jointly by EPA and the U.S. Air
Force.

4.1   FACILITY DESCRIPTION

      The OC-ALC, located at Tinker Air Force Base (AFB) near Oklahoma City, Oklahoma, is one
of five logistic bases owned by the Air Force Material Command, the largest Air Force command in
terms of funding and employment.  The Center's  physical plant, located on almost 5,000 acres,
includes two runways, 20Q acres of ramp space,  118 acres of indoor maintenance area and almost
80 acres of covered warehouse storage space. Daily operations are conducted in over 700 buildings,
including an industrial maintenance facility which  approaches one mile in length.  The only inland
Aerial Port of Embarkation (APOE) in the continental United States, the OC-ALC employs over
22,000 civilian  and military persons, with 6,000 dedicated to depot-level repair, overhaul and
modification of aircraft jet engines and weapon system components.  The Center is host to several
major defense  missions,  including the Navy's E-6A Strategic Communications Wing One.

      The Center engages in a wide range of activities on a large scale.  OC-ALC's plating facility,
one of the largest in the world, has over 230 plating process tanks for plating metals, such a nickel,
chrome, and silver. Each year over 300,000 aircraft and engine components are repaired for return
to the field, and several more are produced from raw stock for use as spares. OC-ALC also offers
complete scientific, engineering, and industrial process laboratory services for DOD and other
government agencies.

4.2   AREAS  OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

      Four major chemical waste generators were evaluated:  (1) overhaul/repair processes
associated with chlorofluorocarbons (CFCs); (2) electroplating; (3) component cleaning;  and (4)
painting/depainting.  Processes generating these wastes are discussed in  more detail in the following
section.

4.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

      The following discussion summarizes several of the pollution prevention options identified at
OC-ALC.
                                             10

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  4-3.1  Ozone-Depleting Substance Alternatives

        At the time the PPOA was conducted, trichlorotrifluoroethane (CFC-113) was used to remove
  oily residue on fuel control bodies and other aircraft and engine components after they were cleaned
  with PD-680, a Type II solvent. A possible alternative involves using an aqueous or semi-aqueous
  cleaning system, such as  Freemont 776 detergent, in the existing spray washer or in an immersion-
  type washer.

        Other possible alternatives recommended in the PPOA include additional alternative
  degreasers, alternatives to use of aerosols containing chlorofluorocarbons, alternatives to use of
  CFC-113 in cleaning applications, and alternative refrigerants.

  4.3.2  Plating  Alternatives

       The silver plating process uses cyanide solutions in the plating and stripping baths significantly
  increasing the  cost of waste disposal.  Substitution of commercially available non-cyanide solutions
 for the copper  strike, silver stripping, and silver plating process steps could reduce disposal costs by
 $33 000 per year, with a payback period of about two years. A second alternative is to eliminate the
 need for silver plating.  Additional research is required to determine the viability of this alternative.

       Other plating-related pollution  prevention recommendations include alternatives to the use of
 perchloroethylene vapor to remove wax maskants from aircraft components after plating  Alternatives
 include conventional aqueous and semi-aqueous cleaners, an azeotropic blend of perchloroethylene
 and water, and a two-step  process using hot mineral oil and aqueous cleaning.

 4.3.3  Component  Cleaning Alternatives

       Vapor degreasers in the oil cooler overhaul process use perchloroethylene solvent to displace
 water on the components, remove oil residue from parts after testing,  and clean parts prior to
 painting.  The process generates waste  streams in the form of volatile organic compounds (VOC) and
 contaminated liquid solvent. Three alternatives were recommended to eliminate the
 perchloroethylene vapor degreaser: (1) aqueous cleaner power flushing and rinsing  of fin-type oil
 coolers; (2)  steam clean paint preparation for fin-type oil coolers; and (3) oven dryinq of core-tvoe oil
 coolers.                                                                              •

 4.3.4 Depaintinq/Paintina Alternatives

      Phenol/methylene chloride paint strippers are used at OC-ALC to remove various types of
 paint or top  coat from aircraft and components  being overhauled.  Depainting with solvents results in
 waste streams of liquid solvent, air emissions, and paint residue.  Some substitute  methods may
 cause surface damage or create coating-contaminated  media which must be disposed of as
 hazardous waste. One possible solution is a hybrid method, in which a solvent softener is used to
 prepare the coating, thus allowing a non-solvent depainting method to  perform more effectively.

4.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      Many  of the possible solutions identified by this project must be tested and further evaluated to
determine if  they would be adequate substitutes for the processes/substances in use at OC-ALC.
                                              11

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Toward this end, research was initiated to address two process areas at Tinker AFB: brush plating,
and cleaning and solvent alternatives.
                                      i
4.4.1  Brush Plating Implementation and Evaluation

      Chromium and nickel tank plating are used extensively in the engine overhaul and repair
process for the resizing of parts that have worn thin from service, usually due to metal-on-metal
contact.  The coating, which can be machined  back to the required dimensions of the part, provides a
hard surface with excellent protection against wear and corrosion.  The chromium and nickel tank
plating processes consist of several steps including degreasing, masking,  alkaline cleaning, etching,
plating rinsing, and demasking.  After plating,  each part must be machined back to its original
dimensions. The masking, demasking  and machining steps make the overall tank plating process
labor intensive, requiring numerous plating tanks to accommodate the workload. These tanks are
constantly heated, requiring a significant' quantity of energy. Additionally,  many of the plating
solutions contain hazardous materials that present an environmental threat due to the potential for
spills and leaks.

      One project was conducted to evaluate the potential of brush plating (electromechanical
metallizing or EM) as a substitute process for hard chromium and nickel tank plating, to reduce the
quantity of waste generated during the repair and overhaul of gas turbine  engines. The results
indicate that the nickel-based brush plating solutions  do not provide the hardness or (Taber) wear
resistance achieved by chrome plating.  ;Nickel-sulfamate brush plated coatings exhibited acceptable
fatigue results on specific base metals.

      A follow-on  study is being conducted to  address  two related areas:  (1)  the feasibility of
implementing  brush plating using alternate alloys as  a substitute for the hard chrome tank plating;
and (2) the potential of substituting Low;Hydrogen Embrittlement (LHE) zinc-nickel planting as a
substitute for  LHE cadmium brush plating, which is used during in-situ plating  of landing gear and
other aircraft high-strength steel.

4.4.2 Cleaning Alternatives Implementation and Evaluation

       Methods to reduce the use of methyl ethyl ketone (MEK) as cleaners and solvents in aircraft
 radome depainting operations are being evaluated.  A WREAFS-developed formulation of n-methyl-
 pyrrolidone, propylene carbonate, and  dibasic  ester is being evaluated through a life cycle
 assessment (LCA) to investigate the energy and environmental impacts of the product as a substitute
 for MEK in depainting operations.

 4.4.3 MEK Recovery/Reuse

       To reduce MEK-laden air discharged to the atmosphere, research is being conducted to
 evaluate a new pollution prevention technology,  i.e.,  a  regenerative adsorption system applicable to
 the adsorption of VOC.  This process captures the MEK on a resin adsorbent. The MEK is
 subsequently released with controlled  heat and recovered by condensation, and may be reused in
 paint stripping operations.
                                                12

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  4.5
STATUS OF IMPLEMENTATION
       The OC-ALC has been actively engaged in pollution prevention as a result of the PPOA
 conducted by EPA. Base personnel considered the assessment to be a thorough documentation of
 the OC-ALC's processes, containing reasonable economic analyses of potential pollution prevention
 projects.  In order for pollution prevention projects to receive Base funding, they must exhibit a
 minimum  payback  period of three years; to date,  the four recommendations identified  by the
 assessment have met this criterion.

 4-5.1  Ozone Depleting Substance Alternatives

       The assessment recommended use of alternatives for ozone-depleting substances such as
 CFC-113.  In response to this recommendation, the OC-ALC has replaced its vapor degreasing units
 with high-pressure washers using soap and water. The OC-ALC has reduced its use of ozone-
 depleting substances by 75 percent, from 600,000 pounds per year to 50,000 pounds per year  by
 implementing this recommendation.  It should be  noted, however, that the new detergent used'in
 these washers is sodium silicate-based.  Use of these washers and detergents has increased the
 amount of oily sludge generated from the washers.  This oily sludge waste is classified as a RCRA
 hazardous waste and must be hauled away and disposed of. The Base employs an outside
 contractor to haul away and dispose of the waste at an approved site in Oklahoma  However  OC-
 ALC is investigating ways to reduce this waste. In fiscal year (FY) 1995, OC-ALC plans to reduce
 the volume of sludge waste by employing a dewatering scheme proposed by Battelle.

       The perchloroethylene vapor degreasers used for component cleaning have also been
 removed and high-pressure washers have been installed.

 4.5.2  Plating Alternatives

       The  OC-ALC  has replaced the cyanide solution in all of their plating processes with a non-
 cyanide solution.  Commercially available, non-cyanide  solutions are used in the  copper strike  silver
 stripping, and silver plating process steps.

 4.5.3   Depaintina/Paintina Alternatives

       Depainting/painting operations, such as phenol/methylene chloride paint strippers were also
 targeted for pollution prevention.  Several pollution prevention alternatives have been implemented  in
 these operations,  including the following:

 •     Using benzyl alcohol in  place of phenol/methylene chloride
 •     Using high-pressure water instead of methyl chloride
 •     Replacing MEK with polycarbonates
 •     Testing a resin to capture and recycle MEK  used


      In 1993, the Base reduced its emissions  of perchloroethylene, MEK, chromium, methylene
chloride, and xylene  by 100,000 pounds (29 percent of the total emissions).  In addition  the
phenol/methylene  chloride emissions were reduced from 400 tons in 1992 to 40 tons  representina a
90 percent reduction.                                                        '           a
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      Finally,  in 1995, the Base plans to implement a high-pressure mobile robotic paint stripper, the
Large Aircraft Robotic Paint Stripper (LARPS).  Using high pressure and low volume, this unit will be
capable of stripping paint from assembled  airplanes without the use of volatile solvents.  Specifically,
LARPS will be able to electronically plot an entire aircraft to determine areas which require stripping,
and then strip the paint using a high-pressure water spray.  Areas not requiring stripping, as identified
through the plotting process, will  not be stripped.
                                                 14

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                                  SECTIONS


                          DEPARTMENT OF DEFENSE

                           SCOTT AIR FORCE BASE


A PPOA was completed in 1991 for three selected processes at Scott Air Force Base in

    ฑSi ฐ"!J^?*^1r!d.a Ve1quick payback (ฐ-24 vears). Changes identified in the
 n hn              M,                                -   years-    anges  e
 other two processes could lead to net reductions in operating costs of $5,000 per year.

 5.1   FACILITY DESCRIPTION


       Scott AFB is located near Belleville, Illinois. About 5,000 military personnel and 3 000 civilian*
 work and or live at the base. The base is part of the Military Airlift Command '(MAC] and I opeStes

 malnSd " ฃ%!ฃ* """" "'^ inC'Udin9 12 ฐ 9S WhiCh ™ ฐUtfiซ*d f'™n a"d


 5.2   AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS


          three processes selected for this project were (1) nondestructive inspection (NDI) of C-9


                                                                     * -
 5.2.1 Nondestructive Inspection


      Two test methods are used to inspect landing wheels for signs of fatique such as cracks or

 S^11""'4168, thf Prtrate t0 the SUrface- An ^y-curren't method^ used to inspecfthe

 current mlfhnH 1   * ^ ^^ ^^^ methฐd is used to check aป other "Bas  The eddy-
 ^umin ,m 1  f  ^ ™ ^^ CUrreni ln proximity to a conductive test specimen such as the

 generate w^ste a   meaSUr6S Impedance Chan9es due to discontinuities.  This activity does not
a suffident'oe^                "TT. immersing aluminum wheel halves in a penetrant tank for
a,S  D P*              the Penetrant to Permeate into discontinuities accessible from the
surface.  Parts are removed from the penetrant tank and are placed over a drip station where excess
penetrant drams back to the penetrant tank.  The wheels are rinsed in water and re immersed in an
          ....      ,                ซ     The parts are then soaked in a ueveiuutji inai
        a thin layer of solid material onto the surface, and are subsequently placed above the

•nortfiJf    3 *    to dram-  Excess solution is returned to the tank. The parts are dried at a
specified temperature, and are then inspected under ultraviolet (UV) light.  Cracks and imperfections
are ,nd,cated by fluorescent lines or spots. Following  inspection, parts are repaired or r^ectedlrom
service.
     Three1waste sir**ms are generated during the NDI process, including waste liquid penetrant

       " ? f' f? deVe'ฐPer-  The Penetrant tank is Periฐdically emptild and ra^taSed^ih
        Spent solution ซ drummed for disposal. The penetrant is classified as a D001 (flammable)
                                           15

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waste  although the flashpoint is above the 140ฐF criteria established for D001 waste.  Waste
penetrant is incinerated in a cement kiln.  A small amount of penetrant is lost to the sewage
treatment plant along with rinse water from the first rinse step.

      The emulsifier tank eventually becomes contaminated with excess penetrant that was not
removed during the rinse step.  The solution is changed approximately every six months.  The batch,
which is approximately 100 gallons, is transferred to the sewage treatment plant through a floor dram.
In addition  small amounts of emulsifier drain to the sewage treatment plant along with the post-
emulsion rinsewater.  The solution is not hazardous, although the manufacturer recommends
disposal by incineration.

      The  developer solution also becomes contaminated, primarily with penetrant, and is changed
following the same schedule as the emulsifier tank.  The developer solution contains high levels of
sodium chromate and is classified as a D007 hazardous waste.  Despite hazardous characteristics,
each 100-gallon batch of developer solution  is  sent to the sewage treatment plant through a floor
drain.

5.2.2  Paintinq/Depaintina/Parts  Cleaning Operations

       The paint shop processes all aerospace ground equipment for Scott Air Force Base. Before
painting parts are either dry-sanded or dipped into a bath of stripping solvent.  Stripping solvent
becomes contaminated with paint sludge and is disposed of off site as a F002 hazardous waste.
Parts which require a clean, grease-free surface for further processing are taken to the Clean Shop,
where they are immersed in a bath of Safety Kleen degreaser for 45 minutes, followed by scrubbing
and rinsing.  Contaminated degreaser solution is removed by Safety Kleen, Inc., and is recycled and
 redistributed back to customers.  The solvent consists primarily of mineral spirits and is classified  as
a D001  hazardous waste because of its 105ฐF flash point.

       Following degreasing, some parts, such as aluminum alloy landing wheels, are dipped into  a
weak acid solution to remove oxidized metal from the surface.  Following the acid bath the parts are
 dipped into a corrosion inhibitor.  Both the acid and corrosion inhibitor solutions are replenished as
 needed; neither solution generates a waste stream.

       The paint shop uses approximately 24 gallons of paint per year.  About 90 percent of the paint
 is polyurethane, with the remainder consisting of various lacquers and varnishes.  Wastes generated
 include overspray solids, booth compound, booth wastewater, waste  paint and thinner, and VOC.
 Paints are applied with spray guns in water curtain booths. When used properly, the spray guns
 typically transfer about 50 percent of the coating to the target surface.  Solids contained  in the
 overspray become entrained in the water curtain and accumulate as floating scum or sludge.
 Approximately 220 gallons of solids are drummed and hauled away each year. Booth water is
 drained and replaced every two months; contaminated water is transferred to the sewage treatment
 plant without the addition of treatment chemicals.  In addition, the protective film  coating which is
 applied to the metal booth walls  to prevent the adhesion of paint materials eventually deteriorates
 and peels from the surface.  This material is discarded in a sanitary  landfill.  Paint thinner used to
 clean paint gun nozzles is discarded along with unused paint.  These wastes are  placed in 30 gallon
 drums for disposal by Safety Kleen, Inc. VOC are released during paint application, and are not
 controlled at the facility.  The amount of VOC generated depends on the amount and composition of
 paint used.
                                                16

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  5-2.3  Printed Circuit Board Manufacture,

        Scott AFB maintains a laboratory-scale circuit board production facility.  The proprietary
  process generates three principal wastes, including an electrons copper solution, sodium persulfate
  so ution, and ammon.um persulfate solution.  The sodium persulfate and ammonium persulfate
  ^nSSfmay w ^rOSIV?- hazardous wastes (D002)-  The electrons copper solution probably
  contains formaldehyde, a listed nonacute hazardous waste (U122).

  5.3    POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

and
 5.3.1  Nondestructive Inspection
                                                         Nฐ'' P-nting/depainting/parts cleaning,
      f NDcS ฐf P,rimary intereSt because of its wide-sPread use throughout the military and airline
        '    HVf   ฐPtl0nS WT6 identified' With the most feasible ฐPtions bein9;  0) altering the
 dvelo         feP    ^  S     3nd deVelฐPer h the tankS' and (2) using a ^ silica-based
 5.3.1.1
            Alter Replacement Method-
       Emulsifier and developer tanks are currently emptied every six months. Since the primary
          nh   ,   at ฐrfnear,!he SUrfaCe ฐf both solutions- jt was recommended that the Cng
 fre<,     I"1"16,   rฐm the SUrfaCe by insta"ing a drain valve on the side of thซ tank and adding
 fresh splut on  Twenty five percent of the tank's contents would be removed every six months and
     H ™ 1"k W0uldhbe drained onlV once every two years, extending the lifetime^ thTbath  This
            !" 3 ^  ฐ^ '^^ * *"* three mฐnths' A quality assurance/quality control (QA/QC)
 are e     adSd to6?'? ^f ^ to- 6ValUate th'S ฐPtiฐn- The Skimmin9 and removal
 are easily adjusted to suit specific requirements.

 5.3.1.2       Dry Silica-Based Developer-
in maron               i                      Use a dry, non-hazardous silica-based developer
in place of the wet chromate solution.  Dry developer solution is applied in an enclosed booth by one
of   o methods. (1) a swir. cloud, whereby the part is placed in a shallow tank above a bed of dry
      P      fฐH lsHsubs,ec1uent|y exPanded with air; or (2) a dynamic cloud, which subjects the part to
       P TH-   dry*   elฐT ^Im"ar t0 3 Painting ฐperation-  Excess Particulate is collected by a f Hte?
system  This system meets the same technical specifications as the wet developer and would
fZSSJSf ^f f?H the^Ket Chrฐmate Sฐ'Uti0n-  However' its use would reW™ additional space for
a dry developer booth and the capital  costs are high in relation to the dollar savings.
5-3.2  Painting/Paint Removal/Parts Cleaning
romoปfK ^ฐIIUti0l1  prevention ฐPtions were identified for this area, including alternative coating
removal methods, replacing wet spray booths, and replacing spray guns.
                                             17

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5.3.2.1       Alternate Coating Removal Methods-

      A plastic media blasting (PMB) method has been suggested to replace solvent-based coating
removal operations.  At the time of the PPOA, the PMB equipment was located on site and lacked
only a few minor fittings before operation could begin.

5.3.2.2       Replace Wet Spray Booths-

      A comprehensive water treatment program for the wet spray booths was recommended, which
included the addition of coagulant to reduce sludge disposal frequency and costs.  Alternatively,
converting the paint booths to a dry operation would eliminate the generation of sludge and
wastewater. Overspray solids in a dry system are collected by filters, which must then be disposed
of.
5.3.2.3
Replace Spray Guns--
      The use of HVLP paint guns reduces the amount of overspray to about 10 to 20 percent, and
substantially reduces VOC emissions.  More efficient paint application results in smaller volumes of
paint being used and less waste generated.  Additional options for reducing VOC emissions include
the use of powdered coatings and/or the use of electrostatic spray systems.

5.3.3 Printed Circuit Board Manufacture

      The manufacturing process for printed circuit boards is complex and closely regulated, making
it difficult to modify. Recommendations for pollution prevention include the substitution of a reducing
agent such as sodium hypophosphite for the electroless  copper plating solution, which would
eliminate the use of formaldehyde, or the recovery of copper from spent electroless plating solution
with the use of sodium borohydride precipitation followed by filtration.

 5.4           STATUS OF IMPLEMENTATION

       Scott AFB has acted on many of the recommendations made in the PPOA. The main pollution
 prevention opportunity concerned changing the standard operating procedures for the emulsifier and
 developer tanks  The recommendation called for skimming contaminants and replacing lost solvent
 instead of emptying the tanks. The AFB purchased an oil/water separator for use in the skimming
 operation; however, installation could not take place due to the major renovation work required.  The
 process, including the separator, will  be moved to a new facility in Hanger 1.  The AFB is conducting
 many general pollution  prevention projects including:

 •     Using a waste oil burner to heat buildings
 •     Converting some vehicles to natural gas
       Implementing an R-134 recovery system
       Instituting  environmental training programs

       One  pollution prevention project of interest is the establishment of a hazardous materials
 pharmacy supply.  Since all hazardous materials entering the AFB must be checked into and out of
 the pharmacy  the  pharmacy acts as a tracking system  for all hazardous materials on the Base. This
 system tracks movement of materials and can identify unnecessary material purchase and
 movement, thereby reducing waste.    :
                                               18

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                                          SECTION 6

                                  DEPARTMENT OF DEFENSE
                                AIR FORCE PLANT NUMBER 6

 ปซ,OCAO  prqiectl comP|eted in 1991- evaluated emulsion cleaners as an effort related to the
 WREAFS program.  The purpose of the project was to provide assistance to Air Force Plant No 6
 personnel by documenting relevant  work by other aircraft fabrication facilities.

 6.1   FACILITY DESCRIPTION

       Air Force Plant No. 6, located in Marietta, Georgia, is operated for the Air Force by Lockheed
 Aeronautical Systems Company.  The facility is part of the Aeronautical Systems Division (ASD),
 headquartered at Wright-Patterson Air Force Base near Dayton, Ohio.

 6.2   AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

       ™s facility operates six vapor degreaser units that use trichloroethylene (TCE) to prepare
 steel and aluminum parts for a variety of subsequent manufacturing steps in the production of C-130

 6*50000 noElmaiSn1' THmillLฐn ^"^ ฐf TCE **" "** ln  1988= thJS ^e decreased *> ^bout
 650 000 pounds in 1990. Th.s decrease was primarily due to reduced production and workload at
 cleaned         ^ * t0 eliminate  TeE use comP|etely by substituting a water-soluble emulsion


 6.3    POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

   .    Concerns about the detrimental effects of TCE  on worker safely and health as well as
 riSSH f nTฐ"meTn'al .imPf ts' have led to an intere*t in substituting less damaging, water-soluble
 cleaners for TCE.  The initial stage of this project  reviewed research conducted by Boeing Aircraft

 4ea^rnmn  TlS? f^?*^ (AFESC)' ฐฐE'  General Dvnamics- Lockheed Missile and
 Space Company (LMSC), Martin Marietta, and  Northrop, on the substitution  or elimination of solvent-
 based cleaners  Boeing Aircraft is evaluating the performance of a given substitute during actual
 aircraft production. One of AFESC's projects evaluated the substitution of cleaners with
 biodegradable solvents, involving field testing at Tinker AFB in Oklahoma.  Enhancement methods
 ^"^s ultrasonic and mixer agitation at various temperatures were evaluated as part of that study
 The DOE is evaluating substitutes for performance and corrosion.  General Dynamics originally
 evaluated forty substitutes and has narrowed the list to four candidate cleaners for further
 consideration.  LMSC and Martin Marietta evaluated substitutes for 1,1,1-trichloroethane (TCA)  use in
 vapor
      The criteria by which substitute solvents were evaluated in the initial stage of this project
include the following: pH level; corrosiveness; cleaning ability; corrosion between fraying surfaces'
foaming; effect on cadmium-plated surfaces; effect on adhesion; water break-free; visual  etching  '
ability; sandwich corrosion; intergranular attack; corrosion resistance; paint adhesion- and sulfur
phosphates, and chromates content.  Of the ten cleaners targeted for evaluation as substitutes for
                                            19

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halogenated solvents, six were selected by one or more of the evaluators for implementation or
further evaluation.  Five were eliminated due to phosphates, flammability concerns, non-recyclability,
or unacceptable etching of the magnesium substrate.

6.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      EPA is continuing to work in cooperation with Lockheed and the Air Force Aeronautical
Systems Division to investigate the potential for implementing emulsion cleaners as a replacement for
TCE  Lockheed has selected cleaner Brulin  815 GD for pilot testing. The successes, problems and
costs associated with using a substitute degreasing solvent and alkaline cleaner will be documented
and the information transferred to similar facilities  in the DOD and DOE. This may expedite the use
of emulsion cleaners at other facilities.
6.5
STATUS OF IMPLEMENTATION
      After pilot-testing Brulin 815 GD to replace TCE as a parts cleaner, Air Force Plant No. 6 has
 modified one of its process lines utilizing an 800-gallon tank for the use of this emulsion cleaner.
 The savings have been substantial in terms of waste disposal and  process time, although specific
 data are currently not available to quantify these savings. Two additional lines containing a 3,400-
 gallon and 15,000-gallon tank are waiting to be modified.

      Air Force Plant No. 6 has instituted other general pollution prevention  measures, including the
 measures outlined below.

      As of April 1994, all ozone depleters have been replaced. TCE has been replaced by Brulin
       815 GD; TCA has been replaced by alternative solvents Shopmaster RC and D108; CFC-113
       has been replaced by a process change to soap and water.

       Paints have been replaced by low VOC, lead-free, waterborne paints.

       Cadmium plating has been abolished.

       Use of methylene chloride has been eliminated  through process changes; alternatives are
       being sought for MEK.
                                              20

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                                          SECTION?
                                  DEPARTMENT OF DEFENSE
                                         FORTRILEY

       This project was a PPOA conducted at the U.S. Army Forces Command (FORSCOM)
 maintenance facilities at Fort Riley, Kansas in 1990.  Ten other FORSCOM installations provide
 potential for application of similar pollution prevention options.

 7.1   FACILITY DESCRIPTION

       Fort Riley is a U.S. Army FORSCOM installation in north-central Kansas that provides support
 and training  facilities for the 1st Infantry Division (Mechanized), Non-Divisional Units and tenant
 activities  Fort Riley provides the Army with the capability to house and train an Army division and
 associated land combat forces,  as well as to service Army functions in the midwest area.

 7.2   AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

       At Fort Riley, large hazardous waste streams are generated, consisting of spent automotive
 cleaning solvents and various RCRA listed wastes, including waste battery acid, waste caustic
 ceaners and spent parts wash water.  Currently the waste battery acid is collected in 15-gallon
 plastic drums, and caustic cleaners are collected in 55-gallon metal drums.  Both are classified
 wastes and are sent by truck to the hazardous waste storage facility.  Wastewater from the
 automotive parts washer is discharged to an on-site nonhazardous waste evaporation pond system.
           areasHwere/f'ected for evaluation: the battery repair and service shop, which generates
 w         ^ r  ' T  the,au omotive subassembly rebuild area, which generates waste automotive
 washwater and spent caustic cleaner.

 7.2.1 Battery Repair Shop
amซ      , !rฐ1! car/nd truck batteries consists of 32 to 37 percent sulfuric acid containing trace
amounts of lead and cadm.um. This material is drained from batteries which are no longer in service
       ne [6Pair' fnd,'S Shipped in 15-gallon drums to the Defense Reutilization and Marketing
      (DRMO)  storage facility for ultimate disposal as hazardous waste (D002  D006  D008)  The
ba tery service area drains about 7,200 gallons per year of battery acid for disposal. The drained
^hefieShaS 'nVerted.'  a?.d 6ither diSpฐSed ฐf if determined to be unusable,  or repaired and refilled
with fresh 37 percent sulfuric acid,  recharged and reused.

