POLLUTION PREVENTION OPPORTUNITY
ASSESSMENT UNITED STATES ARMY CORPS
OF ENGINEERS PITTSBURGH ENGINEER
WAREHOUSE AND REPAIR STATION
AND
EMSWORTH LOCKS AND DAMS
PITTSBURGH, PENNSYLVANIA
by
TRC Environmental Corporation
Chapel Hill, North Carolina, 26514
Contract # 68-D2-0181
Project Officer
N. Theresa T. Hoagland
Sustainable Technology Division
National Risk Management Research Laboratory
Cincinnati, Ohio 45268
NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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CONTACT
Terri Hoagland is the EPA contact for this report. She is presently with the newly organized
National Risk Management Research Laboratory's new Sustainable Technology Division in Cincinnati, OH
(formerly the Risk Reduction Engineering Laboratory). The National Risk Management Research
Laboratory is headquartered in Cincinnati. OH, and is now responsible for research conducted by the
Sustainable Technology Division in Cincinnati.
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DISCLAIMER
The information in this document has been funded wholly or in part by the United States
Environmental Protection Agency under contract 68-D2-0181 to TRC Environmental Corporation It has
not been subjected to the Agency's peer and administrative review, and it has not 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
The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency strives to
formulate and implement actions leading to a compatible balance between human activities and the ability
of natural systems to support and nurture life. To meet this mandate, EPA's research program is
providing data and technical support for solving environmental problems today and building a science
knowledge base necessary to manage our ecological resources wisely, understand how pollutants affect
our health, and prevent or reduce environmental risks in the future.
The National Risk Management Research Laboratory is the Agency's center for investigation of
technological and management approaches for reducing risks from threats to human health and the
environment. The focus of the Laboratory's research program is on methods for the prevention and
control of pollution to air, land, water and subsurface resources; protection of water quality in public water
systems; remediation of contaminated sites and ground water; and prevention and control of indoor air
pollution. The goal of this research effort is to catalyze development and implementation of innovative,
cost-effective environmental technologies; develop scientific and engineering information needed by EPA
to support regulatory and policy decisions; and provide technical support and information transfer to
ensure effective implementation of environmental regulations and strategies.
This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office of Research and Development to assist the user
community and to link researchers with their clients.
E. Timothy Oppelt, Director
National Risk Management Research Laboratory
in
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ABSTRACT
This report summarizes work conducted at the United States Army Corps of Engineers (USACE)
Pittsburgh Engineering Warehouse and Repair Station (PEWARS) and Emsworth Locks and Dams in
Pittsburgh, Pennsylvania under the U.S. Environmental Protection Agency's (EPA's) Waste Reduction
Evaluations at Federal Sites (WREAFS) Program. This project was funded by EPA and the Strategic
Environmental Research and Development Program (SERDP) and conducted in cooperation with
USACE officials.
The purposes of the WREAFS Program are to identify new technologies and techniques for
reducing wastes from process operations and other activities at Federal sites, and to enhance the
implementation of pollution prevention/waste minimization through technology transfer. New techniques
and technologies for reducing waste generation are identified through waste minimization opportunity
assessments and may be further evaluated through joint research, development, and demonstration
projects.
A pollution prevention opportunity assessment (PPOA) was performed during June 1994 which
identified areas for waste reduction at PEWARS and the Emsworth Locks and Dams maintenance
activities. The study followed procedures outlined in EPA's Facility Pollution Prevent;™ ft. .MO Although
the repair station was efficiently designed and employees have established numerous onsite procedures
resulting in the reduction of waste generation, opportunities were identified for further action. This report
identifies potential procedural initiatives as well as technology options to achieve further pollution
prevention progress. :
All waste generating processes were initially screened during a site visit. Opportunities to reduce
wastes in each area were identified and evaluated.