7-2-2  Automotive Subassembly Rebuild
th. iinPriortฐrebuilding vfrious automotive subassemblies (e.g., engines, clutches, transmissions)
the units are disassembled and placed in a specially designed high pressure hot-water washer for
cleaning.  This washer continuously circulates hot alkaline solution through high-pressure jets to
                                            21

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provide the cleaning action. The solution has a pH greater than 12 and contains trace concentrations
of lead chromium, and cadmium, in addition to the oils, grease, and dirt removed from the
automotive parts.  In the past the waste was drained to an onsite nonhazardous waste evaporation
pond. However, because of its characteristics, this waste is being reclassified as RCRA D007 and
D008 waste and will have to be disposed of as hazardous waste.

7.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

      The pollution  prevention  options recommended for Fort Riley are recycling and reuse options,
as described in the following paragraphs.

      Recommended  pollution  prevention options include recycling of waste battery acid from cars
and trucks, and recirculation of washer wastewater. Recycling  both the battery  acid and the
wastewater would cost about $35,000, resulting in an annual operating cost savings of about
$149 000  Payback period for  simultaneous implementation of the two options would be less than
five months. Adequate testing  of refortified, recycled battery acid and monitoring of the detergency of
the washer wastewater would be required.

7.3.1 Recycling  of Waste Battery Acid

      After collection, the waste battery acid would be transferred to an acid-resistant tank and
mixed by recirculating pumps.  The acid strength would be adjusted to 37 to 38 percent H?SO4 using
78 percent sulfuric acid  (60ฐ Baume) as needed to yield standard battery acid.  This refortified acid
would be pumped through an acid-resistant filter to remove particulates and would be collected in
drums for use in the battery repair operation. Recycled acid could be used in place of virgin materials
in reconditioned or new batteries.  To  prevent accumulation of dissolved  metals, 25 percent of the
used acid would be purged, neutralized, treated for heavy metal removal, and disposed of as
nonhazardous waste to an onsite  lagoon.

7.3.2 Recirculation of Washer Wastewater

      The proposed pollution prevention option for the metals-contaminated alkaline wastewaters
 involves using equipment external to the; automotive parts washer for purifying  the alkaline detergent.
 Cleaned alkaline  detergent solution would be reused for further automotive parts cleaning operations.

      The proposed process includes emulsion breaking to cause emulsified oils to float. De-
 emulsified oils and other tramp oils and grease are removed by skimming, while suspended
 particulates are removed  by filtration through an in-line cartridge filter. After adding fresh alkaline
 detergent as necessary, the recycled washwater would be returned to the automotive parts cleaner.
 As with  the proposed system for recycling battery acid, the buildup of impurities would be prevented
 by purging 25 percent of the used washwater, and recycling the remaining 75 percent.  Purged
 alkaline washwater would be neutralized with an appropriate amount of waste battery acid, treated to
 remove heavy metal  impurities, and disposed of as a nonhazardous waste.

 7.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION

       Proposed  particulate filtration and de-emulsification processes would qualify as research,
 development and demonstration projects.  In-plant experimentation is necessary to determine such
 operating and design details as the appropriate type of filter elements for this operation, the number

                                               22

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 of cartridge filters needed to provide a clean solution, and the number of times the washwater can be
 recycled while still maintaining its cleaning effectiveness.
 7.5
STATUS OF IMPLEMENTATION
      Fort Riley has not implemented the measures recommended by the PPOA at the present time
 Upon review of the report, Fort Riley personnel determined that the options recommended were not '
 appropriate for the processes on the site. Specifically, they felt that the recommendation to reuse or
 recycle and filter the solution from the parts washer was not appropriate because the PPOA
 recommendation was based only on the alkalinity of the parts washer solution  and did not address
 the alkalinity of the detergent used in this process.  The detergent is the active ingredient in the
 solution and Fort Riley personnel believe it should have been considered when investigating potential
 pollution  prevention options.                                                     a   an

      It was also recommended that this solution be mixed with the waste battery acid to neutralize
the acid.  This option was considered, but it was determined that the alkalinity of the parts washer is
not strong enough to effectively neutralize the acid.  Fort Riley personnel have instead decided to
discontinue the practice of draining acid from batteries, and instead, will ship the batteries wet  This
will significantly decrease the amount of waste battery acid the personnel must handle and dispose
                                             23

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                                        SECTION 8

                                DEPARTMENT OF DEFENSE
                          FITZSIMMONS ARMY MEDICAL CENTER
                           OPTICAL FABRICATION LABORATORY

      A PPOA at the Fitzsimmons Army Medical Center (FAMC), Optical Fabrication Laboratory
(OFL) near Denver, CO was completed in 1991.  The facility generates three RCRA hazardous
wastes; pollution prevention options were developed for two of the three wastes.

8.1   FACILITY DESCRIPTION

      The OFL produces about 1,400 pairs of spectacles per month, with 85 to 90 percent of the
production involving the fabrication of glass lenses. The remaining 10 to 15 percent involves plastic
lens fabrication.

8.2   AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

      The areas primarily involved in the PPOA were the glass and plastic lens fabrication, where
uncut lenses are received from optical suppliers and  are matched with eyeglass prescription orders.
Lenses are precoated with a polymer film of volatile solvents containing MEK, methanol, and ethanol.
Precoated lenses are blocked, ground to desired curvature, washed, and deblocked.  Cleaned lenses
are then ground to fit frames, chemically hardened, and placed in frames.

      Glass lens fabrication operations at the OFL generate three RCRA hazardous wastes,
including waste lead-bearing lens blocking alloy (RCRA D008), alkaline washwater from ground and
polished lens cleaning and deblocking operations (D002), and spent Stoddard solvent from the tool
cleaning operations (D001). Additionally, one nonhazardous waste is generated, consisting of ground
glass fines from lens grinding and polishing operations.  These wastes were recycled to the  extent
possible, but OFL was particularly concerned about the alkaline washwater from lens deblocking
which contains  particles of lead-bearing alloy,  as well as the hon-hazardous ground glass from
grinding operations.

      Waste lead-bearing blocking alloy particulates are reclaimed and recycled at the OFL.  Spent
Stoddard solvent is recycled offsite by Safety-Kleen,  Inc. The PPOA  primarily focused on the
alkaline washwater from lens deblocking which contains particulates of lead-bearing alloy, and the
nonhazardous ground glass fines generated during grinding operations.

      Alkaline washwater which has a pH of 13 to 14 is discharged periodically from the glass-lens
washing machines at the rate of approximately 200 gallons per month. The washwater passes
through a trap to collect large particulates  of lead-bearing lens blocking alloy, and is discharged to
the onsite wastewater treatment plant. Effluent from the treatment plant is ultimately used to irrigate
the FAMC grounds,  which could result in the discharge of lead to the groundwater underlying the site.
                                             24

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        Lens grinding operations generate approximately 37.5 tons per year of a mixture of waste
  glass fines and water.  The nonhazardous ground glass fines are collected from the onsite grindinq
  coolant filtration operations for disposal at a local sanitary landfill.  These fines, when dry could
  generate particulate emissions, thus creating possible inhalation problems during transportation if
  they are transported in uncovered or improperly covered containers, or at a landfill if they are
  improperly covered or managed.

  8.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

       The nonhazardous glass fines were examined from a recycle standpoint, eliminating a disposal
  cost.  Several options were considered for the RCRA suspect hazardous materials in the alkaline
  wastewaters.

  8.3.1  Glass Fines

       Fine glass particulates may be used as feedstock for glass or ceramic tile production
 Although transportation costs would limit the marketable area, this option would result in an  annual
 savings of up to $1,000 by eliminating  landfill disposal costs.

 8.3.2  Alkaline Wastewaters

       Two options were recommended for the alkaline wastewaters:  (1) substitution of a non-lead
 bearing blocking alloy and (2) filtration  of wastewater prior to disposal.

 8.3.2.1       Substitute Blocking Alloy-

       This option  may not be economically feasible.  Although a technically adequate alloy substitute
 exists, its use would increase operating costs by $33,000 per year.
 8.3.2.2
Wastewater Filtration-
       In this option, submicron-size particles would be captured by a cartridge filter installed in the
 line leaving the trap from the lens washing/deblocking operation.  Installation of a cartridge filter in
 the wastewater line could cost less than $500, and result in annual savings of over $1 000  This
 technique could  recover up to 500 pounds per year of lead-bearing alloy that would ultimately be
 recycled to the lens blocking operation.

 8.4    RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      Three specific needs were identified as a result of this study (1) develop a milder glass
cleaning solution to replace the alkaline one; (2) assess the feasibility of developing another less
costly blocking alloy containing  no toxic metals (e.g.,  lead); and (3) develop and/or adapt an aqueous
cleaner for tool cleaning operations to replace Stoddard solvent.
8.5
STATUS OF IMPLEMENTATION
      The OFL has been involved with a wide range of assessments for pollution prevention
opportunities, having spent considerable staff time researching potential alternative methods related
to optical fabrication procedures that produce waste streams of concern.
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      Several of the waste streams cited in these studies are the subject of a joint
EPA/Navy/industry cooperative research and development agreement (CRADA) to be completed in
1995. The CRADA, which involves the EPA Office  of Research and Development's (ORD's) RREL,
the Navy Ophthalmic Support and Training Activity  and Gerber Optical Incorporated, is studying the
wastes generated from the use of Gerber's "Step One" Surface Blocking System to  prepare lenses
for surface generating (grinding).  Pollution prevention alternatives for lens blocking  materials and
other related substances are also being assessed under this effort. Any promising results obtained in
these studies may also be considered for use at the Fitzsimmons OFL.
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                                          SECTION 9

                                 DEPARTMENT OF DEFENSE
                                       FORT CARSON
                                EVANS COMMUNITY HOSPITAL

       A PPOA at the Evans Community Hospital (ECH), completed in 1992, evaluated xylene,
 ethanol and methanol waste streams generated in the hospital's histology and hematolqgy
 laboratories.

 9.1    FACILITY DESCRIPTION

       The Fort Carson ECH is located in Colorado Springs, CO.  The histology and hematology
 laboratories perform human tissue processing and slide staining for histologic and cytologic
 evaluations to support clinical diagnoses.

 9.2    AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

       The histology and hematology laboratories dispose of approximately 40, 66, and 63 gallons per
 year of xylene, ethanol and methanol, respectively.  These solvents are primarily used during human
 tissue processing and slide staining. The method of disposal at the time of the assessment was by
 transport and incineration. Cross contamination of xylene and ethanol occurs during tissue
 processing and slide staining in the histology laboratory, thus, the wastes cannot be easily separated
 It is possible for the hematology laboratory's methanol to be kept separate from the other wastes;
 however, at the time of the assessment,  all three solvents were mixed in the same drum for disposal.

 9.2.1 Tissue Processing

      The histology laboratory's automatic tissue processing equipment employs one solvent
 reservoir 0.4 gallons of xylene and two solvent reservoirs 0.9 and 0.2  gallons of ethanol. These
 baths are emptied on a weekly basis and are replaced with fresh solvent.  Waste xylene and ethanol
 are pooled together with significant volumes of waste methanol from the hematology laboratory.  The
 wastes are placed in 55-gallon drums for eventual transport by a disposal contractor.

 9.2.2 Slide Stamina
                                                           •      • - "
      Automatic slide staining equipment in the histology laboratory uses three 0.2-gallon solvent
 reservoirs, two containing xylene and one containing ethanol.  The  ethanol bath used during slide
 staining of histologic or cytologic specimens  is changed weekly.  The xylene baths are operated in
 series on a weekly rotating basis, in that  the first bath is discarded, the second bath is moved
 forward to replace the first bath, and a fresh  xylene reservoir replaces  the second bath which has
 been rotated forward. As described above, waste xylene and ethanol are placed in 55-gallon drums
for disposal. Methanol is used for slide staining and other purposes in the hematology laboratory,
and is pooled together with the other solvents for disposal.
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9.3   POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

      The two pollution prevention options identified for xylene and ethanol used in the histology
laboratory included (1) solvent substitution and (2) solvent recovery.

9.3.1  Solvent Substitution

      Xylene substitutes are available for laboratory applications. Although little information is
available regarding the toxicity of these substitutes, the primary hazardous constituents are aliphatic
petroleum distillates,  classified as D001 (flammable) hazardous waste.  A program was conducted at
ECH to evaluate available xylene substitutes.  Results indicate that the substitutes are nondrying  to
skin, leave no oily residue for faster and easier slide cleaning, and allow for complete paraffin
infiltration,  rendering  tissues less brittle than xylenes.  However, preference was shown for continuing
the use of xylene primarily because'the substitutes are not as effective at tissue cleaning and are
relatively expensive.  Furthermore, xylene is still the preferred choice because of its maximum
paraffin infiltration of tissues, which results in greater specimen visibility and enhanced  microscopic
examination.

9.3.2 Solvent Recovery

      At the time of the PPOA,  xylene, ethanol, and methanol wastes generated by the histology and
hematology laboratories were being  mixed in a single drum for disposal. To implement a solvent
recovery program, it would be necessary to keep the solvents separate to maximize their potential for
recovery and reuse.  While methanol used in the hematology laboratory can be segregated from the
other solvents, xylene and ethanol will always be mixed because of cross contamination which occurs
during tissue processing.  The only method available to effectively separate these solvents is
distillation.  Solvent distillation either by spinning band or atomized plate techniques can offer efficient
separation of the laboratory solvents, although pure ethanol  can never be effectively separated from
a mixture of ethanol and xylene. A procedure has been suggested by which ethanol reclaimed  using
distillation  methods (usually 95  percent pure) is used in all containers except the final rinse bath,
which would be filled with fresh (absolute) alcohol.

      Due to a relatively high initial  investment, a solvent recovery system is economically attractive
for laboratories with a large throughput (at least 8,000 slides per month).  Solvent recovery has a
payback of 97 months for laboratories similar in size to the histology laboratory at ECH, which
processes between 1,000 and 8,000 slides per month.

9.4   RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      Additional research is required regarding the potential hazards and safe use of xylene
substitutes. Since substitutes were not identified for methanol, a program should be implemented at
ECH to segregate the methanol wastes.
 9.5
STATUS OF IMPLEMENTATION
 9.5.1 Solvent Substitution

      ECH has initiated a solvent substitution program as recommended. Two replacement solvents
 are used in the vacuum infiltrator processor, with trade names "Prosoft" (alcohol substitute containing
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 propylene glycol ether and ester and propanol) and "Propar" (xylene substitute containing propylene
 glycol ether and alkanes).  The rationale for this substitution is the reduction of toxic constituents in
 the laboratory waste stream. Xylene use in this  process is estimated to have been reduced by
 two-thirds.  The remaining xylene use is located  in a single station on the processor which is used for
 purging the equipment after a day's use. Xylene is also still used to clean paraffin from slides after
 mounting of tissues.

       Some issues have been encountered regarding the long-term suitability of the replacement
 solvent products, including their possible involvement in the deterioration of seals, which may have
 contributed to machine malfunctions, and the inability to obtain support for the use of substitutes from
 makers of planned replacement equipment.  The latter issue appears to  have been resolved, as the
 manufacturer of the processor has recently determined that the two substitute solvents named above
 are appropriate for their current uses at ECH.  The only other ECH observation regarding the
 substitute solvents is that it takes somewhat longer to process specimens than with the original
 solvents. At current production levels,  this  is not a problem for ECH,  since the processor is an
 automatic unit which is currently set up at the end of the work day and programmed to run  overnight.

 9.5.2 Solvent Recovery

      Installation of distillation equipment was considered and rejected due to lack of capital and
space constraints. Waste solvents from the histology laboratory are now stored in two separate
containers (one containing xylene, ethanol and Prosoft, the other containing Propar) rather than being
completely  co-mingled.
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                                        SECTION 10

                           DEPARTMENT OF VETERANS AFFAIRS
                       CINCINNATI-FORT  THOMAS MEDICAL CENTER

      The pollution prevention opportunities identified at the Department of Veterans Affairs'
Cincinnati - Fort Thomas Medical Center (VA-Cin) in 1991  focused on ways to reduce the discarded
medical supply waste stream.

10.1  FACILITY DESCRIPTION

      The VA-Cin is a government-owned general medical and surgical hospital. The facility
maintains 415 authorized and 342 operating beds and is large in comparison to  other private and
federal hospitals.  The facility provides outpatient services for approximately 500 individuals  per day.
In addition to the medical waste generated on-site, the facility also manages wastes for an
associated research facility, nursing home, and home health care services.

10.2  AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

      The pollution prevention assessment investigated the use of disposables in patient care to
identify future opportunities to minimize solid  wastes.  Because the unit cost of disposing infectious
waste far exceeds general waste disposal costs, VA-Cin already practices effective pollution
prevention by segregating  infectious from non-infectious  wastes and by using durable cloth gowns
and drapes instead of disposable paper products.  The VA-Cin facility produces about 0.6 pounds of
infectious waste per patient per day, which is low compared to the typical range of 0.5 to 4 pounds
for  most hospitals.  Unlike some states, the state of Ohio allows the disposal of laboratory wastes
together with the general waste stream provided that the laboratory wastes are sterilized first.
Adding autoclaved laboratory wastes to the infectious waste stream would increase the daily
generation rate to 0.87 pounds per patient.

      Hospital wastes consist primarily of disposable products.  Approximately 80 percent of the
hospital supplies at VA-Cin are disposed of after a single use.  The use of disposables  has increased
over the last few years in response to concerns over patient safety and staff occupational exposure
to the AIDS virus.  In contrast to the sharp increase in disposables which occurred  10 to 15 years
ago, primarily as a result of the development of new disposable products, the recent increase  in
disposables reflects a greater use of existing  products. The preference for disposables includes cost,
convenience, improved quality assurance/quality control of manufacturing, avoided constraints on
space and staff associated with  reprocessing reusables, and health and safety assurance for sterile
integrity.

      The largest consumers of disposables  at VA-Cin include the following departments:  Laboratory
Services; Surgery; Surgical Intensive Care Unit (SICU);  5 South (a patient floor); Medical Intensive
Care Unit (MICU);  Hemodialysis; and the Outpatient Clinic.  The Supply, Purchasing  and Distribution
Department, the Laboratory, and the operating room account for 85 to 90 percent of all disposables
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 used in the hospital. The two general types of disposable supplies used are plastics and paper (non-
 woven) products.
 10.2.1
 Laboratory Services
       This department consists of four laboratory areas:  hematology, clinical chemistry,
 microbiology, and histopatholbgy.  In a nine-month period ending June 30, 1989, the laboratories
 conducted 41,097 venipunctures, 9,935 bacterial cultures, 4,730 blood cultures,  854 fungal cultures,
 and 815 tuberculosis cultures.

       The hematology laboratory staff draw and analyze blood samples from 50 to 60 patients per
 day.  Hematology generates two 30-gallon bags of infectious waste each day, which is rendered
 noninfectious via autoclaving and is disposed of as general trash.  Sharps (needles, broken glass)
 are placed in special containers and are incinerated weekly.                       .

       Clinical chemistry staff conduct urine and blood serum analyses, and also generate two 30-
 gallon bags of autoclaved waste each day.  The microbiology  laboratory generates at least three 30-
 gallon bags of autoclaved trash each day, consisting primarily of glass products.

       Staff at the histopathology laboratory analyze tissue specimens and body  parts,  producing no
 more than one five-gallon  trash bag of infectious waste per day. Pathological wastes and disposable
 specimen containers are incinerated on-site.                         ,
10.2.2
Surgery Department
      Approximately 15 operations are performed daily, with wastes carefully segregated as they are
generated. The surgery department generates between one and two 30-gallon  bags of waste blood
and body fluids per operation. An estimated 70 percent of the waste volume consists of
contaminated paper waste.  Examination gloves and surgical sponges represent the greatest volume
of single-use disposable items in the waste stream.  Blood and body fluid wastes are collected by a
contract infectious-waste hauler for off-site treatment and  disposal.  Sharps are placed in special
containers and are incinerated on-site.

      Operating room packs, prepared with all disposable products necessary for the particular
operation, are also used in the surgery department.  The packs are generally used in full, although
occasionally some items are disposed of unused.
10.2.3
Surgical Intensive Care Unit
      The SICU maintains eight beds.  The unit uses cloth gowns and reusable procedure trays,
although staff have indicated that they would prefer to use the disposable packs similar to those'used
in surgery.  Waste is segregated into three categories: sharps; blood and body fluid wastes, which
consist mainly of suction liners and tubes; and general trash.  Sharps are packaged in special
containers and are incinerated on-site.  Blood and body fluid wastes are strictly segregated  into one
or two 30-gallon  bags per day.  However, for patients requiring isolation, SICU may generate as
many as ten five-gallon bags of waste per patient per day. Blood and body fluid wastes are collected
by a contract infectious waste hauler for off-site treatment and disposal. Foley bags and chest tubes
are flushed of their fluids and placed in general trash, and intravenous (IV) bags go directly  into the
general trash.
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10.2.4
Five (5) South:  Patient Floors
      Thirty-six beds are maintained on the patient floors.  Patients generally wear reusable cloth
gowns, although paper gowns are used if cloth is unavailable.  Wastes are segregated into sharps,
blood and body fluids, and general trash,  although in practice many nurses dispose of non-infectious
waste in the blood and body fluid waste containers. The unit generates between one and two 30-
gallon bags of infectious waste per clay, which are collected by a contract infectious-waste hauler for
off-site treatment and disposal.
10.2.5
Medical Intensive Care Unit/Cardiac Care Unit
      The MICU/Cardiac Care Unit (CCU) operates eight beds.  The unit reuses clean woven cloth
gowns and pressure bags, which are used to introduce blood toซa patient.  Wastes are segregated
into sharps, blood and body fluids, and general trash, although again many nurses dispose of non-
infectious waste in the blood and body fluid waste containers. Infectious wastes are collected by a
contract infectious-waste hauler for off-site treatment and disposal.
10.2.6        Hemodialysis

      The hemodialysis unit treats about 55 patients per week and uses nearly all disposable
products, including aprons and masks. Disposable dialyzers are resterilized and reused about 20
times before disposal.  At least four 30-gallon bags of blood and body fluid are generated each day in
this unit. This waste includes most of the disposable items.  Blood and body fluid wastes are
collected by a contract infectious-waste hauler for off-site treatment and disposal.  Sharps are placed
in special containers for incineration on 'Site.
10.2.7
Outpatient Clinic
      Services performed at the outpatient clinic include surgical procedures, medical examinations,
chemotherapy, dermatology, urology, plastic surgery, orthopedics, and ear, nose, and throat
treatments. Plastic-coated paper gowns are used for chemotherapy and are disposed of as cytotoxic
waste.  The same type of gown is often used for other services, although the clinic also uses
reusable wovens including sheets, pillow  cases, towels, and blankets.  Badly soiled linens are often
discarded rather than laundered.  Gomco suction apparatus, suture removal sets, and scalpels are all
reused.

      The outpatient clinic generates one 30-gallon bag of blood and body fluid wastes each day,
which is disposed of together with the hospital's other infectious waste streams.  Chemotherapy
wastes are transported for off-site disposal by a cytotoxic-waste hauler.  Sharps  are placed in special
containers for incineration on site.

10.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

      Through a review of available literature, the site visit to VA-Cin and an understanding of the
limitations facing waste reduction in a hospital setting, pollution  prevention recommendations were
made involving:  (1) reusing disposables; (2) using wovens versus nonwovens; and (3) product
substitution.
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  10.3.1
 Reuse of Disposables
        As the cost of solid and medical waste disposal (including incineration) escalates the
  reintroduction of reusables may be warranted.  Hospital automation, specifically in the processing and
  sterilization of soiled linens, is enabling many institutions to reconsider the application of reusable
  surgical linens as  a cost-effective option to the disposal of paper products.

    ^   Glass products used in the VA-Cin laboratories, including test tubes, sample cups Petri
  dishes, slides, pipettes, and pipette tips, could represent a source of recycled glass instead of being
  disposed of as waste.  Glassware  made of borosilicate cannot be recycled with general  consumer
  waste glass and would require special handling. Additional concerns exist over the ability of
  autoclavmg to adequately sterilize  the waste glass for further processing.  Pending a decision to
  recycle the glass waste, substitution of glass for currently  used plastic items would further reduce the
  wssts strssrn.

       Approximately 1,500 glass Petri dishes are used each week by the Microbiology Laboratory  A
  recommendation was made to consider  using an off-site facility for cleaning and reprocessing the
  Petri dishes for reuse.  The eight other hospitals existing within a two-mile radius of VA-Cin mav also
  take advantage of  a Petri dish recycling  service.

       Plastic IV bottles which typically never come into contact with body fluids remain
 uncontammated during use and could therefore be safely reused for a single patient.  These could be
 substituted for the  disposable IV bags.

       Economic factors affect the decision to use disposable or reusable products  through waste
  earT!5,?an??SpOSal COStS' Stora9eand reprocessing space, labor constraints, and durable product
 availability.   Infection control,  however, is the primary limiting factor when considering reusable or
 disposable  products.
 10.3.2
Wovens Versus Nonwovens
       The use of wovens would decrease the volume and weight of hospital waste significantly  The
 advantages of woven material include its nonabrasiveness, allowance for freedom of movement
 puncture resistance, and ease of maneuverability.  Reusable fabric can also be made water repellent
 therefore resistant to blood and body-fluid penetration, and in addition the higher density of treated  '
 fabric  provides an effective barrier against bacteria.  When costs are integrated the use of wovens
 may represent a  better use of hospital resources.  Although in some cases paper products will
 remain in  use for specific applications, the universal  use of paper products in any health care facility
 snould be avoided.
10.3.3
Product Substitution
      Plastic covers for pillows can be replaced with vinyl/nylon laminate covers.  These covers
would prolong the life of the pillows, decrease the risk of infection and reduce waste by continuing
the use of woven pillow covers.  In some cases within the laboratories, reprocessing of glassware
may prove an economical alternative to plastic disposables.  Surgical sponges represent a significant
fraction of the infectious waste stream. A recommendation was made to investigate as a pollution
prevention/waste minimization alternative, whether sponges are being  used for purposes better suited
for absorbent, reusable towels (e.g., clean-up activities)
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10.4  RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      Suggestions for research and development possibilities in the health care industry include: (1)
conducting cost studies for certain health care products in cooperation with other Federal agencies,
such as Veterans Affairs and Health and Human Services; (2) working with trade associations and
other Federal agencies, such as the Food and Drug Administration in reviewing technical,  legal and
policy impacts of reusing disposables; (3) stimulating the development of cooperative reprocessing
service centers; and (4) developing procurement guidelines for the VA which will stimulate the
production and distribution of reusables  and recyclables.

10.5  STATUS OF IMPLEMENTATION

      Due to safety concerns at the medical facility, VA-Cin has not implemented any of the pollution
prevention options outlined above. Instead, VA-Cin has instituted a simple recycling program that
has been very successful to date. The program consists of recycling cardboard and white paper and
has expanded in August 1994 to include aluminum cans.  The program has significantly reduced the
solid waste generated by the facility, i.e;, trash removal from the facility has been reduced to once
per week from the earlier levels of three times per week.

      VA-Cin has also implemented  a reuse program for their floor maintenance pads (i.e., various
grades of buffing pads).  These pads are now being washed and reused. Estimated savings from
this program are $10,000 to $15,000 per year.

      VA-Cin is investigating the use of a reusable bed pad. This bed pad would alleviate the need
for bladder protection  products for some patients.   This program is in the preliminary stages; the
waste reduction potential of this program is as yet unknown.
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                                         SECTION 11

                            DEPARTMENT OF TRANSPORTATION
                      U.S. COAST GUARD SUPPORT CENTER NEW YORK
                                    GOVERNORS ISLAND

      This project, conducted in 1990, attempted to develop management initiatives and as technical
 changes that could be implemented for pollution prevention purposes.  Technical pollution prevention
 evaluations conducted at this site centered on paint removal by blasting, painting, and solvent
 recovery.

 11.1  FACILITY DESCRIPTION

      Governors Island is located off the southern tip of Manhattan and is accessible primarily by a
 Coast Guard- operated ferry. The island encompasses 175 acres and consists solely of Coast Guard
 facilities  which are grouped together under the name "Support Center New York." The Island serves
 as a support center for Coast Guard activities conducted within the New York area and for tenant
 commands located on the Island, and is the home port for a number of Coast Guard cutters.  There
 are 22 different commands represented on the Island,  each reporting to Headquarters in Washington
 or to an off-site location.  Support Center New York supports all activities on the Island, although it
 does not have authority over all commands.

 11.2  AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

 11.2.1       Management Activities

      The Governors Island facility generates a substantial amount of hazardous waste in the form of
 lead-acid batteries, lead-contaminated blast grit, paint,  and paint-related material.  The Hazardous
 Waste Office estimated that actual disposal costs for hazardous wastes total $150,000 per year,
 while total annual costs for disposal including  overhead for materials handling activities are
 approximately $270,000.  During the assessment, the hazardous waste  management activities on
 Governors Island were reviewed.  The resulting study included: (1) identification and review of
 successful pollution prevention programs currently in place; (2) identification of pollution prevention
 problem areas; and (3) identification of potential management solutions  for problems.

 11.2.1.1      Successful  Pollution Prevention Programs in Place-

      These programs include use of lead-free paint throughout the Coast Guard, development of a
new paint with  lower VOC content, use of solar batteries  in aids-to-navigation, and elimination of
engine coolants containing dichromate additives. In addition, a pollution prevention policy  has been
established for the facility and instructions  specifically citing pollution prevention objectives have been
provided. Pollution prevention initiatives implemented at  the facility include the following:
establishment of a hazardous waste tracking system; purchase of a compactor for waste paint cans;
installation of a new baghouse and recycling program which  has reduced blasting grit volume by 50
percent; use of disposable  brushes to reduce paint thinner wastes; installation of a silver recovery

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unit on the x-ray apparatus in the sickbay; recycling of Safety-Kleen products; and reusing certain
materials sent for disposal by others.
11.2.1.2
Pollution Prevention Problem Areas--
      Problem areas identified include governmental issues concerning lack of motivation for
compliance, funding and procurement practices, and site organization and facilities.  Examples of
governmental issues include:  end-of-year spending, resulting in the purchase of new paint when
current reserves are sufficient; lack of proper storage for preservation of paint quality, contributing to
excessive waste; high turnover of military personnel, contributing to problems of hazardous waste
handling; and lack of employee awareness, contributing to the unnecessary generation of hazardous
waste at the facility.

      Examples of organizational- and facility-related issues include: the presence of tenant
commands with no centralized procurement or accountability, resulting in poor management of
supplies; and the use of multiple disposal contractors by tenant commands, causing significant
generation of hazardous waste, primarily  paint.  Storage areas throughout the facility are unheated,
causing stored paints to degrade and require premature disposal.  It has been estimated that 50
percent of the paint disposal is unnecessary.
11.2.1.3
Potential Management Solutions--
      Solutions recommended by the study include the following:  work toward cultural changes
emphasizing commitment on all levels; forcefully express policies; provide employee training and
incentive awards; and conduct detailed engineering evaluations of the waste generating processes.
These solutions would require a concerted effort from both Coast Guard Headquarters in Washington
and from Governors Island for policy changes, funding, implementation and technology transfer.
Additional recommendations include addressing storage areas and procurement practices.  For
example, central warehousing could eliminate the loss of paint from storage in unheated lockers, and
a centralized purchasing system would eliminate duplication of supplies with short shelf lives. Other
possibilities include allowing for effective substitution of pollution  prevention  products, and expanding
accountability and reporting protocols to make individual commands more aware of their waste
generating potential.
 11.2.2
Technical Evaluation for Pollution Prevention
      Several technological operations and processes related primarily to buoy maintenance and
 refurbishment were identified as key areas for consideration of pollution prevention opportunities.
 Maintenance of buoys used as navigational aids is one of the Coast Guard's responsibilities.  Buoys
 require refurbishing every four to six years.  Old and degraded paint is removed by blasting with steel
 shot through a high-pressure air gun and several coats of durable paint are reapplied.  The steel shot
 is recycled approximately five times, until  it becomes too fragmented for  use.  Spent shot is collected,
 stored, and disposed of as a hazardous waste because it contains low levels of lead. In 1988,
 approximately 120 55-gallon drums weighing about 750 pounds each were disposed  of.  Estimated
 costs for steel shot purchase and disposal are approximately $38,000 per year.

       Frequent painting  preserves the appearance and protects the integrity of equipment exposed to
 aggressive saltwater environments.  Buoys and other equipment are spray painted using a Binks
 Airless 1 spray gun and  a high-pressure air system.  Buoys are spray painted with several different
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 paints, including an epoxy anti-foulant  A total of approximately 5,300 gallons of various coatings are
 used annually.  It is estimated that the transfer efficiency of paints using this equipment is only about
 50 percent.                                                                          .

 11.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

       Of the several options examined, the following were considered most feasible for the near
 future,  both from an environmental and a cost perspective:  (1) low-pressure guns to replace the
 airless guns; (2) replacement of steel shot with plastic media; and (3) use of an on-site still for
 recovery of reusable solvent.
 11.3.1
 Low Pressure Sprav Guns
       Use of an HVLP spray gun significantly reduces overspray from an estimated 50 percent with
 an airless gun to only 15 percent with the HVLP gun. This immediately translates into a reduction in
 the amount of paint used, resulting in a comparable reduction in the amount of VOC emitted to the
 atmosphere. In addition, by reducing the overspray, sludge buildup in the water curtain is decreased
 and the time between required cleanouts is reduced. The cost of the new HVLP gun system and
 compressor is less than $1000 and retraining of operators is minimal, making this an attractive
 option. Closed system spray gun cleaners are now available at a relatively low cost ($500 at the
 time of the assessment). These systems avoid discharge of solvent to the air while using a minimum
 amount of solvent.  Estimated payback for the conversion is only  0.5 months.
 11.3.2
Plastic Shot
      The use of plastic shot as an alternate blasting media is an emerging technology and should
 be readily implemented at Governors Island. The changeover from steel shot to plastic shot can be
 made with essentially no capital investment and only minor adjustments.  The changeover would
 significantly reduce the weight of the dust due to the plastic material's lighter density (50 pounds per
 cubit foot versus 300 pounds per cubic foot for steel), while increasing the recycle capability from five
 cycles for steel to 20 for plastic.  Lead from the older lead-based paints will remain a problem  until all
 the buoys have been painted with the new no-lead paint; however,  unlike steel, the plastic dust can
 be incinerated. This option is highly cost-effective, with payback occurring in only 3.4 months
11.3.3
On-Site Still for Solvent Recovery
      Waste paint and solvent thinner are major sources of waste and significant contributors to
disposal costs, consequently, reclamation of solvents may have cost and environmental benefits
Small scale stills (15 to 20 gallons per day) for reclamation by distillation were evaluated as a
possible alternative to disposal. This operation is estimated to recover 50 to 90 percent of the
volatile solvents from paints and contaminated solvents.

11.4  RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      Additional research is needed to ensure that plastic shot will effectively remove rust and will
not adversely affect the paint application  process.
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11.5  STATUS OF IMPLEMENTATION

      The Governor's Island installation has implemented one of the options identified in the PPOA:
the use of plastic shot as an alternative blasting media.  However, no data on waste reductions from
the changeover have been gathered.

      The U.S. Coast Guard is also in the process of evaluating several of the other pollution
prevention alternatives that were discussed above for many of their installations.  In  addition, a
replacement for the current buoys is being pursued.  A dense foam buoy which has color embedded
in the foam is being tested.  This buoy would require no further painting or repainting.  The use of
low-pressure spray guns is being evaluated for many facilities, although no data are available on the
results of that evaluation.

      Due to budget constraints, the on-site solvent recovery unit that was suggested has not been
pursued. The Governors Island installation has purchased and installed a distillation unit for
recovering antifreeze; however, data on the effectiveness of that unit are not available.
                                               38

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                                         SECTION 12

                            DEPARTMENT OF TRANSPORTATION
                            U.S. COAST GUARD BASE KETCH(KAN

       A PPOA was conducted at the U.S. Coast Guard's Base Ketchikan in Alaska in 1990  This
 project was jointly funded by EPA Region X and the Risk Reduction Engineering Laboratory.

 12.1   FACILITY DESCRIPTION

       Over 100 Coast Guard and civilian personnel are.employed at Base Ketchikan, Alaska  The
 primary functions of the Base are to  maintain several hundred aids to navigation (ATON) in Alaskan
 waters and to support and maintain several Coast Guard cutters and boats, which are used for
 search and rescue operations, law enforcement, and ATON maintenance. Four tenant commands
 with accompanying housing and medical facilities, are located on the Base.

 12.2   AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

       Major waste generating activities are buoy  maintenance and vessel maintenance. The Base
 also receives hazardous wastes generated by Coast Guard units in southeast Alaska.
 12.2.1
Buoy Maintenance
      Most of the 300 ATON maintained by the Base are steel buoys.  Preventative maintenance
 performed annually includes battery replacement,  wiring repairs, lights and bells maintenance
 lighthouse generator checks, and anchor checks.  The buoy hulls are overhauled every five to six
 years, with an average of 82 buoys overhauled each  year. The overhaul process involves pressure
 spraying to remove barnacles and other marine growth, blasting to remove all paint, preparing the
 surface  for repainting,  buoy repairs as needed, and repainting.  Wastes generated in the process
 include  batteries, blasting waste  (blasting media and  paint dust), waste paints, thinners and paint
 slops.
12.2.2
Vessel Maintenance
      Vessel maintenance includes engine maintenance, oil changes and coolant replacement
periodic maintenance of all on-board systems, and an overhaul approximately once every five years
Maintenance is performed on an average of five vessels each year.  Paint removal from hulls is
accomplished by dry blasting using granulated smelter slag or gravel blasting material.  Steel shot
cannot be used because it damages the aluminum vessel hulls. Wastes generated from these
processes include waste oil,  coolant, bilge waste,  spent blasting media, paint wastes, thinner and
solvents. Bilge waste consists of a mixture of water, oil, diesel fuel, and coolant, and comprises the
largest volume of hazardous liquid wastes disposed of at the Base.
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12.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

      Pollution prevention options were identified for the six primary areas of waste generation: (1)
paint blasting;  (2) painting vessels and buoys; (3) use of solvents; (4) bilge waste; (5) waste oil; and
(6) antifreeze/coolant waste.
12.3.1
Blasting Waste
      Options for reducing blasting wastes and toxic waste paint include:  (1) using lead-free non-
toxic paints; (2) constructing concrete floors for marine ways to collect paint removal wastes; (3)
using recyclable plastic blasting media; (4) retesting the waste for hazardous components; and (5)
reducing the frequency of repainting.   ;

12.3.1.1       Lead-Free, Nontoxic Paints-

      Using lead-free,  nontoxic paints is an effective, long-term  method for reducing hazardous
painting wastes.
12.3.1.2
Concrete Floors--
      Until all existing toxic paint is rernoved and nontoxic paints are used exclusively, installing
concrete floors beneath vessel painting operations would allow for collection of toxic blasting wastes.
While initially expensive ($200,000), this option would result in an annual payback of $30,000 with a
payback period of 6.7 years.

12.3.1.3      Plastic Blasting Material--

      An inexpensive option for reducing waste is to use plastic blasting material to remove paint.
Such material can be used up to 20 times and with such precision that one coat of paint can be
removed at a time,  eliminating the need to strip the paint to bare metal.  However, the plastic
material cannot dislodge rust or heavy encrustation from metal buoys.

12.3.1.4      Retesting Wastes-

      To reduce expensive hazardous waste disposal costs, the blasting waste should be retested to
confirm that it is hazardous.

12.3.1.5      Reduce Painting Frequency-

      Reducing the frequency of repainting would reduce the generation of blasting waste.

12.3.2        Painting Vessels and  Buoys

      Several of the options associated with painting vessels and buoys are (1) substituting lead-
free, nontoxic paint; (2) using HVLP paint guns; and  (3) using a benchtop distillation system to
recycle paint waste and thinner.
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  12.3.2.1
 Lead-Free, Nontoxic Paints-
       As with blasting operations, using lead-free, nontoxic paints is an effective, long-term method
 for reducing hazardous painting wastes.
 12.3.2.2
 HVLP Paint Guns-
       Using HVLP paint guns will provide an estimated $12,250 savings per year, with an initial
 investment of only $1,300 and a payback period of less than one year.  The HVLP gun improves
 paint transfer efficiency  so that more of the paint reaches the surface and less evaporated solvent is
 released as VOC.

 12.3.2.3      Benchtop Distillation System--

       Liquid paint waste and thinner can  be recycled with a benchtqp distillation system  The
 recycled thinner is adequate for cleaning use, but not for thinning paint.  The resulting paint sludge
 while still hazardous, would be reduced in volume, providing an annual savings of $6 200 and a
 payback in 0.6 years.                                                           '
 12.3.3
 Solvents
   ,    The Base uses a variety of solvents, including Stoddard, trichloroethane-based engine cleaners
 and degreasers, paint thinners (primarily MEK), and epoxy cleaners.  In one year, almost 800 gallons
 of solvent waste were disposed of as hazardous wastes. Several options for reducing the use and
 disposal of solvents are (1) using commercial substitutes;  (2) steam pressure washing prior to solvent
 use; (3) filtration; and (4) proper handling.

 12.3.3.1      Solvent Substitutes-

       Several commercial solvent substitutes are available; however, each must be used to
 determine if it is compatible with materials being cleaned and performs the task adequately   While
 less toxic, some substitutes exhibit other characteristics, such as flammability, that may render them
 hazardous.

 12.3.3.2      Steam Pressure Washing-
       Steam pressure washing prior to solvent use will reduce the volume of solvent needed.
12.3.3.3
Filtration-
      Regular filtration or removal of dirt and sludge can also extend the solvent's useful life
significantly.

12.3.3.4      Proper Handling-

      Proper handling of solvents will  reduce the loss of solvent through evaporation and spillage
Examples of proper handling include:  securing container lids; using spigots, pumps, or funnels when
transferring the solvent; segregating solvents so that they are not mixed with other wastes (rendering
the waste unfit for recycling); and segregating chlorinated and non-chlorinated solvents
                                              41

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12.3.4
Bilae Waste
      Bilge  a mixture of water, oil, diesel fuel, and coolant, comprises the largest volume of liquid
wastes disposed of as hazardous waste at the Base. Options for reducing this waste include base-
wide use of oil-water separators and an ultrafiltration system.

12.3.4.1       Oil-Water Separators-

      Base-wide use of oil-water separators and avoidance of detergents or other emulsifying agents
that inhibit oil/water separation would result in an annual savings of more than $18,000 with a
payback period of 1.4 years.
12.3.4.2
Ultrafiltration-
      |f bilge emulsions are inadequately treated by the oil/water separator, an ultrafiltration system
could be used to reduce the bilge waste stream. Ultrafiltration systems incorporate a first stage
coalescer followed by a second stage membrane separation unit.  While these units require more
maintenance, the expense can be recovered within two years, from the resulting reduction in
hazardous waste disposal costs.
 12.3.5
 Waste Oil
       Oil is generated by engine lubrication on boats, cutters, and shore facilities  and generators.
 Possible pollution prevention measures identified include segregating the oil waste for later recovery
 and by-pass filtration systems.

 12.3.5.1      Segregation-

       The best solution for reducing waste oil is to segregate it from other wastes, particularly
 halogenated solvents, and recycle it for on- and off-site energy recovery.

 12.3.5.2      By-Pass Filtration-

       By-pass filtration systems would also extend the life of oils, reducing purchase and disposal
 costs. With a total investment of $17,000, savings of at least $60,930 can be realized with a
 payback period of less than one year.
 12.3.6
 Antifreeze/Coolant
       Purifying engine antifreeze/coolant with commercially available filtration systems can avoid
 both disposal and purchase costs. With a cost of less than $8,000 and an annual savings of $6,880,
 the payback period for use of such a filtration system is 1.2 years.  Large scale purification is also
 commercially available.

 12.4  STATUS OF IMPLEMENTATION

       A Base pollution prevention committee has been established at Base Ketchikan and is acting in
 cooperation with  the Alaska Department of Conservation (ADC).  The Base has shown reductions in
                                                42

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the waste streams generated; however, documentation is not available to quanify the amounts and
types of reductions.
IAI  *      pollution Prevention Programs in effect currently deal with waste oil and waste batteries
Waste oil is now burned for heating value.  Waste batteries are given to the local auto parts store '
which has arrangements for recycling them
                                            43

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                                        SECTION 13

                                 DEPARTMENT OF ENERGY
                             SANDIA NATIONAL LABORATORIES

       PPOAs at the Department of Energy Sandia National Laboratories (SNL) were completed in
 1993  Several areas were identified for waste reduction within the SNL complex. Specifically
 targeted were the Geochemical Laboratory (GL) and Manufacturing and Fabrication Repair
 Laboratory (MFRL).  This project was jointly funded by EPA and DOE.

 13.1  FACILITY DESCRIPTION

       SNL is located in Albuquerque,  New Mexico, within the boundaries of Kirkland Air Force Base
 (KAFB)   SNL is owned by the United States government and is operated by Sandia Corporation, a
 subsidiary of AT&T,  under a prime operating  contract with the DOE.  SNL consists of five technical
 areas and several remote test areas, whose primary mission is national security with an emphasis on
 nuclear weapons development and engineering.  In the process of pursuing this mission, SNL has
 evolved into a multiprogram laboratory pursuing broad aspects of national security issues. As  by-
 products of production,  research and development, and environmental restoration activities, Sandia
 generates a variety of waste materials, all of which are carefully controlled and regulated by the
 Federal government and state and local agencies.

       The GL performs analyses of earth materials and simulates earth  conditions. The MFRL
 repairs printed circuit board assemblies and wiring and box assemblies (mother boards) for use in
 satellite systems.

' 13.2  AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS
  13.2.1
Geochemistry Laboratory
       The GL performs primarily physical and chemical composition analyses of earth materials, and
  simulates earth conditions (e.g., subjecting rock samples to extreme temperature and pressure).
  Varied analytical instruments are used at the GL, including an atomic emission spectrophotometer, a
  scanning electron microscope (SEM), x-ray diffraction analyzer, scintillation counter, and an ion
  chromatograph.  Various wet chemistry techniques are also used. Grinding, sieving, and polishing
  equipment are used for sample preparation.  Additionally, the GL operates a small machine shop
  comprised of a drill press, lathe, and grinder.

       Three types of research projects are performed by the GL, segregated primarily by the degree
  of researcher control over project design.  Type 1 projects account for approximately 40 percent of
  GL's work load, and are funded by a sponsor and completed  by one to two GL personnel over a
  period of several years.

       Type 2 projects account for approximately 50 percent of the GL workload, and include those
  involving a proposal submitted by another group who asks assistance from the GL. Type 2 projects
  are the most likely to be terminated before completion and, consequently, generate the largest
  quantity of wastes. For example, funding for a project examining brine inclusions in salt formations at
  DOE's Waste Isolation Pilot Plant site was withdrawn before  project completion, leaving the GL with

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    npnrnf [ฐf "* *ฐ . Jef disPosed of as ^emical waste. Bench top wet chemistry research in a
  Type 2 project also contributes to waste production.
              PrOJe?Si uฐ Cฐunting for aPProximate|y 10 percent of the GL workload, include projects
  ซ   h * "ft  I  6i SNL researchers to Perform a spedflc task. These projects are
  typically short, of one to three days duration.
  n  tn              K,          S0i' Samples are archived in one of ^ libraries established at the
  GL, to allow for possible retestmg or because of their unique origin or composition. The second
  obralC,T  I ฐฃa chemical library- where chemicals not consumed during projects are allowed to
  th.*™    , f?  bTeS accumulate samP|es until additional space is unavailable, at which time
  the accumulated samples are disposed of as chemical waste. Unique rock and soil samples are
  either retained indefinitely or archived at sites where they were collected.
ซ5FM
                        
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      The need for generating reproducible laboratory results and a strong reliance on standard
methods hinder implementation of pollution prevention initiatives that could compromise a
researcher's findings  Scientists are reluctant to carry out many pollution prevention activities due to
the complexity of Federal and state hazardous waste regulations.  Feasibility of pollution Prevention
opportunities identified therefore depends to a large extent on the attitude and confidence of SNLs
researchers  Elevating pollution prevention objectives to the level of other crucial scientific principles
through education and training may result  in significant reductions in waste generation.

13.3.1       Geochemistry Laboratory

      Pollution prevention options for the  GL focused on  management activities.  Through education
and training efforts, pollution  prevention can be built into the research process. Additional options for
pollution prevention with respect to specific project types  include:

      Type 1 Projects - design pollution prevention into proposals for research activities;  build  in
      funding for proper waste management; return unused, contaminated samples to point of
      collection of SNL grounds.

      Type 2 Projects - escrow a portion  of available funds to cover cost of project closeout; contact
      other labs within SNL before ordering chemicals to determine their local availability; encourage
      chemical  suppliers to accept returned, unopened chemicals and issue refund or credit; exert
      tighter controls on sample sizes sent to GL.
                                                                           1
      Type 3 Projects - determine sample quantities needed and alternatives to sample analyses;
      expand use of microanalytical techniques; retain or return to requester unused portions of
      samples.

 Site-wide options for pollution prevention  include the following:

       Chemical  Material Management System - provide  a life cycling and control mechanism for
       chemical materials.

       Central Purchasing - educate procurement personnel to spot material substitution opportunities.

       Central Distribution - determine usage patterns of operations that commonly use and dispose
       of certain chemicals; order specialty  chemicals through the site-wide stockroom; identify other
       potential users.

       Checkout System - require employees retiring or leaving the laboratory to report the status of
       chemicals and samples present in  their laboratories.

       Chemical Exchange - require supplying  researcher to certify that contents of an opened
       container have not been altered by the addition of contaminants or improper storage;  explore
       ways to use expired  chemicals for other applications.

  •    Chargeback System - use chargeback money for  site-wide pollution prevention .options.
                                                46

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  13-3-2       Manufacturing and Fabrication Repair Laboratory


        Several pollution prevention options were identified for the MFRL including-  m testina the
  nnse water; (2) eliminating ziplock bags; (3) reusing swabs; and (4) eliminating bench cSSng
  13.3.2.1
              Test Rinse Water-
       Testing rinsewater which is disposed of as a D008 hazardous waste may reveal that it is non-

                                                                t0 be USed for <*ซ no*
  13.3.2.2     Eliminate Ziplock Bags-


       Nฐnflammab'e contaminated laboratory trash is placed in Ziplock bags and carried to a 30-

       fTS^SiJjft11^9 Ti  ThS Cฐntainer JS alSฐ Hned With a Plastic ba9' which  is rem
  when full  transported to the waste disposal area and combined in a special container with  other
  wastes. The ziplock bags are labelled with a bar code for tracking purposes, tT^TrnSf air

  20 nliin5 Oc7py u,nnecessary sPa<*-  The use of ziplock bags could be eliminated by keeping a Hned

  faboฑlPt  Vf y?ne, Cฐonain1,r h the Vapฐr de9reasin9 room for disposal of contaminate?
  laboratory trash.  Similar 20-gallon containers are already used for waste disposal at SNL.

  13.3.2.3      Reuse Swabs-
                  ฐff the,6ndS M ^ontaminated swab sticks and using the non-contaminated end  the
                    waste could be reduced with no capital costs involved.  This practice would
 reduce an estimated 80 percent of the laboratory waste resulting from swab use.


 13.3.2.4      Eliminate Bench Cleaning-
trash
                                 perfฐrmed to deflux soldered connections, generating laboratory
                p,f       u vapor degreaser after repair, regardless of whether they were

      *       "  E"m;nat!n9 the bench Cleanin9 step altogether would reduce the generation of
 solvent- and flux-contaminated trash, and would also reduce the  use of wipes and swabs


 13.4  RESEARCH, DEVELOPMENT, AND DEMONSTRATION


      The pollution prevention options discussed in the previous  sections are for verv small

             T6Sent bUt a feW ฐf thS typSS ฐf activities that could be id^d us7ng Tsa
        preVeHnt'ฐnt assessment Astern.  An ongoing effort should be initiated to prioritize waste
 streams according to quantity  and/or type for further examination.


 13.5  STATUS OF IMPLEMENTATION


      The recommendations of the PPOA performed as part of the WREAFS program have not been

         P f ment!,d at,,S,andia Natiฐnal Laboratory-  However, these recommendations  have
        influenced pollution prevention activities at SNL.
te ™,n    ComplexLty ฐf the EPA recommendations encouraged the Department of Energy to develop
ite own internal graded approach to PPOAs. A team including DOE personnel and contractors
                                            47

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developed the PPOA guidance document currently in use at SNL.  This document, entitled Model
Pollution Prevention Opportunity Assessment Guidance, (2) is based on EPA's PPOA guidance but
has been reduced in size and made more specific to the DOE laboratory facilities and their low
volume waste streams. The DOE PPOA guidance document is currently used to help identify waste
streams that may be reduced or eliminated at SNL.
                                             48

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                                         SECTION 14
                               DEPARTMENT OF AGRICULTURE
                       BELTSVILLE AGRICULTURAL RESEARCH CENTER
                                    fฐf
 14.1  FACILITY DESCRIPTION
                                                        the Beltsville Agricultural ^search
           U;S- DePartment of Agriculture's Beltsville Agricultural Research Center (BARC) is located
 rese    work^T" BA™e™^s approximate^ 1,000 scientists and technTcian^who peS
 research work ,n all areas related to the Agricultural Research Service's activities,  including Hvestock

                                          flanafcs
 14.2  AREAS OF POLLUTION  PREVENTION OPPORTUNITY EVALUATIONS
 (2)
 analysis.

 14.2.1
                      fbS55 ฐn ^ areaS: (1) general hazardous materials handling and usage-
                        (    * a  yS'S; 3nd (3) hl'9h Performance "quid chromatography (HPLC)
             General Hazardous Materials Handling and Usage
cost of $42^00  A ฃn9  >    ,T1 5T ga"ฐnS ฐf haZardฐUS Wastes annual|y at a   sPฐs
nrJnnJ   I  u  *K   ฐ, I Slte-Wlde hazardous waste management program led by the Safety
Occupational  Health, and Environmental Section Office includes state-of-the-art marshalling facilities
d^Joft   Ulkm9'hsi'y"moc.ni onsne
                                                                            Samoles are
                                                                             a
 14-2-2       Total Kieldahl Nitrogen Analysis


 nvWiJTi6 IK,N methOCI iStUfed t0 determine Protein nitrฐgen in biological materials.
 S^ฑ/^!??S^!!^* af Which convfrts bound ni*rฐgen to ammonk
                                  /itn an excess of a strong base, distillation, and titration of
                                  len content. Waste reagents used in the TKN analysis include
acidic nr haซir  Am   *     ~" * cont^!ns metals used as catalysts, and the distillate, which is either
acidic or basic  Amounts vary depend.ng on the nitrogen content of the sample.  Samples with low
nitrogen content are analyzed by macro-Kjeldahl techniques which use increased sample sizes and
typ,cally generate 500 to  600 milliliters of waste per sample.  Samples with high nitrogen content are
analyzed by micro-Kjeldahl  analyses, which  use smaller sample sizes and generate waste at
                                           49

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approximately 50 to 100 milliliters per sample.  BARC's total acid and base waste streams during
1990 were approximately 850 gallons.