This report was submitted in fulfillment of Contract Number 68-D2-0181 by TRC Environmental
Corporation, under the sponsorship of the U.S. Environmental Protection Agency. This report covers the
period from 1 March to 30 September 1994; work was completed as of 30 September 1994.
iv
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CONTENTS
Section
Page
Contact ... ..................... _
Disclaimer .................. ...... ......... '
Foreword ........................... ............... "
Abstract . ..... '..;... ......... ............... ." " ' ; ............. ' ' ' "'
Tables ............ . ............
figures .............. ......... ................ ^
[[[ wjj
Acknowledgements ........... . ........... , .......
: .......... ......................................... viii
1 INTRODUCTION ... ..... ...............
1.1 PURPOSE ..... .. ............... ...... ...... ........ 1
1.2 APPROACH ... ..................... 1
.................... ' ....................... ____ ... 3
1 .2.1 Report Structure .................
1 .2.2 Objectives of this PPOA
•••••••••*••*.....,,, ^
2 SITE DESCRIPTIONS ____ ..............
2.1 Emsworth Locks and Dams ...........
2.1 .1 General Activity Description
2.2 PITTSBURGH ENGINEERING WAREHOUSE AND REPAIR STATION ............ 7
3 SITE ACTIVITIES DESCRIPTION
3.1 Emsworth Locks and Dams
................. r ............. ..... ........ 10
3.1.1 Equipment Inspection, Lubrication, and Routine Maintenance-. .............. 10
3.1.2 Hydraulic Oil System Operations
...... ••••••••.......».. ,B> t4
3.1.3 Painting and Depainting ............
3.2 PEWARS../ ...... ............... _ ........................ 16
3.2.1 Depainting . ....................
3.2.2 Painting .....
*" ..............................................
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4 OPPORTUNITY ASSESSMENT . . 22
4.1 GENERAL 22
4.2 Emsworth Locks and Dams ROUTINE OPERATIONS AND MAINTENANCE 22
4.2.1 Use of Conventional Lubricants 22
4.2.2 Hydraulic Oil System 26
4.3 PEWARS
4.3.1 Depainting 2y
4.3.2 Painting 33
4.3.2.2 Requirements of Alternative Systems- ..; 35
4.4.3 Storage and Inventory Control : 40
4.4 POTENTIAL DEMONSTRATION PROJECTS AND SUMMARY , 40
5 REFERENCES
' '' ' 43
APPENDIX A PPOA WORKSHEETS ... .,
44
VI
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V
FIGURES
Number
1
2
Pollution Prevention Program Overview
Location Plan, Emsworth Locks, Dams and PEWARS
2
6
TABLES
Number
1
2
3
4
5
6
7
8
Lubrication Chart for Lock-Operating Equipment 11
Lubrication Chart for Main Channel and Back Channel Dam-Operating Equipment .... 13
Comparison of Grease and Non-Grease Lubricated Bushings 25
Lead Paint Removal Methods 29
Comparison of Paint Removal Methods 30
Comparison of Recommended Alternative Paint Removal Methods 34
Comparison of Paint Methods 38
Summary of Significant Wastestreams Generated by Emsworth and PEWARS and
Recommended Options for Wastestream Reduction or Modification 42
VII
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ACKNOWLEDGEMENTS
The authors wish to acknowledge the help and cooperation provided by Jim Fisher, Dan Foster,
Dave Black, and Jim Stull of the USAGE. In addition, information provided to us by vendors of equipment
and services, additional USAGE personnel, and the useful project guidance and review comments of the
EPA Project Officer, Brenda Massengill, the EPA Project Work Assignment Manager, James Bridges;, and
trie EPA Task Work Assignment Manager, Terri Hoagland, are appreciated.
This report was prepared for EPA's Pollution Prevention Research Branch by Stephen Walata, Jill
Vitas, Mark Smith, Dan Bowman, and Jan Smith of TRC Environmental Corporation under Contract No.
68-D2-0181.