14.2.3       High Performance Liquid Chromatographv Analysis

      HPLC is used extensively at BARC laboratories to separate, isolate, and identify components
of mixtures  Solvents are used as mobile phase to introduce samples and to elute analytes through
and off the chromatography column at specific times, based on their differing affinities for the column
packing material.  A pump regulates solvent flow, and a sensitive detector identifies and quantifies
compounds eluting from the column.  Typical solvents used include aqueous mixtures of methanol
and acetonitrile.  The  HPLC effluent is flammable and may exhibit other characteristics  of hazardous
waste.

      Organic solvents are also used during sample preparation to isolate a specific  analyte or
characteristic class of compounds, or potential interferents for the sample matrix.  Sample
preparation at BARC includes liquid-liquid extraction, in which aqueous samples are extracted with
oraanic liquid, or solid-liquid extraction, in which solid samples are extracted directly  in  solvent.
Secondary extractions may also be performed.  Extraction solvents primarily include  chloroform,
hexane, methanol, and methylene chloride.

      During 1990 approximately 2,600 gallons of waste solvents were disposed of at  the BARC
facility.  A significant amount of this waste stream consists of organic solvents which were used in
connection with HPLC analyses and sample preparative procedures.

 14.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

 14.3.1        General Hazardous Materials Handling and Usage

      Impediments to implementing pollution prevention techniques at BARC include the large
 number of small waste streams generated and the need for approval of new laboratory methods by
 independent boards such as the Association of Official Analytical Chemists  (AOAC). However,
 several pollution prevention options exist in this area, including training and assessments, process or
 equipment modification, waste segregation, and a pollution prevention policy.

 14.3.1.1      Training and Assessments-

       A "Pollution Prevention Officer" could be appointed within each research institute to assist
 researchers with reduction and recycling initiatives.  A network of such officers could be established
 to foster communication and reduce repetitive  pollution prevention development efforts. Periodic
 laboratory pollution prevention assessments could be used to uncover additional  pollution prevention
 opportunities and monitor the success of ongoing programs.

 14.3.1.2     Process or Equipment Modification-

        One option recommends that pollution prevention officers should  be  aware of new technology
 that will prevent pollution in a laboratory setting. Where the technology is expensive, resources could
 be pooled and the technology or equipment shared by several laboratories. Atmospheric emissions
 of chemicals from laboratories could be reduced by such actions as using commercially available
 glassware and automated extraction systems.  In addition, for some samples, emissions can be

                                               50

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  reduced through solid phase extraction techniques, as opposed to.classical liquid evaporation
  techniques that release the solvent carrier into the fume hood and subsequently to the atmosphere.

  14.3.1.3      Waste Segregation-

       . Hazardous waste volumes are often unnecessarily increased due to the addition of waste
  streams that are not hazardous.  Segregation of hazardous from nonhazardous wastes can
  significantly reduce hazardous waste generation rates and subsequent disposal costs.

  14.3.1.4      Pollution Prevention Policy-

  ... .  Each labฐratory should have a written  pollution prevention/waste management/reduction  policy
  Minimum requirements would include annual chemical inventories and the dating of chemSas
  tney are received.
 14.3.2
Total Kieldahl Nitrogen Analysis
                process could be replaced with commercially available automated mbrocomputer-
      I analysis systems that use combustion techniques to remove nitrogen and a thermal
 conductivity detection system to measure nitrogen release.  This would eliminate the need for
 solvents, but the cost of $30,000 may be a limiting factor for laboratories conducting a small number
 thcfnfly.ses. each year:  For those laboratories  involved in a sufficient number of analyses, however
 the payback period using a nitrogen autoanalyzer instead of the TKN process is 2 6 years  The    '
 payback for substituting a phenate autoanalyzer is 7.4 years. Use of the autoanalyzer also improves
 worker safety by eliminating hot acids and bases and trioxide fumes generated during digestion
 Atthougn ac,d and base wastes are eliminated, copper fillings and anhydrous chemicals used for
 water removal must be disposed of when spent.

 14-3-3        High Performance Liquid Chromatography Analysis
 *vtr^Qo.    ฐPtiฐnS indude reP|acin9 the sta"dard HPLC analysis with solid phase
 extract.cn (SPE) techniques or supercritical fluid extraction, and column/particle size reduction.

 14.3.3.1      Solid Phase Extraction Techniques-

 h^nn- Solid  phase extraftion techniques employ small disposable columns containing sorbent for
 bonding and elutmg analytes of interest.  Solvent usage can be reduced by over 95 percent when
 performing certain extractions, because one to two millimeters of solvent in an SPE filter or cartridge
 can accomplish the same function as 200 to 300 milliliters  of solvent in a standard HPLC system

 14.3.3.2     Supercritical Fluid Extraction-
solv6ntpvrnc flyid JJraction (SFE) is an innovative technique that may replace chlorinated
solvent extractions.  In SFE, a gas is compressed above its critical temperature and pressure points
and .s thus transformed mto a supercritical fluid exhibiting high diffusion coefficients and low
clS,Sf  6S' /ai7'ng ^e/emperature and pressure (density) of the supercritical fluid allows for very
wtS ,ndeS   I'0"8- tW'th ? Capita' CฐSt ฐf $3ฐ'ฐ00' a Prฐjected annual Usa9e of 15ฐ extractions per
week, and the el,mmat.on of purchase and disposal costs for organic solvents, the payback for this
option is less than 18 months.
                                             51

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14.3.3.3      Column/Particle Size Reduction-

      Converting from a typical column configuration (4.6 millimeters internal diameter by 25
centimeters length) to a smaller column internal diameter reduces the amount of sample needed, and
hence reduces the wastes generated from the sample preparation step. Reducing the packing
particle size enhances sensitivity by narrowing the analyte peakwidths.  Solvent consumption can
also be reduced by using a shorter column length, which produces shorter elution times while
preserving the separation resolution.  Although these techniques may not be feasible for all HPLC
analyses, their use could reduce waste by as much  as 80 percent with  a payback period of less than
three  months.

14.4  RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      Total quantities  of hazardous wastes must be measured to determine the economic viability of
various pollution  prevention options.

14.5  STATUS OF IMPLEMENTATION

      The BARC PPOA report and project summary were received in December 1993. Because the
report was received so recently, there has not been time to fully explore and evaluate the
recommendations contained.  The report and summary have been distributed among the upper
management at BARC. Major conclusions of the PPOA were discussed at a  quarterly meeting of the
chairpersons of the Institute/Center safety committees, and were also included in the required
hazardous waste training courses conducted for all  waste generators and  new employees.

      Although it is too early to attribute any reductions in hazardous waste generation to the
recommendations of the PPOA, some of the options presented are already in practice, including the
appointment of "hazardous waste advisors" in each center who are laboratory personnel  trained to be
 local  points of contact on hazardous waste management.  Greater efforts  and education  have been
 directed toward waste segregation to reduce hazardous waste generation  rates and disposal costs.

       A survey to assess the feasibility of the PPOA recommendations is currently being considered,
 and BARC will continue to work collaboratively with waste generators, primarily scientists,  to further
 the goals of the PPOA. However, pollution prevention activities are difficult because of the relatively
 small quantities  of a large variety of chemicals being used at BARC. The acquisition and
 incorporation of new technologies must be phased  in over time as new projects begin and funds
 become available. Ongoing projects must continue using the same technologies to avoid introducing
 new  variables which might influence the results.
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                                         SECTION 15

                                 DEPARTMENT OF INTERIOR
                       BUREAU OF MINES ALBANY RESEARCH CENTER

 .000  A Pollution Preventjon workshop was held at the Bureau of Mines Albany Research Center in
 1992. The first part of the workshop introduced participants to basic pollution prevention concepts
 During part two, participants applied pollution prevention concepts to three areas at the Albanv
 Research Center.                                                                    *

 15.1  FACILITY DESCRIPTION

       The Albany Research Center, located on a 42-acre site of the former Albany College in Albanv
 Oregon,  is one of five Bureau of Mines Centers in the United States researching metals and
 minerals. The Center was established in 1943 to investigate possible mineral-related uses for the
 abundant low-grade resources of the area and to develop new metallurgical processes using the
 areas plentiful supply of electrical  energy. The Center's staff of 150 engineers, scientists and
 technical support personnel perform research on ways to more efficiently recover,  process  and use
 needed metals and minerals.

 15.2 AREAS OF POLLUTION PREVENTION OPPORTUNITY  EVALUATIONS

      The types of wastes disposed of by the Albany Research  Center in 1991 included- chlorinated
 solvents, mixed combustible liquids, metal salts, chromic salts,  barium salts,  aluminum nitrate
 mercury wastes, styrene monomer, unused flammable liquids, and lead-contaminated concrete and
 analysis wastes. Because of the quantities of wastes, the facility is designated as a RCRA larqe-
 quantity generator.                                                                    y

 15.3  POLLUTION PREVENTION  OPTIONS AND RECOMMENDATIONS

 _     A complete pollution prevention opportunity assessment was not conducted at the Albany
 Research Center.  Instead, a pollution prevention workshop was held which generated options in the
 following  three basic areas: (1) inventory control; (2) solvent extraction research; and (3) corrosion
 rsscsrch.                                                                  !

 15.3.1        Inventory Control

 15.3.1.1      Waste Generation Data-

      Material balances performed  by facility  managers may help avoid shifting pollutants from one
medium to another. Complete periodic inventories of chemical stock would help to make the orderina
process more  effective, minimizing  over-ordering.
                                            53

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15.3.1.2      Sharing Chemicals-

      A centralized receiving department can function as an internal waste exchange. Departments
with excess chemicals can "advertise" through the receiving department.  In addition, depending on
the volume of surplus chemicals, it may be possible to give away or sell these substances through
one of the dozen or so waste exchanges  located throughout the United States.  Schools or
universities may also accept small amounts of chemicals as a donation.

15.3.1.3      Good Housekeeping-

      All personnel who handle toxic substances should be trained in materials handling.  For
example, personnel should be discouraged from disposing  of chemicals down sink drains by
educating them about the  harmful environmental effects, and possible legal actions, resulting from
this common practice.

15.3.1.4      Waste Management Practices-

      Mixing waste streams often increases treatment costs and  makes recycling more difficult.
Many transporters offer laboratory (lab) pack services in which small containers of different wastes
are placed in large drums called lab packs.  The exact chemicals must be known in the event that
any of the containers break inside the lab pack. A laboratory  should also practice purchasing
controls.  Purchasing controls require extensive pre-planning of research projects and calculation to
determine the amount of materials required.
 15.3.1.5
Other Options-
       Several other options are to determine if suppliers will accept obsolete raw materials;  ask
 mines and other suppliers to take back excess material not used in tests; use "first-in, first-out"
 inventory control to reduce overstock and outdated chemicals; designate one person to be
 responsible for checking the inventory once a month for leaking or uncapped containers.
 15.3.2
Solvent Extraction Research
       The workshop identified several pollution prevention options for solvent extraction research,
 including the following:  modify the research design (this may not be feasible, since the yields may be
 too low); use non- or less toxic materials; avoid using methanol and other solvents for glassware
 cleaning unless absolutely necessary; check all operations to ensure that they are operating at
 maximum efficiency; determine whether diethyl ether can be recycled by using liquid nitrogen in the
 trap; consolidate similar waste streams in order to justify a small on-site recycling system; use  better
 inventory procedures to eliminate waste generated from expired stocks; and check to ensure that all
 containers are tightly closed to prevent atmospheric releases.
 15.3.3
Corrosion Research
       Workshop group discussion generated the following pollution prevention suggestions for
 corrosion research: examine Greene cells for potential downsizing/scale; fill unused spaces with inert
 maten'als; reuse acids elsewhere; research alternative non-acid cleaning methods; extend bathlife
 through monitoring; implement pre-rinse or physical pre-cleaning before the bath; investigate
                                               54

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                                       meta'S; disti" and reuse methanol in solvent extraction or
15.4  RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      More specific pollution prevention options could be generated from a complete PPOA
conducted at this facility.

15.5  STATUS OF IMPLEMENTATION

      As a result of the PPOA, seven performance goals have been established for the Albany
r\6S63rCn OSntsr! ฐ  -

      Appoint a waste reduction team.  A team has been established and has performed several
      environmental audits for pollution prevention regarding chemicals used within each work group
      Hazardous materials not required for research were moved to a storage warehouse  Each of
      he buildings at the center was assigned a hazard ranking according to the criteria set out by

                                                                                On
     Limit purchases of drum quantities of materials.  A new policy requires a Research Supervisor
     to review any purchases of chemicals in 55-gallon drums.  This should help avoid having
     excess hazardous materials requiring disposal when a project has been completed.
          h            : ?• /ef S SUpP'y ฐf chemica's- Oversupplies of reagent grade chemicals
     have been purchased m the past in an effort to spend year-end funds before they are lost This
     practice will be discouraged in the future.

     Purchase no additional technical grade hydrochloric  acid until supply is exhausted  No
                                                         WaS N-™**, and some of the
     Dispose of chemicals in an appropriate manner.  Employees have been instructed to contact
     the Environmental Manager for instructions on proper waste disposal procedures.

     Store waste solvents and oils in an appropriate area.  The previously existing containment
     system failed during a solvent spill. The area was cleaned and contaminated soil evacuated
     All waste chemical storage has been moved to a covered site with secure secondary
     containment. Decreases in the use of halogenated hydrocarbons have reduced the need for
     storage and disposal of these wastes.

     Inform all employees of the new policies.  The policy has been distributed to all employees
     and has been discussed in each of the work divisions at a safety meeting.  This has resulted in
     an increased awareness of the need to properly store and dispose of wastes
                                           55

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                                       SECTION 16

                                  U.S. POSTAL SERVICE
            BUFFALO GENERAL MAIL AND VEHICLE MAINTENANCE FACILITIES

      A PPOA was conducted at two U.S. Postal Service (USPS) facilities in Buffalo, New York in
1992  The pollution prevention alternatives apply to commercial package-handling operations, as
well as other government and commercial vehicle- servicing facilities.  This project was funded by the
USPS through an interagency agreement (IAG).

16.1  FACILITY DESCRIPTION

      The USPS General Mail Facility  (GMF) and a separate building housing the Vehicle
Maintenance Facility (VMF) are located on  approximately 25 acres in Buffalo, New York.  The GMF
consists of a three-story office building and a one-story 276,000 square foot mail processing floor.  A
one-story building several blocks away houses the Computerized Forwarding System and the
Undeliverable Bulk Business Mail (UBBM) operation. Dock positions for more than 50 trucks are
located on the east and west sides of the GMF building.  The building is occupied 24 hours every
day of the year and is occupied by anywhere from 688 to 1,515 full-time employees at a given time.

      The Buffalo GMF receives nearly two million pieces  of mail each day for processing; nearly 3
million pieces are sent out daily for delivery.  The GMF serves as an area distribution center for
several zip code areas, and also processes all mail  from the eastern seaboard destined for Canada.
As a  major passageway between the U.S. and Canada, the Buffalo GMF provides space for the U.S.
Customs and serves as a concentration center for mail transportation equipment.

      The USPS operates the largest civilian vehicle fleet  at its 350  VMF's  nationwide.  The Buffalo
VMF  is located in a one-story  121,061 square foot building. A staff of 32 automotive technicians
maintain the fleet of 1,200 vehicles, which  range from light delivery to 18-wheel tractor trailers. The
major operations include vehicle repair, servicing, and painting.  In one year, approximately 2,500 to
3,000 maintenance and repair jobs are performed and 500 vehicles completely painted with USPS
colors at the VMF.

16.2  AREAS FOR POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

      A pollution prevention opportunity assessment was conducted which addressed the feasibility
of potential source reduction and recycling opportunities and resulted in a limited pollution prevention
 plan. The assessment focused on mail processing and vehicle maintenance operations.
 16.2.1
Mail Processing
       The GMF generates approximately 537 tons of waste per year, at an annual solid waste
 disposal cost of approximately $42,000. The wastes are comprised of 253 tons of old corrugated
 cardboard (OCC) two tons of computer paper, 46 tons of mixed office paper, 30 tons of metals,  13
 tons of plastic film  192 tons of "undetermined wastes," and an undetermined amount of machinery
                                             56

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 maintenance wastes (oil, grease and parts-cleaning solvent).  The three areas responsible for
 generating the majority of the waste are the offices, the mail sorting floor, and the loading/unloading
 QOCKS.
 16.2.2
 Vehicle Maintenance Facility
       Operations performed at the VMF generate waste streams typical of a vehicle maintenance
 operation, including oil filters, spent lead acid batteries, brakes, cleaning solvent waste paint
 containers, waste paint and thinner, soiled rags, buffing pads, cracked corn absorbent, used oil and
 fluid, used antifreeze, and radiators.  Annual waste disposal costs are $21,645.

 16.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS
 16.3.1
 General Mail Facility
       Several pollution prevention initiatives were already in place at the time of the PPOA
 Recycling programs had been instituted at the GMF for corrugated cardboard, ferrous metal" and
 aluminum, undelivered bulk business mail, office paper, and laser printer cartridges.  Energy-efficient
 fluorescent lighting and interior storm windows were installed .throughout the GMF to reduce lighting
 and energy requirements, and electric hand dryers were installed to replace disposable paper towels
 potentially resulting in an annual savings of $50,000, before electricity and maintenance costs.

       Additional pollution prevention options were developed for the GMF WHICH addressed the
 following  items: (1) corrugated containers; (2) paper; (3) plastic film and strapping; (4) pallets-  (5)
 rigid plastic containers; (6) oils, adhesives, and paints;  and (7) cafeteria wastes
 16.3.1.1
Corrugated Containers-
      This waste could be reduced by requiring vendors to provide products in the least possible
amount of packaging, using corrugated plastic trays instead of cardboard cartons for internal mail
distribution,  and reusing cardboard boxes until unusable, then recycling them
16.3.1.2
Paper-
      Paper waste could be reduced by initiating a duplex copy policy, reducing the distribution of
copies, and using reusable rigid plastic or metal cards instead of colored paper destination slips.

16.3.1.3       Plastic Film and Strapping-

      Most plastic film (shrink wrap and stretch wrap) is removed from packaged incoming mail
This type of waste can be significantly reduced by converting to reusable cloth or net bags wheeled
bins, or metal  cage containers for mail redistribution.  Plastic film that is not eliminated can be
recycled through the Mobil Chemical Company's Rochester manufacturing facility, which will pay
$0.11 to $0.12 per pound. Using monochromatic, rather than multi-colored plastic strappinq mav
assist in recycling the material.
                                              57

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16.3.1.4
Pallets-
      Plastic pallets, while more expensive to purchase, are more durable than wood and result in a
reduced cost per use.  Plastic pallets made of high density polyethylene (HOPE) using twin sheet
thermal forming are recyclable and when broken or no longer usable can be returned to the
manufacturer as feedstock for new pallets.

16.3.1.5      Rigid Plastic Containers-

      Waste plastic containers could be reduced by requiring bulk deliveries in refillable  containers.

16.3.1.6      Oils, Adhesives, and Paints-

      Strict inventory control and good housekeeping measures could reduce waste oils, adhesives,
and paints caused by expired material, spills, and overstocking.
16.3.1.7
Cafeteria Wastes-
      Cafeteria wastes can be reduced by instituting discounts for customers using their own mug for
beverages, by allowing  only reusable food service materials (e.g., plates and bowls),  and by
composting food wastes.
16.3.2
Vehicle Maintenance Facility
       Employees have already initiated several pollution prevention measures in this area including
 the following:  using separate paint cups for different color paints; painting lighter colors before darker
 colors to reduce solvent consumption; collecting unused paint prior to cleaning the equipment in the
 solvent sink; saving excess paint in one-gallon containers for use on the next appropriate job; and
 washing parts in  a  solvent sink.

       Options for reducing wastes associated with painting operations include using low VOC paints
 (water-borne or high-solids coatings), using an HVLP paint application  system, using a paint mixture
 system, installing a gun washer station, providing operator training,  reducing and recycling paint
 cans,  cleaning buffing pads, and on-site solvent distillation and recycling.  Some of these options are
 described below.
 16.3.2.1
 Low VOC Paints--
       There are several low VOC paints and coatings available.  These include water-borne
 electrocoating, waterborne non-electrocoating, two-component high solids, single-component high
 solids, and isocyanate-free paint.  Water borne coatings are formulated with water rather than organic
 solvents.  While the average solvent-based coating contains 5 to 6 pounds of solvent per gallon,
 waterborne coatings contain 0.5 to 3.4 pounds per gallon, significantly reducing VOC emissions.
 Also,  waterborne coatings can be cleaned with soap and water, eliminating use of cleaning solvents.
 16.3.2.2
 Paint Mixture System-
       The amount of paint needed for a job and the necessary mixture of paint thinner is presently
 measured by the painter using best professional judgement.  This can result in improperly formulated
                                                58

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  paint and/or leftover or surplus paint. Commercially available paint mixers accurately measure and
  weigh the necessary amount of paint according to manufacture specifications.

  16.3.2.3     Paint Can Reduction  and Recycling-

       Paint is presently purchased in quart or gallon metal containers.  Empty paint cans are drained
  and disposed of in the trash.  It may be possible to order paint in five gallon reusable plastic
  containers which, when empty, would be picked up by the supplier.  If a large quantity of limited
  colors is needed and the paint will be used before expiration dates, buying in bulk may also represent
  a viable option.
 16.3.2.4
Buffing Pad Cleaner-
       The buffing pad cleaner is an example of a low cost pollution prevention option.  A simple
 device is commercially available for cleaning the buffing pads used to polish the newly painted
 vehicles. The buffing pad is strapped into place on top of a machine the size  of a ten gallon drum
 A rotating disk brushes off the paint dust contained in the pad, which can be reused rather than
 discarded.
 16.3.2.5
Aqueous Cleaners-
       Using aqueous cleaners is an example of a relatively simple pollution prevention option with
 significant benefits.  The primary benefits of using an aqueous cleaning system are that it reduces
 the occupational hazards and waste management costs associated with solvents parts cleaning.
 These detergents, acids, and alkaline  compounds displace the oil rather than dissolving  it in organic
 solvent and should be of the type that readily releases the separated oil for collection  When no
 substitute is available for solvent cleaners, emphasis should be placed on minimizing waste
 generation by cleaning only as much as is necessary, minimizing losses associated with
 inappropriate uses (such as spills), and replacing solvents only when necessary.

      Other possible pollution prevention options identified for the VMF include good operating
 practices for parts cleaning, on-site solvent distillation and recycling, on-site antifreeze recycling,
 inventory control and better housekeeping, improved waste management cost tracking, and employee
 participation  in pollution prevention.

 16.4  RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      Several of the identified options will  be evaluated for incorporation into similar USPS facilities.

 16.5  STATUS OF IMPLEMENTATION

      Many of the recommendations made in the PPOA have been successfully implemented at the
 Buffalo facility.  Waste management costs for FY93 were reduced by $62,333 from their 1992 values
Additional cost reductions are expected as further plans are implemented.  Table 1 details the
projected cost benefits from the PPOA and the actual benefits from FY93 (3).

      Approximately 624 tons of solid waste were disposed of by the GMF in  1992, incurring disposal
costs of $42,120.  In fiscal year  1993, waste generation was reduced to approximately 244 tons, A
                                             59

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new waste hauler was contracted, and waste disposal costs for fiscal 1993 were approximately
$20,000, representing more than a 50 percent reduction from 1992 costs.

      Recycling and pollution prevention programs have been implemented in several areas of the
facility, with varying degrees of success. The following sections contain brief descriptions of notable
program elements at the GMF and VMF.
            TABLE 1.  COMPARISON OF ESTIMATED AND ACTUAL RETURN FROM
                       SOURCE REDUCTION AND RECYCLING AT THE
                             BUFFALO GENERAL MAIL FACILITY3
Action

Recycle Corrugated Cardboard
Recycle Computer Paper
Recycle Mixed Office Paper
Improve Division of Scrap Metals
Recycle Plastic film
Replace Paper Towels with Electric Air
Dryers
Total Benefit
Potential Benefit
Based on PPOA Study
$17,228
529
5,035
2,334
3,927
21,681

$50,734
Actual Benefit

$22,828
399
5,035
5,168
0
28,525

$61,955

 16.5.1
General Mail Facility
 16.5.1.1      Corrugated cardboard recycling-

      Approximately 312 tons of corrugated cardboard are collected annually by the GMF.  Annual
 savings of approximately $22,878 result from eliminated collection and disposal fees. Current plans
 include the purchase of a baler, which will generate a net annual revenue from sales of baled
 corrugated cardboard.

 16.5.1.2     Laser cartridges and printer ribbon recycling-

      The GMF was recycling approximately 60 laser printer cartridges per year at the time of the
 original PPOA.  As of FY93, that figure has been increased to 100 per year; additionally, 150 black
 printer ribbons are re-inked instead of being discarded.
                                             60

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 16.5.1.3
Aluminum cans—
       Approximately $75 to $80 per month in revenue is generated from recycling aluminum cans.
 The State of New York offers a five-cent deposit for each can. Approximately 1,500 to 1 700 cans
 per month are recycled by the GMF.

 16.5.1.4      Scrap metal-

       Approximately six tons of scrap metal are generated monthly between the GMF and the VMF.
 Seventy tons of scrap were recycled in FY93, including letter sorting machine carts, old  conveyor
 parts, tubs and buckets, and vehicle doors, roofs, and axles. Annual savings in avoided  disposal and
 collection fees were $5,168 for FY93.

 16.5.1.5      Computer and mixed office paper-

       Color-coded collection bins are used to separate computer paper from office paper. The GMF
 recycles 200 pounds per week of computer printouts, or 5.2 tons per year.  Avoided disposal and
 collection costs resulted in savings of $5,434 for FY93.  No specific data are available for mixed
 paper.
 16.5.1.6
Plastic film-
      Attempts to recycle the plastic film (stretch and shrink wrap) used to wrap pallets have been
 unsuccessful.  The recycling company has stringent requirements for product cleanliness which are
 difficult to achieve.  Because the recycler insists on delivery, the transportation costs outweigh any
 potential revenue from recycling the film. To date, no progress has been made on finding an
 alternative to shrink wrap.

 16.5.1.7      Electric hand dryers-

      The GMF spent approximately $30,100 per year on paper towels, including the purchase and
 disposal of 600 cases per year.  Studies have shown that electric hand dryers are a possible means
 to avoid these costs. Funds have been approved to purchase 55 electric hand driers for the GMF
 with an estimated payback period of six months or less.                                     , '

 16.5.2       Vehicle Maintenance Facility

 16.5.2.1      Paint waste reduction-

      Paint wastes comprise approximately 16 percent of all hazardous wastes generated by the
VMF and are responsible for half of the hazardous waste management costs.  The three primary
PPOA recommendations for reduction of paint related wastes are described below.

      Investigate  water-based or high-solids paints - Investigations at the VMF indicate that water-
      based primers may be substituted for conventional ones without affecting performance. Water-
      based top coatings, however, have been shown to exhibit insufficient durability. One solution
      currently under evaluation at the VMF involves the use of a waterborne primer with an acrylic
      enamel top  coat.
                                             61

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      Conversion  to HVLP paint application systems - HVLP spray guns operate at a much lower
      pressure than conventional spray guns,  resulting in considerably lower paint waste due to
      bounce-back.  Two HVLP spray guns were purchased for the VMF and have resulted in
      improved-quality paint jobs and savings in paint usage. Because the equipment was installed
      only recently, the VMF has not been able to provide accurate data on the incurred savings.
      The VMF's conservative estimate is a twenty percent reduction in paint usage per vehicle, with
      an associated reduction in VOC emissions. These figures are based on a four-month test
      period.

      Install a paint-gun washer station - At present, paint guns are washed in an open solvent
      tank. The PPOA recommended using specially designed enclosed paint-gun washing stations
      which reduce VOC emissions by 75 to 90 percent. The VMF has plans to purchase a paint-
      gun washer station during FY94.                                       ป
16.5.2.2
Aerosol chemicals--
      Aerosol chemical use has been eliminated in all postal facilities in the western New York
District. Portable sprayers are used to dispense maintenance products, which are purchased in bulk
five gallon containers. As a result, significant reductions have been achieved in waste aerosol cans
and packaging.  In  1992, over 2,400 aerosol paint cans were used at the VMF.

16.5.2.3      Solvent cleaning waste reduction--

      In the past, approximately 4,100 gallons of waste petroleum naphtha were generated annually
during brake and engine parts cleaning operations at the VMF. This represented about one third of
the total hazardous waste costs.  The VMF has recently converted to an aqueous cleaner for
cleaning brakes, which will eliminate over 2,000 pounds of hazardous waste annually.  In addition, a
longer- lasting solvent for cleaning automotive parts is in use which  should also result in a substantial
reduction in hazardous waste generation.

16.5.2.4      Antifreeze recycling-

      Historically, the VMF has purchased  about 750 gallons of antifreeze annually. Approximately
300 gallons per year of antifreeze must be  disposed of as hazardous waste.  Although there is no
cost for antifreeze disposal at this time, the VMF has investigated recycling antifreeze to avoid
possible future costs, and to reduce raw material expenditures. The VMF began  recycling antifreeze
through a private contractor in January 1994.
 16.5.2.5
 Oil filter recycling-
      An oil filter crusher was installed at the VMF in 1993.
 to a local smelter for recycling as scrap metal.
                                           Oil filters are drained, crushed, and sent
 16.5.3
 Northeast Area Pollution Prevention Initiatives
      The recommendations of the PPOA for the GMF and VMF were officially released in March
 1993 to all 25 vehicle maintenance managers in the Postal Service Northeast Area.  At the same
 time, the Northeast Area Environmental Compliance Office also made several other pollution
 prevention recommendations to VMF managers.  The Northeastern Area VMF  managers have
                                              62

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committed to a strong program of waste reduction and pollution prevention with the following five
priority goals.

      Substitute nonhazardous products for hazardous cleaning products to reduce hazardous
      waste generation.

      Eliminate the use of hazardous parts cleaning solvents.

      Adopt on-site antifreeze recycling.

      Install high-volume/low-pressure spray paint guns.

      Explore the use of water-based paints.

      A comprehensive pollution  prevention plan has been written for all VMFs in the Northeast Area
and is being supplemented by site-specific plans for each of the 25 VMFs.  By September 30, 1994,
all 25 VMFs will have adopted site-specific pollution prevention plans consistent with the area'wide
plan.  Table 2 shows the progress that the 25 VMFs have already made toward adopting these
pollution prevention goals (3). The plans of the Northeast Area VMF managers are quite ambitious
and include adoption of EPA's 33/50 program and a commitment to eliminate all hazardous materials
by 1995.
                                             63

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       TABLE 2. WASTE PREVENTION AND RECYCLING OPERATIONS IN PLACE
          AT USPS NORTHEAST AREA VEHICLE MAINTENANCE FACILITIES
On-site
Location Antifreeze
Hartford, CT
New Haven, CT *
Stamford, CT
Waterbury, CT
Boston, MA *
Chelsea, MA D
Fall River, MA
Lawrence, MA *
Lowell, MA
Lynn, MA
Pittsfield, MA
Springfield, MA *
Worcester, MA
Portland, ME
Manchester, NH
Albany, NY
Binghampton, NY
Buffalo, NY
Elmira, NY D
Rochester, NY D
Syracuse, NY *
Utica, NY
Providence, Rl *
Framingham, MA *
Brockton, MA *
Total in Place 21
Oil
Re-refined Filter
Motor Oil Crusher
*
*
*
*
*
*

* *
* *
* • *
*
D
D

' *
* *
*
* . *
* *
* ' *
* *
*

*
; D
11 19
Clean
Tire Separator
Retread or with
Recycle Microbe
*
*
*
*
*
*
*
*
*
*
*
* *
*
* *
*
* *
*
* *
*
*
*
*
* *
*
*
25 5
Aqueous/
Low
Hazard
Cleaner

*
*
*
*
*
D
n
n
n

n
n
#
n
*
*
*
n
n
*
*
n
n
n
12
Aqueous
Brake
Cleaner HVLP

*
*



X
*
*
*


*
* ;

* *

* *
*
*
*
it
x
*
x D
11 10
Source: Northeast Area Vehicle Maintenance Managers, April 8, 1994
D = Planned for Fiscal Year 1994
x * These facilities use a HEPA filter unit for brake cleaning
                                        64

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                                         SECTION 17

                                       INTERAGENCY
                                THE WHITE HOUSE COMPLEX

      At the invitation of President Clinton in 1993, staff from the U.S. EPA, the District of Columbia
 Environmental Regulations Administration of the Department of Consumer and Regulatory Affairs
 (DCRA), and technical experts conducted an environmental audit at the White House Complex.  In
 addition to a preliminary assessment of pollution prevention and solid waste management
 opportunities discussed here, the audit also included compliance and environmental management
 systems.  This project was performed through in-house EPA support.

 17.1  FACILITY DESCRIPTION

      The White House Complex is made up of the White House Residence and the Old Executive
 Office Building (OEOB). The White House Residence includes the Executive Residence structure
 and surrounding grounds. The facility employs 89 people, including maintenance staff, function
 activities staff, administrative staff, preservation staff, and grounds staff.  The Residence organization
 is managed by the Chief Usher who is assisted by a staff of four assistant Ushers (for Maintenance,
 Activities, Administrative, and Preservation) and the Superintendent of Executive Grounds.  The staff
 support the many inherent functions and roles of the Residence including  serving as a public
 museum, offering  Residence tours, and conducting official Presidential ceremonies and functions.

      The OEOB  has an estimated occupancy of 1,000 and primarily provides office space, meeting
 rooms and press facilities.  Other portions of the building include restrooms, a cafeteria, service
 kitchens and dining areas, snack bar service rooms,  maintenance rooms,  and a loading dock.

 17.2  AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

      The environmental audit and preliminary assessment of pollution prevention and solid waste
 management opportunities evaluated activities associated with  the paint shops; grounds
 maintenance; heating, ventilating and air conditioning  (HVAC)/chiller operations; office operations;
 and general operations. Wastes generated by the paint shops  include waste paints and solvents.'
 Approximately 100 to 150 gallons of methylene chloride (dichloromethane) are used at the White
 House Complex each year to strip paint from steel trim and wood furniture, and other caustic
 chemicals are used to strip paint from older surfaces composed of horsehair plaster.  Maintenance of
 the White House building exterior requires approximately 22 gallons  of paint each week, generating •
 atmospheric VOC  emissions and cleanup wastes.  Large amounts of water are used for the HVAC
system and for groundskeeping activities,  which  also produce waste from the use of pesticides and
 herbicides for grounds maintenance.  Office operations primarily produce paper waste, mostly in the
form of photocopy and printer paper.
                                            65

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17.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS
17.3.1
Paint shops
      Three major pollution prevention options for the paint shops involve: (1) solvent use, (2) paint
stripping, and (3) exterior coatings.
17.3.1.1
Solvent Use-
      Solvent use can be reduced by replacing solvent only when it is completely saturated with
paint or by using new technologies, such as paint guns. Solvent recycling is also an option.  An on-
site still can be used to recycle solvent. With a cost of $2,500, the still represents a payback period
of less than  six months. For solvents to be recycled, however, they must remain segregated.
17.3.1.2
Paint Stripping-
      Approximately 100 to 150 gallons of methylene chloride are used at the White House Complex
each year to strip paint from steel trim and wood furniture.  Other caustic chemicals are used to strip
paint from older surfaces that are made of horsehair plaster.  Methylene chloride is a hazardous
material, contains a high level of chemically defined VOC, and is an ozone-depleting compound and
a suspected carcinogen.  The primary pollution prevention option is to use a suitable substitute.  One
possibility is the use of non-chemical paint stripping methods, such as corn  cob blasting, or the
Sponge-Jet, which blasts sponge-coated garnet onto the substrate. Additional research and testing
is needed to determine if these methods would be suitable for White House Complex applications.
17.3.1.3
Exterior Coatings-
      Approximately 22 gallons of paint per week are needed for maintenance of the White House
building exterior.  Because there is a continual need for only one color, a paint coating alternative
such as heat-applied thermal plastic paint (a type of solvent-free powder-coated paint) should be
considered.  Additional study is needed to determine if this type  of coating would be appropriate for
existing exterior wood finishes; however, if feasible,  its use would represent a significant reduction in
pollution.                             ;
17.3.2
Grounds Maintenance
      Pollution prevention options include reducing water usage by installing a sensor/moisture
analyzer to determine when watering ofthe lawn is needed, and providing astroturf or paved surfaces
for heavily used areas, such as the helicopter landing area and the west side of the north lawn where
reporters are permitted to deliver news reports.
17.3.3
HVAC/Chiller Operations
      Currently, the OEOB chiller processes five gallons of water per minute or 2,628,000 gallons
per year.  A pollution prevention option that should be investigated is using a system that recycles
the water in-process.
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 17.3.4
 Office Operations
       The primary pollution prevention options in this area relate to the reduction in paper use
 through source reduction and the use of recycled-content and source-reduced products and supplies.
 17.3.4.1
Reduction in Paper Use-
       As is true in most office settings, the White House Complex generates substantial amounts of
 paper, mostly in the form of photocopy and printer paper.  Short term activities such as two-sided
 copying, eliminating facsimile cover sheets, routing documents instead of providing each reader a
 copy, and centralizing files can be accomplished  by changing employee behavior through education.
 Longer range solutions such as microfiching essential duplicate files, and use of local area and other
 computer networks, may involve more costly investments, but can significantly reduce paper waste.

 17.3.4.2      Use of Recycled-Content and Source-Reduced Products and Supplies-

      The White House is in a unique position to serve as a model for other Federal agencies and
 the general  public.  It could, therefore, encourage recycling of existing paper by purchasing recycled-
 content and source-reduced products and supplies.
 17.3.5
General Operations
      Pollution prevention recommendations in this area include pollution  prevention planning,
 awareness, and education; consolidating maintenance functions now performed separately by'the
 White House Residence and OEOB staffs; restoring and upgrading the OEOB to reduce
 maintenance; practicing water conservation; and establishing pollution prevention policies.  An
 example is labeling White House functions "green." Suggestions for accomplishing this include the
 following: sending invitations on recycled paper using vegetable-based inks; printing on both sides of
 menus and function programs; eliminating or reducing the amount  of disposable items used by
 substituting durable napkins, utensils, drinking cups, etc.; donating unused food to a local charity; and
 publicizing the function as being an environmentally sensitive one.

 17.4  RESEARCH, DEVELOPMENT, AND DEMONSTRATION

      Several areas could be researched, demonstrated and evaluated for use at the White House
 Complex, including a less hazardous paint solvent alternative,  alterative paint stripping methods, an
 exterior paint coating alternative,  and using a system  to recycle water in-process for the OEOB
 chiller.

 17.5 STATUS OF IMPLEMENTATION

     The White House Environmental Audit Report was not released until February 1994. However,
 because of a  Presidential  commitment to "greening" the White House, several pollution prevention
projects are ongoing, while many others are planned.  Some of the ongoing projects are described
below (4).
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17.5.1
Water conservation
      Water-saving fixtures are currently being installed in restrooms, kitchens, and other areas.
Water conservation is also a consideration in landscaping. Sprinkler heads are being replaced or
adjusted to minimize water consumption.  Future plans call for "cascading" uses for water; for
example, old drinking water is used to water lawns.
17.5.2
Pest Management
      A grounds maintenance plan is currently being developed which will reduce fertilizer and
pesticide use, change mowing practices, improve irrigation and reduce runoff.
17.5.3
Eliminating Chlorofluorocarbons (CFCs)
      HVAC systems should be renovated to eliminate CFCs and to operate more efficiently. A
comprehensive HVAC system upgrade will require Congressional approval and may take several
years.
17.5.4
Energy-efficient appliances
      White house refrigerators and lighting fixtures have been replaced with energy-efficient models
offering substantial reductions in energy consumption.
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                                         SECTION 18

                                        INTERAGENCY
           TIDEWATER INTERAGENCY POLLUTION PREVENTION PROGRAM (TIPPP)

      The Tidewater Interagency Pollution  Prevention Program (TIPPP) is a cooperative effort among
 the U.S. Environmental Protection Agency (EPA), the Department of Defense (DOD) and the National
 Aeronautics and Space Administration (NASA) to develop and implement multi-media pollution
 prevention plans for each participating installation, outlining short- and long-term projects that are
 readily transferrable to other communities and/or settings.  The TIPPP was initiated in 1991.

 18.1  FACILITY DESCRIPTION

      The TIPPP host facilities  are located at Fort Eustis (Army), Langley Air Force Base, NASA
 Langley Research Center, and Naval Base Norfolk.  Community activities/facilities represented at
 these installations include administrative offices, materials distribution, housing/food services, new
 construction, land management  activities, procurement/acquisition, maintenance operations, vehicle
 storage and fueling areas, and manufacturing processes.
 18.1.1
Fort Eustis
      Fort Eustis and Fort Story, a sub-installation of Ft. Eustis since 1962, are the home of the U.S.
Army Transportation Center located in eastern Virginia. One of 16 Training and Doctrine Command
(TRADOC) installations, Fort Eustis covers 9,000 acres of land which ranges from tidal wetland to
bottomland forest.  The U.S. Army Transportation  Center at Fort Eustis has two major missions: (1)
train Army transportation personnel in various tasks, including the maintenance and operation of
helicopters, oceangoing vessels, and land-based transportation equipment; and (2) provide field
support and equipment during a conflict, such as Operation Desert Storm.  Several active-duty
commands are located at Fort Eustis. Fort Eustis also supports a number of U.S. Army schools and
tenant activities.

18.1.2       Langlev Air Force Base (LAFB)

      Langley Air Force Base is located in Hampton, Virginia and comprises approximately 2,900
acres. More than 9,000 military and 3,000 civilian  employees work and/or  live at the base. 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.  The 1st Fighter Wing flies UH-1N
helicopters and F-15 and C-21 aircraft.
18.1.3
NASA Langlev Research Center fLaRC)
      Nasa Langley Research Center is an 807-acre research center in Hampton, Virginia dedicated
to aeronautical and space research.  At this facility, which employs about 6,000 people, LaRC
conducts research programs to advance aircraft design, and to develop advanced transportation
systems and space station technologies.  Activities include large-scale physics and chemistry

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research, engineering and design testing programs, and routine equipment maintenance. These
activities involve the use of approximately 6,000 different chemicals and materials, and yield
approximately 280 tons of hazardous waste and 780 tons of municipal waste each year.
18.1.4
Naval Base Norfolk
      Located in the Tidewater, Virginia area, Commander, Naval Base (COMNAVBASE) Norfolk
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 mission of the Base is to provide quality support to the
tenant commands.  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 waste streams.

18.2  AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

      As a cooperative demonstration program, the TIPPP was designed to support pollution
prevention efforts to:  (1) reduce solid and manufacturing  wastes generated at the participating
facilities; (2) improve energy efficiency at the installations; (3)  test the use of alternative,
environmentally protective materials that still meet research and military specifications; (4) improve
procurement practices and inventory controls; and  (5) reduce  non-point source environmental
problems.

18.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

      WREAFS Program support to TIPPP  has been undertaken in a base-by-base  approach.  Early
work in the program resulted in the development of several pollution  prevention recommendations.
These include actions related to the follpwing:  chemical material management; land management
practices;  municipal solid wastes; laboratory wastes; electroplating; painting operations; metal
working (surface preparation and shaping); halogenated and non-halogenated solvents; and
depainting operations.  Recommended  options for  each are given below.
18.3.1
Chemical Material Management
      Chemical material management consists of a series of tools for controlling the procurement,
distribution, and use of chemicals. Examples of the various activities that can become an integral
part of chemical material management are described in the following sections.
18.3.1.1
Procurement--
      Some of the procurement practices that generate excessive waste and that should be avoided
include: allowing customers to reject usable chemicals that have been recertified with extended shelf-
lives; requiring that the supply element maintain stockpiles of materials that expire; and ordering
chemicals without previous use rates and without verifying the appropriateness of the materials for
the specified activity.  Automatic ordering can reduce the amount of expired materials while meeting
all supply demands of the facility.
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 18.3.1.2      Employee Training-

       Train employees in the safe use of chemicals, spill procedures, and proper recycling or
 disposition of chemicals.
 18.3.1.3
 Inventory Control-
       Practice first-in first-out inventory control, whereby older materials are used first. When
 possible, assign control of hazardous material supplies to a limited number of individuals trained to
 handle the materials.  Finally, limiting access to supplies also helps employees conserve raw
 materials.

 18.3.1.4      Chemical Storage-

       Routinely check the chemical storage areas for leaking containers,  rusted or damaged
 containers, or containers that have the potential to leak.  Store chemical containers off the floor for
 improved leak detection.  Store chemicals to preserve their chemical integrity.  For example, solvents
 should be stored to avoid temperature extremes.  Assign one person the responsibility of checking
 for leaks and maintaining  the storage area.

 18.3.1.5      Proper Labels-

       Assure that containers are properly labeled and dated.  Replace labels before they deteriorate.
 Unlabeled chemicals are often disposed of unnecessarily,  increasing  disposal and replacement costs.

 18.3.1.6      Return Empty Containers-

       Empty containers often contain hazardous residue and should be returned to the supplier for
 recycling  whenever possible. Out-of-date material returned to the supply center may qualify for
 recertification, enabling continued use or recycling.  Some suppliers give credit toward the next
 purchase for returned material.

 18.3.1.7     Chemical Use Tracking-

      Comprehensive chemical use tracking involves the use of a computer system to track the
 procurement, storage, distribution,  use and  disposal or recycling of every chemical used. The
 requestor must justify the need  and qualifications for handling the chemical being  requested.
 Instructions are issued with the  chemical for proper use, recycling  or disposal. A  bar code system for
 hazardous material containers should also be considered.  The code would contain information on
 the chemical  content, the recipient,  the date issued, the chemical's intended use,  and the chemical's
 expiration date.
18.3.2
Land Management
      Land management can significantly influence non-point source pollution and stormwater runoff,
which are major sources of nutrients and significant sources of sediment and toxic pollutants from
urban runoff (e.g.  metals, pesticides, oil and grease).  Existing pollution  prevention options relate to-
(1) flightline and runway management; (2) erosion and sediment control; (3) nutrient management
planning; (4) pesticide management; (5) forestry management practices; (6) road construction and

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maintenance; (7) urban runoff in developing areas; (8) housing; and (9) wetland and riparian area
protection.
18.3.2.1
Flightline and Runway Management-
      The largest potential sources of contaminants to stormwater from flightlines and runways are
fueling operations, vehicle maintenance/washing, and deicing practices. Best management practices
strive to prevent fuel from coming into direct contact with rain and stormwater runoff. Examples of
methods to accomplish this aim include: fuel-spill management; covering chemical storage areas;
use of low phosphorous content cleaning agents; and use of a less environmentally  disruptive deicing
agent.
18.3.2.2
Erosion and Sediment Control-
      Best management practices include: maintaining perennial vegetative cover on vacant land,
slopes, and around wetlands and  other waterbodies; leaving undisturbed vegetative buffer strips
adjacent to streams,  wetlands and waterbodies; and constructing sediment retention structures.

18.3.2.3       Nutrient Management Planning-

      Applying the minimum required amount of fertilizer would limit nutrient runoff. This would
require such practices as optimum timing and methods of fertilization to limit loss to runoff,
investigating organic alternatives to chemical fertilizers,  such as compost,  and determining the proper
rate of fertilizer application  based on the vegetation's actual nutrient requirements.
18.3.2.4
Pesticide Management-
      The best method to reduce the environmental impacts of pesticides is to use fewer pesticides
and lower quantities.  Pesticides should only be used when there is an economic gain. In such
cases, an effort should be made to select the pesticide with the least toxicity, leachability,
persistence, and volatility that will still be effective in the desired application.  Pesticides should be
applied in such a way as to minimize their movement into water and exposure of workers and
nontarget wildlife or vegetation.  Since  many pesticides bind to soil and clay particles, practices that
reduce soil erosion are also effective in retaining pesticides on the treated area.

18.3.2.5      Forestry Management Practices-

      The goal of best management practices in forestry is to plan, design, and  operate logging and
silvicultural practices to minimize erosion,  pesticide  use, and hydrologic disruption  to streams,
wetland and waterbodies.
 18.3.2.6
 Road Construction and Maintenance-
       Roads should be located away from wetlands, critical habitat areas, and drainage areas.  Cut
 and fill should be minimized and road culverts should be sized at waterbody crossings to minimize
 hydrologic disturbances. Sweeping and vacuuming road surfaces will remove accumulated dust,
 debris and pollutants, while more frequent mowing may  replace large scale herbicide application.
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 18.3.2.7      Urban Runoff in Developing Areas-

       Recommendations include minimizing impervious surface areas and certain natural
 drainageways.  Development should be located away from critical areas, such as steep slopes  highly
 erodible soils, and wetlands. Where possible, vegetation buffer areas should be retained.

 18.3.2.8      Housing Areas-

       Lawn care nutrient and pesticide use should be reduced, and pet wastes should be managed
 Alternatives to commercial fertilizers, such as compost, can often be used.  Commercial fertilizers,
 when used, should never be used in amounts which exceed the recommended application rates.
 Mechanical weeding should be used whenever possible, rather than wide spread pesticide use.
 Pesticides, when needed, should be organic rather than chemical, and used in spots instead of  broad
 application.

 18.3.2.9      Wetland and Riparian Area Protection-

       Wetlands function  as a natural filter and regulator of nutrients and sediments.  The best way to
 protect wetlands is to leave them undisturbed.  Riparian areas (uplands or floodplain areas
 immediately adjacent to wetlands, streams, rivers or other waterbodies) perform similar functions as
 wetlands and should be protected from disturbance, as well.
 18.3.3
Municipal Solid Waste
      Almost 43 tons of solid waste, (including, but not limited to, scrap metal, paper, wood, and
 aluminum cans) are generated each year by the four facilities participating in the TIPPP program.
 Pollution prevention options include one or a combination of the following: (1) source reduction; (2)
 recycling; (3) composting; and (4) waste-to-energy/incineration.
 18.3.3.1
Source Reduction-
      Source reduction falls into five basic categories: product reuse, reduced material volume
reduced toxicity of products, increased product lifetime, and decreased consumption.  These activities
can be accomplished by: buying in bulk; avoiding the use of disposable items (razors,  cameras);
reusing common items (plastic bags); repairing items; buying  concentrates (drinks, laundry soap's)-
using two-sided copies; and using longer-life tires and light bulbs.

18.3.3.2     Recycling-

      Recycling is the  process by which materials otherwise destined for disposal are  collected
reprocessed or remanufactured  for subsequent use.  Commonly recyclable items in the waste stream
include paper, aluminum cans, glass, ferrous metals, plastics, batteries, used oil, and tires.

18.3.3.3      Composting-

      Composting  is the controlled biological decomposition of organic solid waste under aerobic
conditions.  Degradable organics, such as yard waste and food, are easily composted.  High quality
compost can then be used by greenhouses, golf courses, landscaping, public parks, military
installation grounds, and cemeteries.
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18.3.3.4      Waste-to-Energy/lncineration--

      This is the process of burning solid waste and capturing steam to generate power, usually
electricity. The primary use of this energy is for industrial heating and cooling systems.
18.3.4
Laboratory Wastes
      Due to the potential for variability,  laboratory wastes present unique challenges for protective
and environmentally sound management. In addition, laboratories may generate small quantities of
numerous types of wastes, or a specific experiment may generate wastes on a one-time basis.
Existing pollution prevention options include: (1) inventory management; (2) product substitution;  (3)
changes in experimental design; (4) recycling/reuse/recovery; (5) volume reduction; (6) energy
recovery; and (7) waste segregation.

18.3.4.1      Inventory Management-

      Optimize the use of supplies on hand; control dispensed chemicals and check for outdated
solvents and other chemicals.

18.3.4.2     Product Substitution--

      Replace  hazardous materials with less toxic or hazardous substances whenever possible.

18.3.4.3     Experiment Design-

      Improve  current research practices to increase the efficiency of experiments, thereby
decreasing waste generation.  For example, lab experiments conducted on a smaller scale will use
smaller quantities of raw materials.

18.3.4.4     Recycling/Reuse/Recovery-

      Promote reuse of materials, such  as  by solvent recovery through distillation and/or metals
extraction (particularly silver and mercury).
 18.3.4.5
Volume Reduction--
       Reduce hazardous waste volumes with methods such as neutralization, precipitation, and
 inactivation.

 18.3.4.6      Energy Recovery-

       Recover energy, primarily from waste solvents, in the form of fuel supplements.

 18.3.4.7      Waste Segregation-

       Separate waste streams to facilitate treatment, disposal or reuse.
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  18.3.5
Electroplating
        In electroplating, metal ions supplied by the dissolution/of metal from anodes or similar pieces
  are reduced onto the workpieces (cathodes). Depending on the metals involved, electroplating cells
  may use acidic, alkaline, or neutral solutions.  The majority of metals and cyanide discharged into the
  Nation s waterways originates primarily from electroplating activities.  Centralized wastewater
  treatment systems are common and result in the generation of solid-phase sludges   In addition
  spent process solutions and quench baths are discarded when contaminant concentration inhibits
  proper function of the solution or bath. When discarded, process baths usually consist of solid- and
  liquid-phase wastes that may contain high concentrations of cyanide and other harmful constituents.

       Existing pollution prevention options related to electroplating and associated processes include
  (1) training and supervision; (2) production planning and sequencing; (3) process or  equipment
  modifications;  (4) substitutions; (5) waste generation and separation; and (6) recycling.

  18.3.5.1      Training and Supervision-

       Educate plating shop personnel in the conservation of water during processing and material
 segregation.

 18.3.5.2      Production Planning and Sequencing-

       Pre-inspect parts to prevent processing of obvious rejects.

 18.3.5.3      Process or Equipment IModifications-

       Several process or equipment modifications can be used to prevent pollution-  greatly reduce
 rinse water usage through counter current rinsing; increase drain time to allow parts to drain 10
 seconds or more after removal from the bath;  add wetting agents to the plating baths to reduce
 solution adhesion to the parts; increase bath temperature to reduce viscosity and  improve drainage-
 spray rinse to increase rinsing efficiency for non-complex part configurations;  use air agitation in rinse
 tanks to improve rinsing efficiency.

      Changing continuous treatment to a batch system would account for upsets in  effluent levels
 Bath evaporation can be reduced by covering the surface with non-reactive gases or materials  For
 example, a blanket of polypropylene balls can significantly reduce losses  through evaporation
 Processes baths can be continuously filtered to extend their life.  If etching is used only to put a
 shine on the parts, some customers  may agree to buy them unetched, thus reducing  etch bath
 wastes.  Use of low concentration plating solutions rather than mid-point concentrations will reduce
 the total mass of chemicals being dragged  out.