VIII
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SECTION 1
INTRODUCTION
1.1 PURPOSE
The purpose of this project was to conduct a Pollution Prevention Opportunity Assessment
(PPOA) of the United States Army Corps of Engineers (USAGE) Pittsburgh Engineering Warehouse
and Repair Station (PEWARS) and operations at the Emsworth Locks and Dams in Pittsburgh,
Pennsylvania. The assessment was conducted under the Waste Reduction Evaluations at Federal
Sites (WREAFS) Program, which is administered by the Pollution Prevention Research Branch of the
National Risk Management Research Laboratory (NRMRL) of EPA. The study was conducted in
accordance with the EPA manual, Facility Pollution Prevention Guide (EPA/600/R-92/088), which
describes procedures for collecting and analyzing information using detailed worksheets to
characterize waste streams and pollution prevention alternatives.
Pollution prevention in environmental management requires the development of a
comprehensive program which continually seeks opportunities to implement cost-effective strategies
to reduce waste generation. PPOAs provide detailed assessments of waste streams, options for
preventing pollution, and analyses of alternative operating practices which generate less waste.
Figure 1 identifies the key elements of a pollution prevention program showing the interrelationship of
the PPOA to the program. The elements of the pollution prevention program are discussed in detail
in tne Facility Pollution Prevention Guide.
The approach for conducting the PPOA at PEWARS and Emsworth Locks and Dams is
described in this section. Section 2 describes both of the facilities. Section 3 describes activities
identified that generate waste at the two facilities. Possible alternative practices to minimize these
wastes are discussed in Section 4. Recommendations for potential follow-up activities are also
included in Section 4. The PPOA worksheets used during the site visit are included in Appendix A.
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Figure 1. Pollution prevention program overview.
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1.2 APPROACH
1-2.1 Report Structure
This report summarizes the PPOA efforts conducted at the Emsworth Locks and Dams System
and PEWARS. A general description of the facilities is presented in Section 2, and the facility
maintenance operations are described in Section 3. As apparent in these two sections, operations
performed at the two facilities are related, in that PEWARS performs painting, departing, storage
and routine and major maintenance operations for all flood control and navigation projects in the
USAGE Pittsburgh District, including Emsworth. Normal operations are quite different at the two
facilities. Emsworth personnel have the chief responsibility for controlling lock and dam operations at
their facility. PEWARS maintains a large warehouse, which is used to store materials and repair
equipment for all of the USAGE Pittsburgh District sites. PEWARS also maintains a floating barge
which is used to perform maintenance activities and travels to various Pittsburgh District sites
The facilities generally operate separately; therefore, their operations are discussed in separate
subsections of this report. Activities discussed in detail about one facility that are relevant to the
other are referenced in the applicable section, in order to avoid redundancy.
1-2-2 Objectives of this PPQA
To allow for navigation of major rivers in the United States, ft is necessary to maintain lock and
dam operations. The most significant environmental disturbances from locks and dams occur during
initial construction of these projects, which can permanently alter the local ecosystems. Generally,
the environmental impact during normal, continuing operations of the projects is much less
significant. Minimal air and water pollution are generated by lock and dam systems, and generally
few natural resources are consumed during normal operations. However, during the assessment of
PEWARS and Emsworth, areas were identified for both of the facilities that appear to be candidates
for waste reductions. The following areas were identified as having the greatest potential reduction
in waste generation:
Bearings, chains, gears and other components in the lock and dam system needing" lubrication
The current hydraulic system which transfers lubricating oils
Depainting methods
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Painting types and application methods
Inventory control practices
These significant areas are described in detail in Section 3 of this report. Potential waste-saving
measures are discussed in Section 4.
During the site visit conducted in connection with this PPOA, all areas of waste generation and
potential reduction were discussed to promote understanding of all facets of the operations and
barriers to potential waste-reduction initiatives. Research conducted subsequent to the site visit
explored pollution prevention issues that affect these facilities and similar systems throughout the
United States. This PPOA report attempts to provide specific pollution prevention initiatives
applicable to PEWARS and Emsworth. while maintaining a broader perspective on the potential for
similar measures at other facilities.