 18.3.5.4     Substitutions-

      Examples of less toxic substitutes that can be  used include zinc instead of cadmium in
alkali/saline environments; nitric or hydrochloric acid  instead of cyanide in certain plating baths- zinc
chloride instead of zinc cyanide;  non-chlorinated  stripper instead of methylene chloride- trivalent
chromium instead of hexavalent plating systems; and non-cyanide instead of cyanide  plating baths
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18.3.5.5
Waste Generation and Separation-
      Wastewaters containing recoverable metals should be segregated from other wastewater
streams.
18.3.5.6
Recycling-
      Any combination of the following techniques can be used to recycle materials: evaporation; ion
exchange; chemical reaction; reverse osmosis; electrolysis;  and reclamation.  Specific recycling
opportunities include:  process chemicals; regeneration of caustic etching solutions; use of acid
copper in the electroplating of plastics; recovery of spent chromatic acid from anodizing; and filtration
and reconstitution of plating baths instead of disposing of the baths when strength has decreased.
18.3.6
Painting Operations
      An estimated total of 250 tons of waste paint, paint and sludge, and 68,000 gallons of thinner
are disposed of annually by the four facilities participating in TIPPP. Paints may contain highly toxic
levels of lead, cadmium, mercury, copper and titanium. Chlorinated solvents used in painting
operations create solvent and paint-bearing sludge, and release VOCs into the air.  Pollution
prevention options include: (1) use of air-assisted airless spray equipment;  (2) use of HVLP spray
painting; (3) electrostatics use; (4) dip tanks use; (5) use of cyclone separator and paint detackifying
compounds; (6) UNICARB™  use; (7) product substitution; (8) recycling; (9) incineration; (10) process
redesign/equipment modification; (11) segregation; (12) heat recovery; and (13) housekeeping
changes/process control.

18.3.6.1      Air-Assisted Airless Spray Equipment-

      This equipment delivers paint to a spray gun under very high pressure. Air is not required
because the pressure at which the coating is delivered to the nozzle is sufficient to atomize the
coating.

18.3.6.2      High Volume/Low Pressure Spray Painting-

      This is  a compressed air paint spraying system utilized to reduce overspray.
 18.3.6.3
 Electrostatics-
       In this process, an electrostatic charge is applied to the workpiece while the surface to be
 painted receives an opposite charge. The spray is attracted to the work surface to such an extent
 that some of the overspray curves back and coats the reverse side of the item.
 18.3.6.4
 Dip Tanks-
       When painting with dip tanks, the workpiece is inserted into a tank of coating, removed, and
 allowed to drain back into the tank.  Excess paint may be removed electrostatically or with a doctor
 blade or squeegee.
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  18.3.6.5     Cyclone Separator and Paint Detackifying Compound-

       These options reduce paint sludge generation. The cyclone separator and paint detackifyinq
  compound are used to dewater and concentrate solids in the paint sludge.
  18.3.6.6
 UNICARB™-
       This coating technique applies coating by using supercritical carbon dioxide, which produces
 vigorous atomization and allows for high quality coating without the use of volatile organic solvents.

 18.3.6.7      Product Substitution-

       Substituting water-based paints for solvent-based products reduces environmental and worker
 exposure to solvent vapors and allows cleanup with soap and water.

 18.3.6.8      Recycling--

       Recycling 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 recovered, reused and recycled.
 18.3.6.9
Incineration-
       Combustion can be used to dispose of still bottom wastes resulting from the use of organic
 solvents.

 18.3.6.10     Process Redesign/Equipment Modification-

       This includes alteration of the existing process design to include new equipment and
 implementation of new technologies or changes in operating practices to reduce waste'generation
 (i.e. housekeeping or maintenance).

 18.3.6.11      Segregation-

       Solvent waste streams should be separated from other solvent and non-solvent waste streams
 Utilization of water can aid in future recovery efforts.

 18.3.6.12      Heat Recovery-

      Spent solvents may be used  as supplementary fuels, "particularly in high-temperature industrial
 processes.

 18.3.6.13     Housekeeping Changes/Process Control-

      Modifications in procurement procedures can optimize the use of raw materials thereby
reducing wastes.  An example would be to purchase only the amount needed to complete the task
avoiding the accumulation of excess paints that may expire and require disposal
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18.3.7
Metal Working
      Metal working operations include metal shaping (e.g., casting, drilling, machining, polishing,
shaping, milling, etc.) and surface preparation (e.g., acid cleaning,  paint stripping, ultrasonic
degreasing, mechanical treatment, etc.).  Such operations typically result in scrap metal and metal
working fluids/oils as waste.  Related pollution prevention  options involve: (1) training and
supervision; (2) process modification; (3) waste segregation; (4) recycling and reuse; (5) loss
prevention and housekeeping controls; (6) metal recovery; and (7)  materials handling and storage.
18.3.7.1
Training and Supervision-
      Instruct operators in water conservation, materials segregation techniques and process
monitoring.

18.3.7.2      Planning and Sequencing-

      Pre-inspect parts to identify reject workpieces prior to processing.

18.3.7.3      Process Modification--

      Possible process changes may reduce atmospheric emissions by using such techniques as
increased free board height, installation of refrigeration coils to condense vapors, rotation of
workpieces before removal to drip solvents back into the reservoir, reduced drag-out techniques,
increased drainage, proper racking, and use of counter-current cleaning to maximize the use of
cleaning solvent prior to disposal or recycling.
 18.3.7.4
 Raw Material Modification-
       Identify and use less toxic materials, including alternatives for chlorinated hydrocarbon cleaning
 solvents such as aliphatic  hydrocarbons, dibasic acid esters, N-methyl-2-pyrrolidone and terpenes.
 18.3.7.5
Waste Segregation-
       Separate waste streams to recover and recycle metals and to avoid contamination of other
 wastes with potentially toxic constituents.
 18.3.7.6
 Recycling and Reuse-
       Devise methods to maximize use of rinse waters and other materials, such as solvents.  Such
 methods include the use of activated carbon or condensers to capture solvents for reuse, acid
 recovery from wastewaters using evaporation techniques, and on-site recycling of solvents by
 distillation, filtration, and gravity separation.
 18.3.7.7
 Loss Prevention and Housekeeping Controls-
       Preventative maintenance on equipment will minimize leaks and spills.  Establishing solvent
 check-out procedures through the shop leader will also assist in minimizing losses.
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  18.3.7.8      Metal Recovery--


  ซ,     Predฐus metals and metal salts can be recovered from sludges and spent process baths

  electro!1 sis   Procedures as evaporation, reverse osmosis, ion exchange', electrolytic recovery, and



  18.3.7.9      Materials Handling and Storage-


        Control inventory, pre-inspect materials, and properly store chemicals to prevent degradation.

  18.3.8        Solvents


        Over 75,000 gallons of solvents, both halogenated and non-halogenated, are estimated to be

  SSfn   hT  yeaf *% thVฐUr TIPPP faCilitieS' These Organic solvents and solvent mbchirwi
  contain such  toxic constituents as benzene, toluene,  methyl ethyl ketone, isobutyl ketone

  SSSS^t1?; methylene chloride, 1,1,1-trichloroethane, and others.  Pollution prevention options
  include. (1) substitut.on; (2) reformulation; (3) process redesign/equipment modification- (4)

                                                tiฐn: (6) minil*ization;  (7) heat recovery; and (8)
18.3.8.1
              Substitution-
 dnp* nntH  subs*ance which is e^er less hazardous or produces a less hazardous waste, but
 does not jeopardize product quality.  An example is the replacement of benzene with aliphatic
 naphthas.                                                                        r
18.3.8.2
              Reformulation-
      Certain products may be reformulated to reduce the volume or toxicity of the waste produced

  h^nnan th acฃฐmp"f ed ^ alterin9 or Iowerin9 ^rtain product specifications (i.e. concentration) '
 changing the chemical composition, or changing the physical state.


 18.3.8.3      Process Redesign/Equipment Modification-


      This includes alteration of the existing process design to include new equipment and
 implementation of new technologies or changes in operating practices to reduce waste generation
 (i.e. use of condensers to capture solvent emissions).


 18.3.8.4      Housekeeping Changes/Process  Control-
man,lff             beuredUCed thrฐUgh careful monitoring of solvent consumption during product
manufacturing and through evaluating current spill-avoidance procedures.


18.3.8.5      Segregation-


      Separating solvent waste streams from other solvent and non-solvent waste streams is
particularly important for halogenated solvent wastes.
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18.3.8.6
Minimization-
      Standardization and consolidation of solvent use can minimize wastes.  As examples, many
solvents can be used for more than one application, or solvents may be reused in the same
application or in other applications, resulting in less solvent consumption.

18.3.8.7      Heat Recovery-

      Non-halogenated spent solvents may be used as supplementary fuels, particularly in high-
temperature industrial processes such as industrial boilers, rotary kilns and blast furnaces.

18.3.8.8      Recycling/Reuse/Recovery--

      Regularly used solvents may be recovered from waste streams using techniques such as
distillation, evaporation or steam stripping.
18.3.9
Depaintinq Operations
      Almost 420 tons of blasting grit, sand blast residue, and paint stripper, and over 1,000 gallons
of thinner, solvent, paint remover, and associated liquids are cumulatively generated by the four
TIPPP facilities each year.  Options for pollution prevention in this area include: (1) using a fluidized
bed unit; (2) substituting less toxic cleaning media; (3) using aqueous cleaners; (4) using emulsion
cleaners; and (5) employing mechanical thermal methods.
 18.3.9.1
 Fluidized Bed Unit-
      A heated bed of fluidized aluminum oxide can be used instead of chemical stripping to remove
 paint, thus increasing solution life.

 18.3.9.2      Less Toxic Cleaning Media-

      An example of substituting less toxic cleaning media includes the conversion from vapor
 degreasing to cold tank cleaning.

 18.3.9.3      Aqueous Cleaners-

      This cleaning method uses water in conjunction with mechanical or ultrasonic agitation and
 relies mainly on the displacement of soils.
 18.3.9.4
 Emulsion Cleaners--
       When solvent and aqueous cleaning are combined, the solvent is dispersed in the aqueous
 phase with the aid of emulsifiers, surfactants, and coupling  agents.
 18.3.9.5
 Mechanical Thermal Methods-
       These methods eliminate the need for solvents and include such techniques as air blast
 systems, abrasive blast cleaning, and dry stripping.
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  18.4  STATUS OF IMPLEMENTATION


  citซc  Dlt!ftj'es fฐr P0l!ution Prevention ^ve been implemented to varying degrees at the four TIPPP
  sites.  Pol ution prevention recommendations developed for each facility do not necessarily reflect
  actions related to all of the areas describe above, because of differences in the nature of operations

                                                                        prevention initiatives at
  18.4.1        Fort Eustis
  i,  M •/? *EuSt'S has conducted several Pollution prevention activities through TIPPP  Fort Eustis
  held ,ts first env,ronmental fair, Ecologic '93, on April 23, 1993.  The fair supported the Armv s

  ZSSSES^             " ^ฐPPr "^ t0 PreS6nt -^^meiiJinSSi^nS^
  nuhiSnn Pฎrsฐ"nelat Fort fustls and In the surrounding communities.  In addition, a quarterly

  everlol in?n    H   ''T^ ^fc/? haS been develฐped for ^tribution post-wide to keep
  everyone informed on pollution prevention and other environmental issues.
 ซซซซ AS Pait ฐf ltS PฐlUtiฐn prevention efforts- Fort E^tis has established an ongoing environmental
 awareness program.  The program has sponsored many activities,  including the following


 '     s/ubL0tStPrfl0nnHStrf1!i0nS ฐf parts.washers and "on-hazardous solvents and lubricants, material
       substitutes,  and other equipment to reduce hazardous wastes.


      A training program in pollution prevention that incorporates the Transportation Officers' Basic
      Course, Warrant Officers' Advanced Course,  Officer Development Courses and Pre Sommand
      Courses.  As of July 1994, over 1,500 personnel on post had participated  in this iralning  An
      annual polluter, prevents workshop is currently being developed.  The three-day worShop
      anticipates training 80 personnel stationed at the installation.                     wumsnop


      An Environmental Day in October 1992 sponsored by the 24th Battalion.


      A Household Hazardous Waste Forum, co-sponsored by the city of Newport News.

Additional pollution prevention initiatives are described below.

18.4.1.1      Chemical Material Management-
centraLThS^T " I" thf Preliminary sta9es <* development.  The first phase will consist of a
centra teed hazardous material issue and storage facility.  Components of the program will include

AuEST,r?-S ฐ?96 ,ฐf haZardฐUS materia'S' reuse ฐf opened materials- developmS of an
                   develฐm
                -       ,                     '       ฐf opened materials- developm   of an
                  ' develฐPment of environmentally friendly substitutes, and appointment of

                                ancl extend the shelf life of materials-  This
18.4.1.2      Land Management--
on
on
   ni^f?401""1 Vl/a^er PKIUtiฐn Prevention Plan is scheduled to be finalized by November 1994
   thl h  ^3 f  9e chf acterization study will be available in August 1995  The study will focus
   the beneficial reuse of sludge generated  at the facility, thereby avoiding the need for sludge
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disposal  A second study has been designed to set up a pilot project to clean, recycle, and reuse
soils currently contaminated with petroleum hydrocarbons which otherwise require disposal as
hazardous waste. The soils will be composted with organic debris and biosolids obtained from the
facility's wastewater treatment plant.

      For the past two years, an environmental fair called "EcoLogic"  has been held during Earth
Week at Fort Eustis.  As part of the fair, field trips are conducted to the wetlands on the installation
and to the Recycling Center.
                                                           From March 1990 to November
18.4.1.3      Municipal Solid Waste-

      A recycling program has been established at Fort Eustis.
1992 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 1992 22 percent of the solid waste generated at Fort Eustis was recycled.  In recognition of
its success, the recycling program was presented the 1992 TRADOC Pollution Prevention and
Recycling Award and was nominated for the Army Pollution Prevention and Recycling  Award.  The
Recycling Center is expanding to approximately double its current size.  A policy memorandum
making recycling mandatory at Fort Eustis is scheduled for release in November 1994.

      The installation Commissary has implemented a program to highlight the use of
environmentally  friendly products,  provide extensive pollution prevention training for the employees,
and post bulletin boards highlighting "Reduce, Reuse, Recycle."  The program includes a storm dram
labeling  effort, which would reduce the inadvertent disposal of wastes and trash into the storm sewer
A waste characterization project is also ongoing at the Commissary, which entails the identification of
recyclable materials.  The project  has been in progress since December 1993 and will continue
through  the end of November 1994. Based on the results of the characterization, recommendations
will be made on the commissary's  internal solid waste management program.

 18.4.1.4     Painting and Depainting Operations-

       Several procedural changes have been implemented based on PPOAs at Fort Eustis. Paint
 shops at Fort Eustis began using  HVLP spray paint guns to apply Chemical Agent Resistant Coating
 (CARC)  The CARC paint is solvent-based and is extremely  hazardous in liquid form, but is non-
 hazardous when dry. Overspray has been reduced by 60 percent, which has in turn reduced paint
 usage by 40 percent, for an annual savings of approximately  200 gallons at $6,700.

       Use of a  lower VOC CARC  paint was considered,  but was eliminated in favor of a single-step
 application of CARC.  The low VOC CARC is only available in a two-step application.  A filter system
 was  added to the paint booth water curtain, which has improved the efficiency of the  paint booth
 operation. A study is underway to eliminate the water curtain altogether. This would eliminate
 wastewater production and would  rely on filters to capture paint particles.
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       An indoor sandblasting facility was completed in June 1992, which has reduced the air
  emissions incurred from outdoor sandblasting.  Recyclable blast media are currently used at the
  sandblasting facility.
  18.4.2
Lanalev Air Force Base (LAFB)
       Langley Air Force Base conducts a number of activities on base and in the surrounding
 communities as part of an ongoing environmental awareness program, the base sponsors an Earth-
 Week program  each year, which includes educational and training programs and poster and art
 contests to promote environmental and pollution prevention awareness.  LAFB attempts to educate
 the base community on environmental issues by using various types of information  sources such as
 federal and state  EPA information publications, Air Force Times, the base newspaper  and closed-
 circuit television.                                                               '     wuocu

       A computer-based reporting system has been developed at LAFB to track hazardous waste
 disposal.  The system identifies wastes associated with each operation, tracks waste disposal and
 provides other information  required to make management decisions. Langley Air Force Base has
 conducted a variety of other pollution prevention activities through TIPPP, as described below.

 18.4.2.1      Chemical Material Management-

       Household chemicals are used for cleaning purposes throughout the base and resident
 housing.  Facilities and residents often have excess household chemicals that may  inadvertently
 become part of the municipal solid waste stream. LAFB recently established a program allowing
 facilities and residents to contribute excess household chemicals so that they may be re-issued for
 use, thereby avoiding disposal.                                                     raoucu .ui

 , A TO  A" antifreeze  recycling system which enables the reuse of antifreeze has been installed at
 LAFB.  The system removes metals, colloid silica, and other harmful particulates in  used antifreeze
 and restores corrosion inhibitors to the reprocessed antifreeze. It is anticipated that this recycling
 system will significantly reduce the amount of hazardous materials entering and therefore leaving  the
 installation.

      The process of powering down an aircraft generates about  one quart of JP-5 fuel which is
 collected in a sump on the aircraft.  The fuel is removed from the sump and deposited into specially
 designed  125- or 660-gallon containers called bowsers.  Recovered  fuel is tested for contamination
 and moisture content.  If results indicate that the fuel conforms to the required specifications  the fuel
 is  returned to the mam fuel storage tank and is mixed through the bulk  storage filter  banks prior to
 being used to refuel aircraft. Approximately 2,400 gallons of JP-5 aircraft fuel are recycled annually
 by this process.  Cost savings  associated with the fuel recovery program are estimated  at $1  848 in
 raw materials and $432 in avoided disposal costs.

 18.4.2.2      Municipal Solid Waste-

      The recycling program at LAFB is divided  into areas that target different parts  of the
installation. The 1st  Moral Welfare Recreation and Services Squadron recycles aluminum cans
office paper, and corrugated cardboard boxes for administrative and  industrial areas.  The residential
communities'  curbside recycling program recycles newspaper, corrugated cardboard  boxes  brown
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paper grocery bags, glass, metal food and beverage cans, aluminum foil and foil products, metal
aerosol cans, metal paint cans, and number 1- and 2-type plastic bottles.

18.4.2.3      Painting Operations--

      A plural component paint system has recently been installed at the LaRC. This system allows
paint to be mixed in the exact quantities and packaged in units for a specific task.  The painting
system is cleaned with thinners which are collected for recycling in separate containers. An HVLP
spray gun is scheduled to be installed at the facility.  The new system will increase the efficiency of
paint use and will reduce the amount of VOC emitted from the facility.  Due to the increased
efficiency'of paint use, it is anticipated that there will be a reduction  in the amount of hazardous
materials entering and therefore leaving the facility.

18.4.3       NASA Lanqlev Research Center (LaRC)

      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.  Activities involve the
use of approximately 6,000 different chemicals.  Accumulated chemical and hazardous wastes
generated during 1992 totaled 180,000 pounds; atmospheric emissions for 1992, including Total
Hazardous Air Pollutants, VOC, Ozone Depleting Compounds (ODC), carbon  monoxide, lead,
nitrogen  oxides, sulfur oxides, ozone, and PM10, totaled 175 tons.

      LaRC's pollution prevention program emphasizes source reduction and  recycling, and
recognizes that eliminating pollutants at the source is generally less risky and less costly than waste
treatment and disposal.  Recycling activities and use of conservation measures at LaRC have
reduced the use  of chlorofluorocarbon by 44 percent, or 19,305 pounds, in 1992 compared with 1989
figures  Total hazardous waste, excluding abrasive blasting debris generated by specific projects,
has been reduced by 45 percent, or 120,605 pounds, in 1992 compared to  1990.  A natural gas-fired
boiler is being installed to reduce air emissions by reducing the use of  inefficient oil-fired units. OH,
when used, will be substituted by a low-sulfur fuel (at or below 5  percent sulfur) to reduce SO2
emissions.

       The focus of pollution prevention activities at LaRC since September 1992 has been the
 Center-wide Pollution Prevention Program. The  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.   Specific
 Program Goals are as follows:

       Systematically reduce and eliminate the use of  hazardous  materials, and the discharge of
       hazardous and solid waste and other emissions to the environment.

       Adopt a comprehensive approach to environmental management that collectively considers all
       environmental media.

       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
        srsss.

        Acquire world-class pollution prevention technologies for distribution throughout NASA.

        LaRC developed a comprehensive pollution prevention plan in 1992 as a first step toward
  meeting the overall goals.  The Program Plan covers three general sectors: (1) energy production
  and use; (2) industrial and commercial processes or operations; and (3) natural resource
  conservation/land management.  The  Program Plan provides the framework within which to identify
  plan  implement, monitor and evaluate specific pollution prevention projects or initiatives  The Plan
  will be updated periodically to identify  new pollution prevention opportunities and to assess the
  performance of existing pollution prevention techniques.

       The LaRC Pollution Prevention  Program consists of a collection of short- and long-term
  projects and initiatives designed to accomplish the Program Plan goals.  Foundation projects have
  been initiated to help build the organizational and physical infrastructure required to support a
  pol ution prevention program. Four foundation  projects underway include developing a chemical
  materials tracking system, constructing a pollution prevention building, conducting training and
 outreach and communication. In addition, action projects, ranging  from recycling municipal solid
 waste and eliminating the use of organic solvents to filtering and reusing antifreeze, are currently
 being conducted at LaRC. These individual pollution prevention  activities conducted under the
 Program Plan are described in the following sections.
 18.4.3,1
Materials Tracking System/Chemical Material Management/Laboratory Wastes-
       Reduction of laboratory waste presents a challenge due to the small amount of specific waste
 material generated by each laboratory.  However, combined laboratory wastes represent about 10
 percent of the total waste stream generated in 1992. Recycling is often impractical due to the
 chemical m.xture and/or the small amount of material generated, and the need for certifiable chemical
 grades.  The nature of research and development work requires specific chemicals, thus making
 chemical substitution  impossible in many cases.

      As part of a pollution prevention foundation project, LaRC staff chose to implement a center-

              Ta KH^ 6m t0 T™6 ฐhemiCal Utilization'  The chemical material trackin9 Astern
 nป    H   *     *e ^P? ?  qUantltl6S ฐf chemicals enterin9 'he Center and determine where
 they are used.  It is estimated that approximately 75 percent of the benefits identified in the PPOA
 with respect to  laboratory wastes can be achieved simply by accounting for the types and quantities
 of chemica s entering  LaRC.  The remaining 25 percent can be achieved by tracking the

                                                                                   is
18.4.3.2      Pollution Prevention Support Building-

      An additional pollution prevention foundation project involves the design and construction of a
support building to house pollution prevention related equipment and materials  The building will
house an electrolytic silver recovery unit for centralized silver recovery from preprocessing wastes
used oil management equipment and a drum crusher                                     w^ies,
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18.4.3.3      Pollution Prevention and Environmental Awareness Training-

      The objective of environmental awareness training, the third pollution prevention foundation
project being conducted at LaRC, is to strengthen the pollution prevention program by enlisting the
support of staff throughout the Center. Training sessions are being developed for environmental
coordinators which are intended to familiarize coordinators with pollution prevention concepts and
techniques and encourage them to  implement pollution prevention at their job sites.  Continuing
briefings for senior management are also being conducted, to introduce top management to the
concepts of pollution prevention with the hope of institutionalizing the commitment for the Pollution
Prevention Program.
18.4.3.4
Communications and Outreach-
      The fourth foundation project at LaRC involves pollution prevention communication and
outreach  Environmental education, communication, and outreach is considered to be a crucial
element of the Pollution Prevention Program. This aspect of the Program will present the role of
pollution prevention and will publicize accomplishments, both internally at LaRC and externally.
Through publicizing pollution prevention accomplishments, it is anticipated that the staff will begin to
understand prevention concepts, including the need for and the benefits of pollution prevention.  This
increased awareness should expand interest in the program.  External publications will enable
transfer of pollution prevention awareness to other facilities,  including those participating in the
TIPPP.

      Through a Communications and Outreach Strategy developed in early 1994, informal focus
qroups were developed to solicit input on how best to maximize employee participation in and
external awareness of the Pollution Prevention Program.  The LaRC Pollution Prevention Program is
described in posters which have been displayed, and a series of fact-sheets has been distributed to
employees and reproduced in the LaRC newsletter. Additional activities  planned for  FY 95 include
flyers, educational presentations, and seminars.

 18.4.3.5      Oil Analysis to Reduce Waste Oil Generation-

       The amount of waste oil  generated during equipment repair or scheduled equipment
 maintenance has been reduced by analyzing equipment oil to determine  whether or not it needs to
 be changed, rather than requiring oil replacement on a schedule.  A sample of used  oil is collected
 semi-annually and sent to  an outside laboratory'for analysis.  Based on the results, the oil is either
 changed or left in the system.  Savings achieved through this program include the cost of
 replacement oil, the labor required to change the oil, and the avoided disposal cost of $100 per 55-
 gallon  drum of contaminated oil.  The cost for off-site laboratory analysis is approximately $23,328
 per year, based on 54 samples per month at $36 per sample.

       The program is currently used for volumes of lubricating oil greater than  100 gallons.  LaRC is
 considering  expanding the program to include equipment with capacities of less than 100 gallons.
 The oil is currently changed every 12 months for such equipment.  The oil analysis program may also
 be applied  in the future to the LaRC vehicle fleet.  A portable oil analyzer designed for m-shop use by
 maintenance staff will be purchased in the near future.  At a cost of $8,635, the system will be used
 to determine which  oil samples require off-site analysis.
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  18.4.3.6      Used Oil Filter Recycling-

       LaRC's Vehicle Maintenance Shop began collecting used oil filters for recycling in May 1993
  The shop routinely changes oil for approximately 700 government vehicles annually  The shop would
  previously dram the excess oil from the filters into a 55-gallon waste oil drum before disposing of the
  filters in the trash. Three drums of used oil filters are recycled annually  under the new program
  LaRC incurs a net cost from sending  oil filters out to be recycled.  Shipping a 55-gallon  drum of
  drained oil filters costs $88; drained used oil filters would otherwise  be included with NASA's solid
  waste, at no additional cost.

  18.4.3.7      Substitute Reusable Absorbent Pads for Single-Use Materials-

       LaRC has implemented a program using reusable absorbent pads in place  of single-use
  absorbent pads and speedi-dry absorbent material at the National  Transonic Facility (NTF) and  the
 Vehicle  Maintenance Shop. Two wringers sit atop disposal drums which collect oil squeezed from
 the pads.  According to the manufacturer, up to 90 percent of the oil can be wrung out of the
 absorbent pads when they become saturated; the pads can be reused up to ten times.

       Before implementation of this initiative, the two facilities purchased approximately 3 200
 pounds  of speedi-dry per year, at a cost of $286, and 863 single-use absorbent pads, socks  and
 piNows per year, at a cost of $1,374.  LaRC  disposed of 18 drums of used absorbents at a cost  of
 $2,040 annually; an unqualified amount of soiled absorbent material was disposed of as solid
 waste and incinerated  in LaRC's waste-to-energy facility.

      This action project was  implemented in January 1994 and is anticipated to reduce the  amount
 of absorbent pads purchased and disposed of at the facility.  The reduced volume of waste absorbent
 materials should decrease disposal costs. Additionally, the oils removed from the absorbent pads
 T*™01160'601 for energy recovery-  Cost  sav'ngs associated with  the reusable  pads are estimated
 at $2,281 per year at these two facilities.  The capital investment for the wringer units will be
 recovered in  about six months. LaRC staff report that reusable pads are better suited for large spills
 where the pads can be wrung out and immediately reused to soak  up the spill
      Wringer units and reusable pads have been in use at the Vehicle Maintenance Shop and the
 National  Transonic Facility since January,  1994.  Vehicle Maintenance Shop staff have not used the
 reusable pads,  because the large reusable pads are ill-suited for the  small leaks and drips typical of
 Vehice Maintenance Shop operations. The wringer and reusable pads will be removed from the
 Vehicle Maintenance Shop and transferred to the Operations  Support Division for a trial basis.

 18.4.3.8      Electroplating Waste Reduction-

      Printed circuit board manufacturing is one of the major waste-generating operations at LaRC
 Current 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  The
 nnsewater pretreatment facility, which handles all rinsewater generated from circuit board fabrication
 processes,  pretreats an average of 5,000 gallons of rinsewater a week and generates one cubic yard
of metal hydroxide sludge.                                                                *

      A deionization/water recycling system was purchased and installed  at LaRC  as part of a
pollution  prevention action project.  The system allows treated wastewater to be reused as
rinsewater,  and is anticipated to reduce the amount of wastewater treatment sludge generated by

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approximately 75 percent in addition to reducing water consumption. The capital cost for the system
is $20,000. It has been estimated that the avoided costs based on  reduced sludge generation and
seed material costs will be $19,868, excluding cost savings from water reuse.  Testing of the system
is currently in progress.  The system was installed in January 1994, and should reach maximum
efficiency by January 1996, at which point water recycling will be considered.

      The size of the electroplating tanks was reduced in 1991. The size reductions are variable,
ranging from 19 to 50 percent.  This initiative has reduced chemical supply  costs, waste generation,
and labor costs associated with waste processing activities.  Chemical cost savings associated with
the tank reductions are $652 per year. Reduced waste generation and reduced labor costs have not
been quantified.
18.4.3.9
Centralized Silver Recovery Unit-
      Photoprocessing and x-ray operations are located at eleven facilities throughout LaRC in
addition to the main photo lab. Wastes generated by these operations include silver-bearing liquid
wastes, which are hazardous because of the high silver content.  Improved silver recovery
procedures reduced the amount of photographic laboratory waste by 28 percent, or 6,141 pounds,
during 1992.

      A centralized silver recovery unit is scheduled to begin operation in late 1994. The unit will be
used to recover silver from all silver-bearing waste generating operations at LaRC, except for the
main photo lab.  Disposal of silver-bearing liquids will  be reduced by approximately 1,200 gallons,
reducing disposal costs by  approximately $3,000.

18.4.3.10     Termination and Restriction of Ozone Depleting Substances-

      Chlorofluorocarbons  (CFCs) have traditionally been used at NASA to clean wind tunnel
components and oxygen systems.  NASA has established a goal of eliminating non-essential uses of
chlorofluorocarbons and methyl chloroform (1-1-1 trichloroethane, TCA). LaRC has begun
terminating from the supply system Class 1- Ozone Depleting Compounds (ODCs) and TCA. LaRC
 has also restricted the use of CFC-22, CFC-11,  CFC-113, and CFC-12 to refrigerant applications
 only.

      Approximately 825 gallons of CFC-113 were previously used annually at  LaRC to clean
 oxygen systems. LaRC staff laboratory-tested a number of alkaline detergents in conjunction with an
 ultrasonic cleaner to determine the detergent with the best  cleaning performance.  Aqueous cleaning
 has replaced the use of CFC-113 in 99 percent of the cleaning operations.  Annual savings from
 using alkaline detergents in place of CFCs were approximately $15,000 in raw material costs as of
 1993.  Projected cost savings are anticipated to be greater due to the increase in price of CFC-113
 because of declining commercial availability in response to statutory mandates.

       Aqueous cleaning replaced the use of CFC-113 to clean small metal parts used in the NTF
 wind tunnel,  eliminating the annual consumption of 70 to 130 gallons of CFC-113 at an annual cost of
 approximately $18,000 in 1991.  Although the alkaline detergents reduce use and subsequent
 disposal of CFC's,  conversion to aqueous cleaning generates a new waste stream.  The wastewater
 from the  parts cleaner is collected, tested, and discharged  to the sanitary sewer.
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       The LaRC continues to use CFC-113 to clean flight hardware, removing particles by
 ultrasonification and organic contamination by dissolution.  Projects designed to test the cleaning
 efficiencies of alternative aqueous solvents demonstrated that these solvents left a residue on the
 cleaned part. Isopropyl alcohol, which was also tested, cleaned better than the other aqueous
 solvents. One ultrasonic tank has been converted to allow the use of isopropyl alcohol and a
 deionized water rinse. CFC-113 will be used in the remaining tanks until the phase-out date.  A
 deionized water blanket in the CFC-113 tank has significantly  reduced the evaporative losses  of
 CFC-113.

 18.4.3.11     Aqueous Parts Washiing-

       Thirty-two facilities were identified which use solvent-based cleaners such as xylene,
 methylene chloride, or petroleum  naphtha. These organic degreasers not only produce VOC
 emissions, but also must be managed as hazardous materials because of their flammability  and/or
 toxicity.

       Aqueous cleaning agents have replaced solvent cleaning at the compressor building, the
 machine shop,  the Aircraft Landing Dynamics Facility, and the Vehicle Maintenance Shop.  Two
 aqueous parts washer machines were installed at the Vehicle Maintenance Shop.  These changes
 have eliminated approximately 3,500 pounds of hazardous waste and 2,000 pounds of VOC
 emissions annually, and have avoided approximately $1,000 annually in direct waste disposal costs.
 Raw material costs have been reduced since solvents are typically more expensive than aqueous
 cleaners.  The cleaning solutions can be reused with the addition of makeup water and fresh
 detergent as needed,  and thus do not require disposal.  Sludge collects in the tank bottom and will
 eventually require disposal. The material will have to be tested to determine the proper disposal
 method.

 18.4.3.12    Electronic Document Transfer to Eliminate Paper Use-

      The NASA LaRC library uses  an estimated 20 reams of paper each week to photocopy
 articles, journals, and  other publications requested by researchers.  The library is investigating
 electronic transfer to replace paper copies thereby reducing paper use and waste.  With the
 electronic transfer system, documents will be scanned and sent electronically via LaRC Net (the local
 network) to the  researcher.  Currently only one page at a time can be scanned, processed,
 transferred to diskette, or sent across the Local Area Network.  The software is being upgraded to
 increase processing capacity.

      The electronic system may not be appropriate for transferring documents containing technical
 or engineering drawings. These types of documents may require traditional paper photocopying.

 18.4.3.13     Gas Cylinder Management and Recycling-

      Several hundred compressed gas cylinders are maintained at LaRC for use in research and
 related activities. The cylinders fall under three ownership categories: (1)  stock cylinders; (2) rental
 cylinders; and (3) government-owned cylinders. Stock cylinders are government-owned, issued by
supply to LaRC personnel.   Empty stock cylinders are returned to supply, and then transported off-
site to be refilled by a  vendor.  Rental cylinders are owned by a vendor. The contents are purchased
 by NASA, and vendors charge a daily fee for use of the cylinder bn-site. Government-owned
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cylinders are variable in size and are purchased from vendors.  Many of these cylinders are
disposable and are designed for one-time use.

      Cylinders often remain on-site for many years,  and personnel lose track of their origin.  As tags
fade, knowledge of their contents and purpose is often lost.  Unidentifiable cylinders must be
disposed of as hazardous waste at an average cost of $300.  In contrast, returning a cylinder to a
vendor costs about $27, while shipping a cylinder to the  Defense Reutilization and Marketing
Organization (DRMO) for sale as scrap metal costs $75. Approximately 200 cylinders were disposed
of or returned to vendors between 1993 and 1994,  at a combined cost of $28,000.

      The Center has instituted a new policy for gas  cylinder management, which includes tracking
the movement of cylinders at the facility. All "returnable" cylinders, both rentals and government-
owned, should be returned to vendors instead of being disposed of as hazardous waste. Non-
returnable government-owned and stock cylinders with expired  service lives are prepared and
shipped to DRMO.

      The new management system will reduce the number of cylinders disposed of as hazardous
waste. Tracking cylinders  and cylinder contents at LaRC will reduce the need for testing to identify
tank contents, and may also increase the material  usage rates  of cylinder gases.
18.4.4
Naval Base Norfolk
      As part of its pollution prevention program, Naval Base Norfolk established a PPOA training
program in FY 1992. Approximately 25 personnel have been trained in the opportunity assessment
process. This training is believed essential to successful implementation of the PPOA
recommendations.
      A major objective for the environmental program at Naval Base Norfolk is moving beyond
environmental compliance to incorporate pollution prevention practices into everyday activities.
Numerous  pollution prevention initiatives have been implemented at the base.  These initiatives,
described below, encompass a wide range of operations and are not limited to the recommendations
made as part of the PPOA.
 18.4.4.1
Air Pollution Control--
      Three boilers at the PWC Norfolk P-1 Power Plant were converted to enable fueling by natural
 gas or oil.  Two were converted in 1992, and the third in  1993. The use of natural gas at the Power
 Plant has reduced carbon emissions by approximately one third of the preconversion value.  Nitrogen
 oxides (NOX) emitted in pounds per hour were reduced by approximately 40 percent, lowering the
 annual NOX emissions by an estimated 30 tons. The converted boilers are currently maximizing the
 use of natural gas by burning all the natural gas that Virginia Natural Gas Company can supply
 through existing pipelines.  Plans are underway to build an additional pipeline to provide for the
 expanded use of natural  gas.

      Three additional boilers are being installed at building Z-312 which will burn natural gas and
 low sulfur #2 fuel oil, and will act as the main power backup during times of peak power demand on
 base.  The boilers should be fully  operational by Spring 1995.
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 18.4.4.2
Water Conservation-
       Two projects at Naval Base Norfolk address water conservation. The first project provided a
 replacement for the demineralizer at the P-1 Steam Plant, which came on line in the Fall of 1992.
 The Steam  Plant had previously experienced a continuous seven percent blowdown.  With the
 addition of the demineralizer, blowdown percentages have dropped to between 0.5 and 1.0 percent,
 resulting in a water savings of well over 18.5 million gallons per year.

       The second project involves the installation of flushometers in  Navy Housing toilets.  The
 flushometers are able to save water by raising toilet tank levels while dropping toilet  bowl levels,
 effectively reducing water use while maintaining adequate flush velocity.  Water savings are expected
 to be 10 million  gallons  per year, once full installation  is complete.

 18.4.4.3      Chemical Material Management-

       COMNAVBASE has produced a Hazardous Materials/Hazardous Waste Minimization,
 Reutilization and Disposal Guide that details procedures for minimizing and  reutilizing hazardous
 materials and  identifying, accumulating, and disposing of hazardous waste.  The document is
 distributed base-wide, including homeported ships as well as hazardous waste accumulation area
 custodians during the hazardous waste accumulation area training course.  Standardized training to
 custodians is conducted bimonthly by the Environmental Programs Department.

       Every ship homeported at the Naval Station receives training and a Hazardous
 Materials/Hazardous Waste Minimization,  Reutilization and Disposal Guide,  produced by Naval Base
 Norfolk.  A prototype effort began in August 1992 to manage hazardous material off-loads in the
 Hampton Roads area. COMNAVBASE serves as the single point of contact for ship  offloads of four
 or more pallets of hazardous materials/hazardous waste.  Through the effort, the quantity of
 hazardous waste disposed of was reduced by 6 percent from 330,595 gallons in FY 92 to 312,315
 gallons in FY 93. A significant amount of stock fund material has also been diverted  from the
 disposal system.

      A hazardous pollution prevention  program focusing on training,  education, and  single point
 hazardous material issuance has been implemented at the Naval Air Supply Station Supply
 Department and  the Naval Supply Center  Norfolk Paint Mart and Reutilization Store.  Hazardous
 materials are collected for reutilization and placed in the Reutilization  Store.  The store provides used
 hazardous materials, at no cost, as well as a crossdecking service.  The Fleet and Industrial Supply
 Center (FISC)  Flash Bulletin and Streamlined Alternative Logistics Transmission System (SALTS)
advertises available hazardous materials every 2 weeks.  This program reduced  hazardous waste
disposal from 408,000 gallons in FY90 to 253,000 gallons in FY92.  During only eight months of
operation, from March to December 1993, the Norfolk Reutilization Store avoided $1M in hazardous
materials purchase and disposal costs.

      During 1992 and 1993, the Hazardous Waste Minimization Program at Naval Base Norfolk
accomplished the following.

      Training for every  homeported ship at  the Naval Air Station Norfolk regarding proper
      processing of hazardous materials and hazardous wastes
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      Development and distribution of standardized procedures for turn-in of hazardous materials
      and hazardous wastes, for ships and shore commands, shelf life extension and ship offloads

      Redirection of $666K in medical  items for use in lieu of disposal. These items were given to
      the State Department Humanitarian Assistance Program

      Establishment of a Household Chemical Reuse Program  in March 1993. Families that live in
      government housing can donate  partially used household chemicals to the Navy Family
      Housing Office, Self Help stores for reuse  by other residents or new arrivals

•     Maintenance of an authorized hazardous materials user list and inventory,  which entails annual
      reviews of products and procedures used by tenants and subordinates

      Installation  of six prefabricated storage buildings with spill containment at Hazardous Waste
      Accumulation Areas to provide secure storage and minimize hazardous waste generated by
      spillage and cleanup materials

      Establishment  of an independent Naval Air Station Norfolk fluid recovery contract to dispose of
      contaminated oil and hydraulic fluid with a cost savings of $66,600

      COMNAVBASE Norfolk has been working to phase out the use of Oil Disposal Rafts (ODRs)
for ship bilge water disposal. A Military Construction project was developed to provide pier piping for
bilge water collection at the submarine piers.  This project will also provide piping to the two drydocks
at Naval Station (NAVSTA) Norfolk. Piping for the two remaining NAVSTA piers will be  provided
during a follow-on project,  which is currently being developed.   These two projects are anticipated to
provide both environmental and cost savings benefits for the base.

18.4.4.4     Municipal Solid Waste—

      A recycling program has been in effect since the mid-1980s at Naval Base Norfolk. The
Resource Recovery and Recycling  Program (RRRP) services all tenant and subordinate commands
on the Naval Base and encompasses a multitude of separate revenue-generating operations  that,
combined, make it the most effective and profitable recycling program in the Department of the Navy.
The COMNAVBASE  RRRP is ranked third in revenue-generating recycling  programs in the
Department of Defense. Operations include the following.

      An  on-base waste transfer station  for recovery of recyclables

•     A thriving scrap metals recovery program

      An  aluminum can recovery facility

      Two materials recovery facilities (primarily for office and  computer paper and corrugated
      cardboard)

      Recycle Saturdays (at the Naval Air Station Norfolk on the last Saturday of each month)

      Curbside collection  of recyclables in the Willoughby housing area
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      Aerosol can puncturing and recycling

      Empty drum crushing and recycling

      Over 8,000 tons of recyclables were processed, sold, and credited to the RRRP in FY 93,
 equalling 25 percent of the total waste stream at the Naval Base complex at a cost avoidance and
 revenue generation of $5.16M.  The ultimate goal  of the RRRP is to eliminate  marketable recyclable
 materials from the Naval Base waste stream.  Near-term goals include increasing the percentage of
 recyclable  materials removed from the waste stream to 33 percent by the end  of calendar year 1994;
 decreasing the number of refuse dumpsters on the Naval  Base complex by 5 percent; decreasing the
 size of at least 20 percent of the remaining refuse containers to smaller, less costly containers;
 decreasing the pick-up frequency of at least 30 percent of the refuse containers in fiscal year 1994;
 and, by the end of calendar year 1995,  recycling 15,000 tons of material.
18.4.4.5
Electroplating-
      Several provisions for pollution prevention had been successfully implemented at the Naval
Base Norfolk electroplating facility at the time that the PPOA was conducted. Rinsewater had been
reduced by 75 percent, from 80,000 to 20,000 gallons per day, by installing flow restrictors on all
water inlets which feed rinse tanks, and by training platers to close water valves on idle plating lines.
Water use is assessed through at least two periodic inspections per day.  Water meter readings are
recorded on a daily basis to track water use and to identify unusual conditions.  Process solutions are
rarely discarded, due primarily 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 the conventional cyanide bath.  Finally, the shop contains a
mist eliminator system to recover chromic acid from hard chromium plating tank emissions.

      A recently implemented pollution prevention project has significantly reduced the generation of
heavy metal sludge-bearing wastes containing chromium,  cadmium, silver, and nickel during hard
chromium and nickel sulfamate electroplating operations.  Using commonly available equipment, the
quantity and toxicity of rinsewaters generated during the plating, stripping, and cleaning processes
have been significantly reduced, thereby reducing waste disposal costs associated with plating
activities.

18.4.4.6      Painting and Depainting  Operations--

      Painting facilities at Naval Base Norfolk are currently being converted from wet to dry booths.
This effort is anticipated to reduce the quantity and toxicity of paint wastes, reduce VOC emissions,
and increase the efficiency of paint use.  Conversion from wet to dry booth operations at the Naval
Aviation Depot (NADEP) alone eliminated more than 25 large electric motors needed to operate the
wet systems, significantly reducing power consumption in addition to the improved paint process
reliability and paint recovery efficiency.  High volume/low pressure paint guns have also reduced
overspray solids at NADEP.

      Efforts have  been made to minimize blast grit in the paint shops, thereby reducing waste
generation.  Best Management Practices (BMPs) were developed for the Norfolk Barge Repair
Facility that address sand  blasting, painting and welding operations. The  BMPs are designed to
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eliminate violations for Total Suspended Solids, which have been characteristic for this facility. The
BMPs require containment of spent blast grit and debris, daily cleaning and removal of spent blast
grit, spray painting only under calm weather conditions, shrouding of surfaces to be blasted, and
proper storage of materials  in  use.

      COMNAVBASE Norfolk has drafted a BMP that requires use of paint floats and roller pans to
minimize paint discharges.  In addition, COMNAVBASE Norfolk is evaluating the feasibility of
alternative painting equipment, such as HVLP spray guns and continuous-feed rollers, for pier-side
hull painting operations.
18.4.4.7
Solvents—
      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. The installation of the parts washer at SIMA resulted in the cancellation of the
base's single largest cleaning contract.  Procurement of solvents and procurement and disposal of
cleaning rags have been eliminated, resulting in an immediate savings of $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.  The parts washers aboard 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.

      From 1991  to 1993, the Naval Aviation Depot (NADEP) Norfolk undertook the following actions
to reduce emissions:  vapor degreasers were replaced with water parts washers, freon and ethyl
acetate wipe cleaning of aircraft was  replaced with water based cleaning, and  replacements for freon
spray cleaners and freon dip tanks were investigated.  Through a thorough review of line processes,
NADEP was able to eliminate all but  a few of the solvent-containing process tanks, thereby
eliminating virtually all VOC emissions. The  generation of hazardous waste was reduced, since
these solvents previously required disposal as hazardous waste.

      Refrigerant recovery equipment was procured during 1992 and 1993 for several facilities at
Naval Base Norfolk.  This  equipment is used to recover and contain ozone depleting substances
during maintenance of refrigeration units, thereby reducing emission to the atmosphere.
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                                        SECTION 19

                  NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
                            NASA LANGLEY RESEARCH CENTER
                                       PHOTO LABS

      As part of the TIPPP program, a pollution prevention opportunity assessment was conducted at
the NASA Langley Research Center (LaRC) photo labs in 1991.  This project was jointly funded by EPA
Risk Reduction  Engineering Laboratory and NASA.

19.1  FACILITY DESCRIPTION

      Photoprocessing and x-ray operations are located at twelve facilities throughout LaRC; however,
the majority of activity takes place at the main photo lab, Building 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.  Operations include batch mixing of photographic
chemicals, plate-making, and negative and x-ray development.

19.2  AREAS OF POLLUTION PREVENTION OPPORTUNITY EVALUATIONS

      The LaRC photo  labs generate approximately 16 percent of LaRC's hazardous and chemical
wastes. These wastes include spent developers, fixers, and bleaches which amounted to 7,582 gallons
of waste shipped off site at a cost of $14,372.  The main photo lab,  building 1155,  accounts for 66
percent of the total hazardous wastes generated by photo operations. Liquid wastes generated by photo
developing activities are hazardous because of the high silver  content.  Additional wastes generated
include scrap film  and scrap photographic paper.  Building 1155 collects scrap  film  for off-site silver
recovery; scrap photographic paper is disposed of as solid waste.

19.3  POLLUTION PREVENTION OPTIONS AND RECOMMENDATIONS

      The two areas with  the greatest potential  for savings  per year are: (1) general processing
procedures; and (2) silver recovery.
19.3.1
General Processing
      Photo technicians currently print several photographs from each negative regardless of the number
of photos requested.  Assuming two prints were made of each negative, a potential savings of 50 percent
could be realized from printing only one. However, occasionally, a reprint is needed for quality; therefore,
a conservative estimate of the amount of photographic paper saved by printing only one photo is
33 percent, which would still result in an annual savings of $35,000.

      The PPOA additionally recommended several other pollution prevention options to improve photo
lab operations.
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•     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.

•     Install 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.

19.3.2       Silver Recovery

      The main photo lab at LaRC is a major generator of silver-bearing wastewater. LaRC will generate
silver-bearing photoprocessing wastes whenever typical photographic reproductions of images on film
are produced.  In several  areas, electrolytic silver recovery units were discontinued and the metal
cartridges were used for silver recovery, then disposed of.  After extensive testing to ensure that silver
in the effluent from the canisters would meet discharge permit levels, the used canisters are shipped to
Defense Reutilization  and Marketing Organization for sale to metal-recovery companies. To minimize
the waste, it was recommended that the photo labs reinstate the use of electrolytic silver recovery units
in conjunction with silver recovery cartridges.  The reduced purchase and disposal of cartridges would
result in an annual savings  of $1,800 per year.

19.4  STATUS OF IMPLEMENTATION
19.4.1
General Processing
      As recommended,  the photo lab has installed a water meter to establish baseline water usage.
Additional recommendations regarding water usage will be implemented after applicable information has
been available for one year.

      The photo lab has  modified General Processing Procedures and Quality Assurance Procedures
used by the lab.  These two initiatives are anticipated to  reduce the amount of waste paper due to
decreasing the number of unused photographic prints produced by the lab and reducing the number of
poor quality prints that are disposed of as solid waste. Savings associated with these two initiatives are
estimated at $35,000 per year.
19.4.2
Silver Recovery
      A centralized silver recovery unit will be in  operation in  late 1994 for all silver-bearing  waste
generating operations except for the main photo lab,  which has its own recovery system. The centralized
unit will be located in the new pollution prevention support building at LaRC. Implementation is expected
to ensure  uniform management of all silver recovery activities.  Silver flake will  be recovered from the
waste solutions.
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       The recovery of silver from photoprocessing and x-ray equipment liquid waste is anticipated to
reduce disposal costs  by eliminating the off-site hazardous waste shipment of silver-bearing liquids,
reducing the amount of liquid waste  by approximately 1,200 gallons, resulting in an anticipated annual
savings of $3,000 in disposal costs.  Although additional revenue can be expected from the silver flake
which is recovered  from the waste stream, this revenue has not been included in the analysis due to
fluctuating silver prices and will vary depending on the efficiency of the electrolytic silver unit.
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                                       SECTION 20

          WREAFS PROJECTS ONGOING OR COMPLETED AFTER SEPTEMBER 1994

      In addition to the completed WREAFS projects,  several new projects are ongoing or completed
after September 1994.   Unless otherwise noted, a published report  of each project has or will  be
published and available through NTIS and a project summary has or  will be published and available
through EPA-CERI (see attached list and ordering blank).  A summary  of each project follows.

20.1  U.S. DEPARTMENT OF DEFENSE
20.1.1
Naval Ophthalmic Support and Training Activity (NOSTRA)
      EPA, with technical support from NOSTRA, worked with the Optical Laboratories Association (OLA)
and its member companies to reduce or eliminate process wastes such as MEK, acetone, methanol,
toluene, xylene, TCE and TCA.  The technical  evaluation was funded by the EPA Risk Reduction
Engineering Laboratory.  The results of the evaluation will be published  in a journal article.
20.1.2
Naval Station Mayport
      Through the Naval Facilities  Engineering Services  Center  (NFESC), implementation of fluid
filtration,  recovery, and  reuse technologies  and rag-use  reduction  techniques were evaluated for
application to the Public Works Operations at Naval Station Mayport in Florida.
20.1.3
U.S. Air Force Center for Environmental Excellence
      Using the data from the PPOAs conducted at the OC-ALC, a lessons learned document has been
developed for aircraft repair pollution prevention  assessments and demonstrations.  The project was
funded under SERDP.
20.1.4
U.S. Army Corps of Engineers (USAGE)
      PPOAs were conducted at four USAGE facilities as models for future assessments at similar types
of Corps facilities.  The facilities included in the assessment were: a hydropower plant, a repair station,
an operational lock and dam, with ongoing major maintenance occurring within the lock chamber, and
a flood control project.  The project was funded under SERDP.
20.1.5
Fort Eustis Army Transportation Center
      Under the TIPPP program, Fort Eustis has completed a base-wide pollution prevention program
plan, which identified a  need to evaluate and  upgrade  painting, depainting and  corrosion  control
operations.  Several improvements have been implemented. A Life Cycle Assessment (LCA) of painting
and depainting operations is being conducted, beginning with an inventory analysis of improved CARC
painting and depainting operations to determine the resources used and environmental releases.  An
impact analysis  will  determine the environmental consequences associated with CARC operations,
including corrosion control techniques. By evaluating the environmental consequences, the improvement
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analysis will identify opportunities which will be implemented and evaluated on-site. The project is being
funded under SERDP.

20.2  U.S. DEPARTMENT OF TRANSPORTATION
20.2.1
U.S. Coast Guard Air Training Center
      Joint assessments were conducted for pollution prevention options in aircraft maintenance, aircraft
fueling, flight simulators, and aircraft cleaning at the Air Training Center in Mobile, Alabama. This project
was funded by EPA-RREL.
20.2.2
U.S. Coast Guard Technology Assessments
      A study was conducted to provide guidance for the USCG in choosing cost-effective parts cleaning
chemicals that have minimum environmental and safety impacts. The three bases chosen for this study
were: Aviation Training Center (ATC) Mobile, AL; Air Station Cape Cod (ASCC), Falmouth,  MA; and
Support Center NY (SCNY), Governors Island, NY.  The project was jointly funded by USCG and EPA-
RREL

20.3  U.S. DEPARTMENT OF ENERGY
20.3.1
LCA Research and Development Demonstration
      As a follow-on to the joint Life Cycle Assessment Research and Development (LCA RD&D), cross-
cutting pollution prevention  technologies and methodologies at DOE laboratories are being developed
and demonstrated.  The project is jointly funded by SERDP and DOE.
20.3.2
Complex-wide LCA Design Case Studies
      This will build on current DOE/EPA LCA work which  is developing a technical framework, Life
Cycle Cost Assessment (LCCA) to be included within a life cycle assessment. This project will take the
framework to the next phase of demonstration allowing for further development and refinement of DOE
products and processes. The project will be jointly funded by SERDP and EPA-RREL.