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SECTION 2
SITE DESCRIPTIONS
2.1 EMSWORTH LOCKS AND DAMS
2.1.1 General Activity Description
The Ohio River is separated into two channels by Neville Island, east of the town of Emsworth,
Pennsylvania. The Emsworth Locks and Dams System is located on both of these channels. The
lock and dam system consists of two separate water control systems on the two channels. The main
portion of the project consisting of two locks and a gated dam, is located on the main channel near
the town of Emsworth, 6.2 miles downstream from Pittsburgh, where the confluence of the Allegheny
and Monongahela Rivers form the Ohio River. The second portion, which consists of a single gated
dam, is located on the back channel of the river across Neville Island, 6.8 miles downstream of
Pittsburgh. The location plan for Emsworth is illustrated in Figure 2.
Emsworth Locks and Damss (main channel dam and backwater channel dam) were originally
constructed on the main channel between 1919 and 1922. Operations commenced on September 1,
1921. The dams were reconstructed between 1935 and 1938 to install movable gates and to
increase the water level upstream by seven feet. Major rehabilitation of the Emsworth lock and clams
was performed by USAGE between February 1980 and August 1984.
The Emsworth locks enable boats (commercial and recreational) travelling on the river to be
raised or lowered to the water levels created by the Emsworth dam. The typical differential in water
level on the two sides of the dam is approximately 18 feet. The locks operate by permitting boats to
enter on one side of the dam through open lock gates ("miter gates." so called because they come
together at an angle). The hydraulically operated miter gates then close, sealing the boat into the
lock. The water level in the lock chamber is then either raised (for a boat traveling upstream) or
lowered (for downstream travel) by means of water-carrying culverts located on either side of the lock
chamber. Hydraulically operated butterfly valves located in the culverts are opened or closed to
allow water flow. The miter gates on the opposite side of the Hock chamber are then opened,
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allowing the boat to pass. The system consists of two locks which are different sizes, the landward
lock being 600 feet long by 110 feet wide, and the riverward .ock measuring 360 feet by 54 feet.
River water impounded behind the dam is called the "pool." Pool levels can be controlled by
movable tainter gates built into the dam. The gates are normally in the .owered position but can be
raised to allow increased water flow downstream (thus decreasing the pool level upstream) Pool
elevation on the upstream side of the dams is normally 710.0 feet above mean sea level (MSI) while
the pool elevation on the downstream side is normally 692.0 feet above MSL
Most lock and dam operations for the main channel are controlled from the operations building
located on the middte wall of the locks. The upstream lock gates for the smaHer lock are operated '
from the control station at the upstream gate bay. Dam operations for the back channel are located
•n the back channel control building. Three hydraulic oil pumps which provide oil to the lock gab.
butterfly valves are located on the second floor of the operations building. Routine maintenance'
acfvities are conducted at scheduled intervals. ,n addition, major maintenance activities, consisting
of lock gate repair or replacement, hydraulic system repair, repair or replacement of lock chamber
equ,pment. and dredging of chambers and approaches, are scheduled periodically throughout the life
of the system.
2.2 PITTSBURGH ENGINEERING WAREHOUSE AND REPAIR STATION
PEWARS is located on Neville Island between the main and back channels of the Ohio River
near the town of Emsworth. The tract of land currently occupied by PEWARS was originally part of a
much larger facility built by the Dravo Corporation in conjunction with the United States Navy which
constructed landing craft, destroyers, and other vessels for use in World War II combat At that time
the buildings housed fabrication shops, warehouses, .aboratories. carpentry shops, steam generation'
facttea. offices, and locker rooms. The yard areas of the facility were used for steel fabrication and
storage activities.
In 1947. ownership of the property reverted back to the United States government and was
then transferred to the USAGE. The USAGE transferred the Pittsburgh District's Repair Station from
Chartera, Pennsylvania to Neville Island. The property then became known as PEWARS PEWARS
now operates to fulfill the following five objectives:
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Act as a central receiving agent for the Pittsburgh District's 27 navigation and flood control
projects
Store spare parts critical to the operation and maintenance of the District's navigation and
flood control projects '
Repair and fabricate critical parts for the District's navigation and flood control projects
Respond to and support any emergency situations that adversely affect the District's navigation
and flood control responsibilities
Perform all major maintenance on the District's navigation and flood control projects
The main building of PEWARS is the 90,000 square foot maintenance warehouse, which
houses machine, welding, electrical, and carpentry shops. Generally. 30 to 40 people are employed
at the Repair Station. In addition to maintenance operations, the warehouse contains, a supply
storage area for the Pittsburgh District. Consumable materials such as paint, antifreeze, degreaser
compounds, lubricating oils, paper products, and other miscellaneous items are purchased by
PEWARS and are stored at and distributed from the warehouse. In addition, the warehouse serves
as a storage facility for surplus property generated throughout the Pittsburgh District prior to
relocation or disposal.
PEWARS operates a floating maintenance barge which travels on the Ohio River system and
performs repairs at various Pittsburgh District projects. The barge also performs maintenance
operations at the PEWARS facility. The barge measures 52 feet wide by 150 feet long. Typically, 40
to 50 people are employed both on the floating barge and in the field operations sections of
PEWARS. The barge is capable of supplying electrical power, compressed air and fuel, and can
provide the following services: ,
Steel fabrication, machining, carpentry, and masonry operations
Heavy mobile equipment, tool, and other equipment repair
Sewage treatment
Storage for both hazardous and nonhazardous waste
Sandblasting and painting activities
Diving operations
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Sanitation support
The warehouse and floating maintenance barge together enable PEWARS to conduct several
repair operations simultaneously. Routine daily maintenance operations conducted at both the
warehouse and barge include lubricating and greasing gears, chains, and bearings in the lock
mechanisms; repairing parts and equipment; and checking hydraulic systems for any leaks or breaks.
These maintenance operations are required at the Emsworth Locks and Dams, and much of this
work is performed by PEWARS using the warehouse and floating maintenance barge.
In addition to routine maintenance, major maintenance and repairs are conducted by the
PEWARS floating barge, field sections, and outside contractors at each of the sites within the
Pittsburgh District. Major maintenance and repair activities, which often require complete dewatering
of lock chambers, include installation of new lock miter gates, repair of hydraulic crossovers, repair or
replacement of lock chamber parts and equipment, and dredging of chambers and approaches.
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SECTIONS
SITE ACTIVITIES DESCRIPTION
3.1 EMSWORTH LOCKS AND DAMS
3'1'1 Equipment inspection. Lubrication, and Routine Maintenance
3.1.1.1 Description-
Equipment inspection, lubrication, and routine maintenance is performed on all Emsworth
equipment at the regularly scheduled intervals suggested by equipment manufacturers and specified
in USAGE guidelines. Routine maintenance may include adjusting, lubricating, or cleaning equipment
as required. Some of this maintenance is performed by Emsworth personnel and other maintenance
is performed by PEWARS personnel. However, this maintenance will only be discussed in the
Emsworth sections in order to avoid redundancy in this report. Information pertaining to maintenance
is stored on Preventative Maintenance Cards, USAGE Form 1852, which are kept on file at •
Emsworth. Information recorded on,the maintenance cards includes the following:
Inspection frequency
Type of equipment
Location of equipment
List of required inspections
Date of inspection
Name of inspector
Item number inspected
Descriptions of any repair performed (recorded as "Remarks")
Table 1 provides a summary of the maintenance schedules for lock-operating equipment, as
well as the preferred brand of lubricant used. The major task involved during routine maintenance
activities conducted on the lock-operating machinery is ensuring that a proper amount of lubricant is
present on all bearings and other parts requiring lubrication. All parts requiring lubrication are. at a
minimum, lubricated every six months and cleaned every two years. Cleaning involves washing with
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TABLE 1. LUBRICATION CHART FOR LOCK-OPERATING EQUIPMENT
""*""" "'''•"''" ' ' I '- — 1 . . ' "-L'_ ..I I"— •-•'• -I, Li
Jtem of Equipment Frequency of Lubrication
Lock Gates
Pintle bushings
Gudgeon pins
Strut pins
Gate Anchorages
Roller bushing pins of
the mitering devices
Tumbuckles
Latching device
turnbuckles
weekly
weekly
weekly
6 months
weekly
6 months
weekly
Fiske-Lubriplate No. 630AA®
Fiske-Lubrlplate No. 630AA®
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
S.A.E. 20 or 30 Motor Oil
Lock Gate Operating
Machinery
Sector pin
Strut pin at sector arm
Horizontal roller pins
Vertical roller pins
Gate end casting
Rack teeth
Sector teeth
Guide shoe and back of
rack
weekly
weekly
weekly
monthly
monthly
monthly
monthly
monthly
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
Never Seez®
Never Seez®
Fiske-Lubriplate No. 630AA®
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kerosene, which functions as a solvent to remove spent lubricant, flushing with a light oil to remove
any remaining lubricant or other impurities, and applying a fresh supply of lubricant.