20.4  U.S. DEPARTMENT OF INTERIOR
20.4.1
Bureau of Indian Affairs
      Based in part on the work being done by tribal pueblos, a pollution prevention Resource Guide is
being developed to provide technical assistance on source reduction to Indian tribes and business
operating on Indian lands. The Guide addresses creation of a pollution prevention program that consists
of five elements, including a multi-media pollution prevention effort for Indian tribes that fosters close
coordination with State and Federal  programs.  A training program and workshop on source reduction
will  also be included as part of the project.  The project is funded by EPA-RREL.
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20.5  U.S. POSTAL SERVICE
20.5.1
Pollution Prevention Opportunity Assessments
      PPOAs are being conducted at six types of postal facilities, including an Engineering and Research
Development Laboratory; a Stamp Distribution Center; a Bulk Mail Facility; an Area Supply Depot; a
Forensics  Laboratory; and  customer  service centers (small, medium,  and large post  offices).  The
recommendations should have applicability to other similar postal facilities throughout the United States.
Also, an evaluation was conducted for recycling opportunities between  the USPS and Federal Prison
Industries.  The project is jointly funded by USPS and EPA-RREL. Technology transfer will be in the
form of project reports and an implementation workshop.

20.6  U.S. ENVIRONMENTAL PROTECTION AGENCY
20.6.1
Federal Facility Enforcement Office (FFEO) - F2P2 Manual
      To assist Federal managers in reducing waste generation and emission rates in order to meet
compliance objectives  by using pollution prevention tools, a manual was produced by the WREAFS
program titled, "Federal Facilities Pollution Prevention-Tools for Compliance."  The project was jointly
funded by EPA-RREL and EPA-FFEO.
20.6.2
Federal Facility Enforcement Office - FMECI Support
      In a project jointly funded by FFEO and RREL, RREL is providing support to EPA Regions in
developing Pollution Prevention Supplemental Environmental Projects (SEPS) underthe Federal Facilities
Multi-Media Enforcement/Compliance Initiative (FMECI).  As requested, RREL will provide pollution
prevention solutions for violations and other identified areas of noncompliance at Federal sites. The first
P2 SEP developed under this program was at Eielson Air Force Base.

20.7  NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
20.7.1
NASA Langlev Research Center - Dry Powder Towpreq
      In performing its mission, LaRC develops composite materials for use in subsonic and supersonic
aircraft applications.  LaRC developed a  new dry powder towpreg process to manufacture these
composite materials. The process is a less hazardous way to impregnate carbon fibers with dry powder
resin (towpreg) by using powdered polymers to coat fibers.  The TIPPP project is demonstrating this
innovative pollution  prevention  technology and  conducting a life-cycle  analysis of its energy and
environmental impacts.  Final products are being compared with commercially produced products to
determine comparable performance characteristics. The project is jointly funded by EPA and  NASA.

20.7.2        NASA Lanqlev Research Center - Pollution Prevention Program
             Implementation

      Under TIPPP, a base-wide assessment of NASA-LaRC operations was conducted and a Pollution
Prevention Program Plan  for the facility was developed under the WREAFS program.  WREAFS
continues to support the implementation of selected projects from the  Pollution Prevention Program Plan.
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20.8  OTHER POLLUTION PREVENTION RESEARCH INVOLVING FEDERAL AGENCIES

      Other pollution prevention research projects involving federal agencies, but not under the WREAFS
program per se, were completed or underway at the Newark Air Force Base, the Naval Aviation Depot
in Jacksonville,  Florida, Tooele Army Depot,  and the U.S. Department of Agriculture Forest Products
Laboratory.
20.8.1
Newark Air Force Base
      EPA in cooperation with Vortec Corporation (equipment supplier) completed a study at the Newark
Air Force Base to revaluate compressed air and nitrogen as replacements for spray cans of refrigerants
(CFC-12 and HCFC-22). The application was for trouble-shooting thermally  intermittent circuit board
components.
20.8.2
Naval Aviation Depot
      EPA in cooperation with Honeywell-Space Systems Group (Clearwater, FL) and Naval Aviation
Deport (Jacksonville, FL) conducted a project to evaluate the effectiveness of using CO2 at supercritical
conditions for cleaning precision parts, such as gyroscope bearings. This method will replace the use
of CFCs or other toxic solvents.
20.8.3
Tooele Army Depot
      EPA in cooperation with Tooele Army Depot (Tooele, UT) evaluated N-methyl-2-pyrrolidone (NMP)
as a substitute paint remover in an automated conveyer paint stripping system used to depaint the High
Mobility Multipurpose Wheeled Vehicle (HMMVW) and other Army vehicles.
20.8.4
U.S. Department of Agriculture. Forest Products Laboratory
      Two projects funded under interagency agreements between the U.S. Department of Agriculture
and EPA are: (1) Reclaiming Fiber from Newsprint (investigating the potential for newsprint reclamation
through a dry fiberizing process); and (2) Developing composites from Recycled Plastics, Wood and
Recycled Wood Fiber (investigating and developing wood/plastic composites).

20.9  SUMMARY AND CONCLUSIONS

      The WREAFS Program takes on many facets in its endeavor to support the Federal community
with pollution prevention  research. There have been a number of RD&D products completed and a
number of on-going efforts, but perhaps the most important impact will come from any resulting cultural
change brought about by conducing a PPOA or reading an RD&D report.  It is necessary for all Federal
agencies to  take  an active  role  in pollution  prevention and set examples for  others.   The
SERDP/WREAFS combination is an excellent illustration of the opportunities available for Federal
agencies to wisely use funding and manpower to attain the goal of pollution prevention.
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                                        SECTION 21

                                       REFERENCES

1.    U.S. Environmental Protection Agency, Facility Pollution Prevention Guide, EPA/600/R-92/088,
      Reduction Engineering Laboratory, Cincinnati, Ohio, 1992.

2.    U.S. Department of Energy,  Model Pollution  Prevention Opportunity Assessment Guidance,
      Assistant Secretary for Defense Programs, Washington, DC, December 1993.

3.    Houlahan, J., et a/., Pollution Prevention and Recycling Practices in the  U.S. Postal Service.
      Federal Facilities Environmental Journal, Summer 1994.

4.    U.S. Environmental Protection Agency, Greening the White House. U.S. EPA Pollution Prevention
      News, EPA-742-N-94-003, June-July 1994.
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                                      SECTION 22

                                POLLUTION PREVENTION
                          PUBLICATIONS AND ORDERING FORM

     The following list of current publications and ordering form include pollution prevention topics in
addition to those related to the WREAFS program.  WREAFS program products are indicated with an
asterisk. For additional information, contact the Pollution Prevention Research Branch at (513) 569-7215,
FAX: (513)569-7111.
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                                     P2 PUBLICATIONS

 PLEASE PLACE A CHECK NEXT TO THE GUIDES YOU WISH TO ORDER AND MAIL TO:

                                CERI PUBLICATIONS UNIT, US EPA
                                28 W. MARTIN LUTHER KING DRIVE
                                     CINCINNATI, OH 45268
                                        (513) 569-7562

 GUIDES TO POLLUTION PREVENTION:

 	   THE PESTICIDE FORMULATING INDUSTRY

 	   THE PAINT MANUFACTURING INDUSTRY

 	   THE FABRICATED METAL PRODUCTS INDUSTRY

 	   THE PRINTED CIRCUIT BOARD MANUFACTURING INDUSTRY

 	   THE COMMERCIAL PRINTING INDUSTRY

 	   SELECTED HOSPITAL WASTE STREAMS

 	   RESEARCH AND EDUCATION INSTITUTIONS

 	   THE PHOTOPROCESSING INDUSTRY

 	   THE AUTO REPAIR INDUSTRY

 	   THE FIBERGLASS REINFORCED AND COMPOSITE PLASTICS INDUSTRIES

 	;_   MARINE MAINTENANCE AND REPAIR INDUSTRY

 	   THE AUTOMOTIVE REFINISHING INDUSTRY

 	   THE PHARMACEUTICAL INDUSTRY

 	   MECHANICAL EQUIPMENT REPAIR

 	   METAL CASTING AND HEAT TREATING INDUSTRY

 	METAL FINISHING INDUSTRY

 	   MUNICIPAL PRETREATMEMT PROGRAMS

 	   NON-AGRICULTURAL PESTICIDE USERS

 	  WOOD PRESERVING INDUSTRY


 GUIDES TO CLEANER TECHNOLOGIES

 	  ORGANIC COATING REMOVAL

 	  ALTERNATIVES TO CHLORINATED SOLVENTS FOR CLEANING & DECREASING

 	  CLEANING AND DECREASING PROCESS CHANGES

	  ORGANIC COATING REPLACEMENTS

	  ALTERNATIVE METAL FINISHES
  Januarys, 1995
 EPA/625/7-90/004

 EPA/625/7-90/005

 EPA/625/7-90/006

 EPA/625/7-90/007

 EPA/625/7-90/008

 EPA/625/7-90/009

 EPA/625/7-90/010

 EPA/625/7-91/012

 EPA/625/7-91/013

 EPA/625/7-91/014

 EPA/625/7-91/015

 EPA/625/7-91/016

 EPA/625/7-91/017

 EPA/625/R-92/008

 EPA/625/R-92/009

 EPA/625/R-92/011

 EPA/625/R-93/006

 EPA/625/R-93/009

 EPA/625/R-93/014




EPA/625/R-93/015

EPA/625/R-93/016

EPA/625/R-93/017

EPA/625/R-94/006

EPA/625/R-94/007
                                          104
                                                                          CONTINUE ON BACK

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 OTHER MANUALS:

 	   FACILITY POLLUTION PREVENTION GUIDE

     '   OPPORTUNITIES FOR P2 RESEARCH TO SUPPORT THE 33/50 PROGRAM

 	   LIFE CYCLE DESIGN GUIDANCE MANUAL

 	   LIFE CYCLE ASSESSMENT: INVENTORY GUIDELINES & PRINCIPLES

 	   POLLUTION PREVENTION CASE STUDIES COMPENDIUM

 	,   ACHIEVEMENTS IN SOURCE REDUCTION & RECYCLING FOR TEN INDUSTRIES IN
        THE UNITED STATES

 	   INDUSTRIAL P2 OPPORTUNITIES FOR THE 1990'S

 	   BACKGROUND DOCUMENT ON CLEAN PRODUCTS
        RESEARCH & IMPLEMENTATION

 	   A PRIMER FOR FINANCIALANALYSIS OF P2 PROJECTS

 	   MEASURING POLLUTION PREVENTION PROGRESS PROCEEDINGS

 • -• .     WASTE MINIMIZATION PRACTICES AT TWO CCA WOOD-TREATMENT PLANTS

 	   INNOVATIVE CLEAN TECHNOLOGIES CASE STUDIES

 	   DUPONT CHAMBERS WORKS WASTE MINIMIZATION PROJECT

 	   MERCURY USAGE AND ALTERNATIVES IN THE ELECTRICAL
        AND ELECTRONICS INDUSTRIES

 	  A REVIEW OF COMPUTER PROCESS SIMULATION IN INDUSTRIAL
      .  POLLUTION PREVENTION

 	  FEDERAL FACILITY POLLUTION PREVENTION TOOLS FOR COMPLIANCE

 	  POLLUTION PREVENTION OPPORTUNITY ASSESSMENT: US COAST GUARD
       AVIATION TRAINING CENTER MOBIL, ALABAMA

 	  DEVELOPMENT OF A POLLUTION PREVENTION FACTORS METHODOLOGY BASED ON
       LIFE-CYCLE ASSESSMENT: LITHOGRAPHIC PRINTING CASE STUDY

 _	  INNOVATIVE CLEAN TECHNOLOGIES CASE STUDIES SECOND YEAR PROJECT REPORT

 	  NASA LANGLEY RESEARCH CENTER & THE TIDEWATER INTERAGENCY POLLUTION
       PREVENTION PROGRAM

 	  CHEMICAL HAZARD EVALUATION FOR MANAGEMENT STRATEGIES (CHEMS 1)- A
       METHOD FOR RANKING & SCORING CHEMICALS BY POTENTIAL HUMAN HEALTH &
       ENVIRONMENTAL IMPACTS

	  THE PRODUCT SIDE OF POLLUTION PREVENTION: EVALUATING THE POTENTIAL FOR
       SAFE SUBSTITUTES

	  .GERMANY, GARBAGE, & THE GREEN DOT: CHALLENGING THE THROWAWAY SOCIETY

TO CERI PUBLICATIONS UNIT:

       PLEASE SEND THE ABOVE GUIDES TO ME AT THE FOLLOWING ADDRESS:

                  NAME             	.	.      	

                  ADDRESS
 EPA/600/R-92/088

 EPA/600/R-92/175

 EPA/600/R-92/226

 EPA/600/R-92/245

 EPA/600/R-92/046


 EPA/600/2-91/051

 EPA/600/8-91/052


 EPA/600/2-90/048

 EPA/600/R-93/059

 EPA/600/R-93/151

 EPA/600/R-93/168

 EPA/600/R-93/175

 EPA/600/R-93/203


 EPA/600/R-94/047


 EPA/600/R-94/128

 EPA/600/R-94/154


 EPA/600/R-94/156


 EPA/600/R-94/157

 EPA/600/R-94/169


 EPA/600/R-94/171




 EPA/600/R-94/177


EPA/600/R-94/178

EPA/600/R-94/179
                                       105

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                        PROJECT SUMMARIES / PROJECT REPORTS
  December 14, 1994
PLEASE PLACE A CHECK NEXT TO THE REPORTS YOU WISH TO ORDER AND MAIL TO:

                                CERI PUBLICATIONS UNIT, US EPA
                                26 W. MARTIN LUTHER KING DRIVE
                                      CINCINNATI, OH 45268
                                          (513) 569-7562
       WMOA Report and Project Summary - Fort Riley, Kansas

       Recovery of Metals Using Aluminum Displacement

       Machine Coolant Waste Reduction by Optimizing Coolant Life

       Metal Recovery/Removal Using Non-Electrolytic Metal Recovery

       WMOA Project Summary- Philadelphia Naval Shipyard

       WMOA Project Summary- Coast Guard/ Governor's Island

       Diaper Industry Workshop Report

       Hospital Pollution Prevention Case Study

       WMOA Project Summary - Naval  Undersea Warfare Engineering Station,
       Keyport, WA

       WMOA Project Summary - Optical Fabrication Laboratory, Fitzsimmons
       Army Medical Center, Denver, CO

       WMOA Project Summary - A Truck Assembly Plant

       WMOA Project Summary - A Photofinish!ng Facility

       Industrial Pollution Prevention Opportunities for the 1990s

       WMOA Project Summary - Scott Air Force Base

       Automotive and Heavy-Duty Engine Coolant Recycling by Filtration

       Evaluation of Five Waste Minimization Technologies at the General
       Dynamics Pomona Division Plant

       Automotive and Heavy-Duty Engine Coolant Recycling by Distillation

       PPOA: Histology Laboratory  Xylene Use, Fort Carson, CO

       An Automated Aqueous Rotary Washer for the Metal Finishing Industry

       Onsite Waste Ink Recycling

       PPOA: USDA Beltsville Agricultural Research Center,  Beltsville, Maryland

       PPOA for Two Laboratories at Sandia National Laboratories

       Ink and Cleaner Waste Reduction Evaluation for Flexographic Printers


                                           106
   EPA Document #


   EPA/600/S2-90/031

   EPA/600/S2-90/032

   EPA/600/S2-90/033

   EPA/600/S2-90/035

   EPA/600/S2-90/046

   EPA/600/S2-90/062

   EPA/600/S2-91/018

   EPA/600/S2-91/024



   EPA/600/S2-91/030


   EPA/600/S2-91/031

   EPA/600/S2-91/038

  ' EPA/600/S2-91/039

   EPA/600/S8-91/052

   EPA/600/S2-91/054

   EPA/600/S2-91/066


   EPA/600/S2-91/067

   EPA/600/SR-92/024

   EPA/600/SR-92/187

   EPA/600/SR-92/188

   EPA/600/SR-92/251

   EPA/600/SR-93/008

   EPA/600/SR-93/015

   EPA/600/SR-93/086

CONTINUE ON BACK

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         Mobile Onsite Recycling of Metalworking Fluids

         Evaluation of Ultrafiltration to Recover Aqueous Iron Phosphating/ Degreasing Bath

         Replacement of Hazardous Material in Wide Web Flexographic Printing Process

         Watts Nickel & Rinse Water Recovery via an Advanced Reverse Osmosis System

         A Fluid Sorbent Recycling Device for Industrial Fluid Users

         Recycling Nickel Electroplating Rinse Waters by Low Temperature Evaporation
         and Reverse Osmosis

         Carbon-Black  Dispersion  Preplating Technology for Printed Wire Board
         Manufacturing

         Ultrasonic Cleaning as a Replacement for a Chlorofluorocarbon-Based System

         Onsite Solvent Recovery

         Evaluating ACQ as an Alternative Wood Preservative System

         Evaluation of Supercritical Carbon Dioxide Technology to Reduce Solvent in
         Spray Coating Applications

         Cadmium and  Chromium  Recovery from Electroplating  Rinsewaters

         Wash Solvent Reuse in Paint Production

         Evaluation of an Eiectrodialytic Process for  Purification of Hexavalent
         Chromium Solutions

         Removal  and Containment of Lead-Based Paint via Needle Sealers

        Waste Reduction Evaluation of Soy-Based Ink at a Sheet-Fed Offset Printer

        Alkaline Noncyanide Zinc Plating & Reuse of Recovered Chemicals

        PPOA: US Coast Guard Aviation Training Center, Mobile, AL

        Innovative Clean Technologies Case Studies, Second  Year Project Report

        Electronic component Cooling Alternatives:  Compressed Air & Liquid Nitrogen

        Evaluation of Propylene Carbonate in ALC Depainting Operations
 EPA/600/SR-93/114


 EPA/600/SR-93/144


 EPA/600/SR-93/149


 EPA/600/SR-93/150


 EPA/600/SR-93/154



 EPA/600/SR-93/160



 EPA/600/SR-93/201


 EPA/600/SR-93/223


 EPA/600/SR-94/026


 EPA/600/SR-94/036



 EPA/600/SR-94/043


 EPA/600/SR-94/050


 EPA/600/SR-94/063



 EPA/600/SR-94/071

 EPA/600/SR-94/114

 EPA/600/SR-94/144


 EPA/600/SR-94/148

 EPA/600/SR-94/156


 EPA/600/SR-94/169


EPA/600/SR-94/170

EPA/600/SR-94/176
TO CERI PUBLICATIONS UNIT:


        PLEASE SEND THE ABOVE REPORTS TO ME AT THE FOLLOWING ADDRESS:

                    NAME              	    •• '	•


                    ADDRESS
                                            107

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                               NEW JERSEY RESEARCH BRIEFS

PLEASE PLACE A CHECK NEXT TO THE BRIEFS YOU WISH TO ORDER AND MAIL TO:

                                  CERI PUBLICATIONS UNIT, US EPA
                                  26 W. MARTIN LUTHER KING DRIVE
                                       CINCINNATI, OH  45268
                                           (513) 569-7562

Waste Reduction Activities and Options for a:

	   Printer of Forms and Supplies for the Legal Profession

	   Nuclear Powered Electrical Generating Station

	   State DOT Maintenance Facility

	   Local Board of Education in New Jersey

	   Manufacturer of Finished Leather

	   Manufacturer of Paints Primarily for Metal Finishing

	   Manufacturer of Writing Instruments

	   Manufacturer of Room Air Conditioning Units and Humidifiers

	   Autobody Repair Facility

	   Fabricator and Finisher of Steel Computer Cabinets

	   Manufacturer of Artists' Supply Paints

	   Manufacturer of Wire Stock Used for Production of Metal Items

	   Manufacturer of Commercial  Refrigeration Units

	   Transporter of Bulk Plastic Pellets

	   Manufacturer of Electroplated Wire

	   Manufacturer of Systems to Produce Semiconductors

	   Remanufacturer of Automobile Radiators

	   Manufacturer of Fire Retardant Plastic Pellets and Hot Melt Adhesives

	   Printing Plate Preparation Section of a Newspaper

	   Manufacturer of General Purpose Paints and Painting Supplies

	   Manufacturer of Fine Chemicals Using Batch Processes

	   Laminator of Paper and Cardboard Packages

	   Manufacturer of Hardened Steel Gears
December 14, 1994
  EPA/600/S-92/003

  EPA/600/S-92/025

  EPA/600/S-92/026

  EPA/600/S-92/027

  EPA/600/S-92/039

  EPA/600/S-92/040

  EPA/600/S-92/041

  EPA/600/S-92/042

  EPA/600/S-92/043

  EPA/600/S-92/044

  EPA/600/S-92/045

  EPA/600/S-92/046

  EPA/600/S-92/047

  EPA/600/S-92/048

  EPA/600/S-92/049

  EPA/600/S-92/050

  EPA/600/S-92/051

  EPA/600/S-92/052

  EPA/600/S-92/053

  EPA/600/S-92/054

  EPA/600/S-92/055

  EPA/600/S-92/056

  EPA/600/S-92/057
                                                 108
                                                                             CONTINUE ON THE BACK

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         Scrap Metal Recovery Facility
         Manufacturer of Electroplating Chemical Products
         Manufacturer of Plastic Containers by Injection Molding
         Fossil Fuel-Fired Electrical Generating Station
         Manufacturer of Commercial Dry Cleaning Equipment
         Electrical Utility Transmission System Monitoring and Maintenance Facility
         Manufacturer of Orthopedic Implants
EPA/600/S-92/058
EPA/600/S-92/059
EPA/600/S-92/060
EPA/600/S-92/061
EPA/600/S-92/062
EPA/600/S-92/063
EPA/600/S-92/064
TO CERI PUBLICATIONS UNIT:

        PLEASE SEND THE ABOVE GUIDES TO ME AT THE FOLLOWING ADDRESS:
                    NAME
                    ADDRESS
                                                 109

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                             ENVIRONMENTAL RESEARCH BRIEFS
                                                                                  December 29, 1994
PLEASE PLACE A CHECK NEXT TO THE GUIDES YOU WISH TO ORDER AND MAIL TO:

                                 CERI PUBLICATIONS UNIT,  US EPA
                                 26 W. MARTIN LUTHER KING DRIVE
                                       CINCINNATI, OH  45268
                                           (513) 569-7562
Waste Minimization Assessment for a:

	   Manufacturer of Printed Plastic Bags

	   Metal Parts Coating Plant

	   Manufacturer of Outdoor Illuminated Signs

	   Manufacturer of Rebuilt Railway Cars and Components

	   Manufacturer of Brazed Aluminum Oil Coolers

	   Manufacturer of Heating, Ventilating, and Air Conditioning Equipment

	   Bumper Refinishing Plant

	   Multilayered Printed Circuit Board Manufacturing  •

	   Manufacturer of Printed Circuit Boards

	   Paint Manufacturing Plant

	   Manufacturer of Compressed Air Equipment Components

	   Manufacturer of Aluminum Cans

	   Manufacturer of Refurbished Railcar Bearing Assemblies

	   Manufacturer of Prototype Printed Circuit Boards

	   Manufacturer of Speed Reduction Equipment

	   Manufacturer of Printed Labels

	   Manufacturer of Chemicals

	   A Dairy

	   Manufacturer of Metal-Cutting Wheels and Components

	   Manufacturer of Automotive Air Conditioning Condensers and Evaporators

	   Printed Circuit Board Manufacturer

	   Manufacturer of Components for Automobile Air Conditioners

	   Manufacturer of Aluminum Extrusions

_j	   Manufacturer Producing  Galvanized Steel Parts

	   Manufacturer of Commercial Ice Machines and Ice Storage Bins

	   Manufacturer of Water Analysis Instrumentation


                                         110
   EPA/600/M-90/017

   EPA/600/M-91/0'15

   EPA/600/M-91/016

   EPA/600/M-91/017

   EPA/600/M-91/018

   EPA/600/M-91/019

   EPA/600/M-91/020

   EPA/600/M-91/021

   EPA/600/M-91/022

   EPA/600/M-91/023

   EPA/600/M-91/024

   EPA/600/M-91/025

   EPA/600/M-91/044

   EPA/600/M-91/045

   EPA/600/M-91/046

   EPA/600/M-91/047

    EPA/600/S-92/004

    EPA/600/S-92/005

    EPA/600/S-92/006

    EPA/600/S-92/007

    EPA/600/S-92/008

    EPA/600/S-92/009

    EPA/600/S-92/010

    EPA/600/S-92/011

    EPA/600/S-92/012

    EPA/600/S-92/013

CONTINUE ON BACK

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.   Manufacturer of Can-Manufacturing Equipment
.   Manufacturer of Metal Bands, Clamps, Retainers, and Tooling
.   Manufacturer of Permanent-Magnet DC Electric Motors
.   Manufacturer of Military Furniture
   Aluminum Extrusions Manufacturer
   Manufacturer of Metal-Plated Display Racks
   Manufacturer of Motor Vehicle Exterior Mirrors
   Manufacturer of Sheet Metal Cabinets and Precision Metal Parts
   Manufacturer Producing Treated Wood Products
   Manufacturer of Industrial Coatings
   Manufacturer of Cutting and Welding Equipment
   Manufacturer of Finished Metal Components
   Manufacturer of Machined Parts
   Manufacturer of Injection-Molded Car and Truck Mirrors
   Manufacturer Producing Printed Circuit Boards
   Manufacturer of Custom Molded Plastic Products
   Manufacturer of Sheet Metal Components
  Manufacturer of Silicon-Controlled Rectifiers and Schottky Rectifiers
  Manufacturer of Penny Blanks and Zinc Products
  Manufacturer of Baseball Bats and Golf Clubs
  Manufacturer of Product Carriers and Printed Labels
  Manufacturer of Rotogravure Printing Cylinders
  Manufacturer of Screwdrivers
  Manufacturer of Pliers and Wrenches
  Manufacturer of Finished Metal & Plastic Parts
  Manufacturer of Prewashed Jeans
  Manufacturer of Paints and Lacquers
 Manufacturer of Gravure-Coated Metalized Paper & Metalized Film
 Manufacturer of Surgical Implants
 Manufacturer of Aluminum and Steel Parts
 Manufacturer of Aerial Lifts
 Manufacturer of Mountings for Electronic Circuit Components
                                                  111
            EPA/600/S-92/034
            EPA/600/S-92/015
            EPA/600/S-92/016
            EPA/600/S-92/017
            EPA/600/S-92/018
            EPA/600/S-92/019
            EPA/600/S-92/020
            EPA/600/S-92/021
            EPA/600/S-92/022
            EPA/600/S-92/028
            EPA/600/S-92/029
            EPA/600/S-92/030
           EPA/600/S-92/031
           EPA/600/S-92/032
           EPA/600/S-92/033
           EPA/600/S-92/034
           EPA/600/S-92/035
           EPA/600/S-92/036
           EPA/600/S-92/037
           EPA/600/S-93/007
           EPA/600/S-93/008
           EPA/600/S-93/009
           EPA/600/S-94/003
          EPA/600/S-94/004
          EPA/600/S-94/005
          EPA/600/S-94/006
          EPA/600/S-94/007
          EPA/600/S-94/008
          EPA/600/S-94/009
          EPA/600/S-94/010
          EPA/600/S-94/011
          EPA/600/S-94/012
CONTINUE ON NEXT PAGE

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       Manufacturer of Felt Tip Markers. Stamp Pads, & Rubber Cement
       Manufacturer of Coated Parts
       Manufacturer of Microelectronic Components
       Manufacturer of Corn Syrup and Corn Starch
       Manufacturer of Caulk
       Manufacturer of Electrical Rotating Devices
       Manufacturer of Parts for Truck Engines
EPA/600/S-94/013
EPA/600/S-94/014
EPA/600/S-94/015
EPA/600/S-94/016
EPA/600/S-94/017
EPA/600/S-94/018
EPA/600/S-94/019
TO CERI PUBLICATIONS UNIT:
        PLEASE SEND THE ABOVE GUIDES TO ME AT THE FOLLOWING ADDRESS:
                    NAME                                           .
                    ADDRESS           	;	
                                               112
                                                        ซU.S.  GOVERNMENT PRINTING OFFICE:  1995-650-006/22032

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