Dam gate inspections are performed every six months. Table 2 provides a summary of the
frequency of lubrication and lubricant of choice for the dam-operating equipment. During this
inspection, idler sprockets and guide bearings on each gate are lubricated. All gear and pinion teeth
are surveyed for misalignment, and are then lubricated after the correct alignment is ensured. Gate
chains are lubricated and protected with a high grade chain dressing. The bulkhead hoisting cranes
require periodic maintenance, which includes lubricating all gear boxes with high-grade light oil. In
addition, all bearings and gears, including the gears on the driving wheels of the crane, must be
properly lubricated. The proper amount of hydraulic oil must be maintained in the crane hoist
mechanism.
As mentioned, the major component of routine maintenance performed at the Emsworth lock
and dam is the addition of lubrication to the lock and dam bearings, gears, chains, and other
equipment. This equipment usually deteriorates due to two factors. First, the equipment components
are exposed to high pressure during operation, causing them to vibrate. If uncontrolled, the vibration
will heat or begin to cause fractures in the components, eventually causing the components to fail.
This type of failure could be immediate if the equipment is under great stress, or could take many
months or years to occur.
The second type of component failure is due to contamination entering the joint. As air or
water passes by the joint, movement of the joint will inevitably allow some particles to enter. This
paniculate material can scour the surfaces within component joints, eventually causing failure.
Failure due to scouring generally occurs over a relatively long period of time, usually many months or
years, and is most common in joints operating in water containing high levels of particulates. When
this type of failure occurs, the equipment typically must be replaced.
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TABLE 2. LUBRICATION CHART FOR MAIN CHANNEL
OPERATING EQUIPMENT
AND BACK CHANNEL DAM-
Frequency of Lubrication
Gate Hoist Mechanism
Motors
Ball Bearings
Pressure Grease Fittings
Enclosed worm gear
reducers
Open spur gears and pinions
Main lift chains and
sprockets,
chaindressing sprocket
bearings, pressure
grease fittings
Gate guide wheels
bearings - plain,
pressure grease fittings
Exposed portions of shafting
Bulkhead Hoisting Crane
Hoist Motion
Motors - ball bearings,
pressure grease fittings
Spur gear reducers -
enclosed both lubricated
Open spur gear and
pinion, gear dressing
plain bearings
Pressure grease fittings
Drum bearings, pressure
grease fittings
Wire rope dressing
Travel Motion
Motor - ball bearing, '
pressure grease fittings
Enclosed worm gear reducer
Open gear and pinion
gear dressing
Pleiin bearings, pressure
grease fittings
Wheel bearings, plain
tjearings, pressure
grease fittings
6 months
6 months
6 months
check monthly
6 months
6 months
not specified
not specified
6 months
check monthly
6 months
6 months
6 months
6 months
6 months
check monthly
6 months
6 months
6 months
Fiske-Lubriplate No. 630AA*1
Fiske-Lubriplate No. 630AA1*
Fiske-Lubriplate No. 630AA1*
S.A.E. 90 Transmission Oil
Never Seez®
Fiske-Lubriplate No. 630AA18
not specified
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
S.A.E. 90 Transmission Oil
Never Seez®
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
Never Seez®
Fiske-Lubriplate No. 630AA®
S.A.E. 90 Transmission Oil
Never Seez®
Fiske-Lubriplate No. 630AA®
Fiske-Lubriplate No. 630AA®
13
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Operation of the hydraulic pumps is conducted from the control stations on the middle wall of
the lock. The hydraulic system which controls the gates is supplied by two of the three pumps at any
given time. The pumps are arranged and interconnected for pump rotation so that combinations of
two of the three pumps may be used to control the gates. The selected pump combinations are
regulate'd from the control center and are changed weekly so that all pumps receive equal use.
Each hydraulic pump is equipped with a filter capable of passing 60 gpm of hydraulic oil
through 149-micrometer filter elements with a pressure drop of three psi. An additional filter is
located in the return line which allows for six-micron filtration. The filters are periodically changed out
and disposed of during preventative maintenance operations at the facility.
The hydraulic piping system consists of primary and secondary lines. Primary lines consist of
dedicated pressure or return lines in which the oil always flows in one direction. The primary lines
connect the three oil pumps to four-way control valves, which are controlled from the operations
building. The secondary lines connect the four-way control valves to cylinders which actuate the
hydraulically controlled units. Secondary lines serve as both pressure and return lines, depending on
the direction of gate movement. .All of the hydraulic lines are welded into continuous lengths, with
the exception of locations that require assembly and disassembly of valves and equipment. Many of
the hydraulic lines are located beneath the facility floor, and are inaccessible for prompt service or
repair: ,
A hydraulic oil storage tank for the gate system is located on the second floor of the middle
wall control center. The tank provides storage for any oil not immediately needed to fill the hydraulic
lines and cylinders. When oil is lost from the system, it will automatically be replenished by the
storage tank. The tank has a maximum storage capacity of 400 gallons. A cleanout opening is
located at each end of the tank, and a drain cock is located at tank bottom. The tank is equipped
with a site level gauge which is used to maintain the established volume of oil in the system. If the
volume of hydraulic oil decreases below the acceptable level, an oil-level monitoring system will
sound an alarm and shut down the pumps.
An additional hydraulic system is used to operate the tow haulage and retriever system. This
system serves to move boats which are operating without power through the lock chamber. The
hydraulic system consists of a hydraulic motor, hydrostatic power drive unit with oil reservoir, variable
displacement pump, and an electric motor. Unlike the hydraulic system used to operate the gates,
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this system utilizes a localized hydraulic oil reservoir and does not have long lines connecting the oil
storage tank to the equipment. This system operates independently of the gate hydraulic system.
3.1.2.2 Pollution Prevention Issues-
Waste hydraulic oils are generated from the hydraulic systems through breaks in hydraulic
lines and leaks in seals and fittings. If a break-occurs in one of the hydraulic lines, a significant spill
could occur in a short period of time. Since the system is interconnected with feed and return lines,
a break in a line will continue to drain the oil in the system until hydraulic pressure decreases or the
leak is sealed. According to onsite personnel, a major break in the main system is likely to result in
the loss of 200 to 500 gallons of hydraulic oil. PEWARS personnel estimate that a break of this
magnitude occurs every 5-10 years at one of the Pittsburgh district facilities. Many of the hydraulic
lines at Emsworth are located in culverts or encased in concrete, making access for repairs
extremely difficult and time-consuming.
Routine maintenance of the central hydraulic system includes periodic additions of fresh oil to
the tank. Generally, the hydraulic fluid is not routinely changed; instead, oil is added as necessary to
maintain the proper fluid level in the tank. According to site personnel, approximately 50 gallons of
hydraulic oil are added to the system each year. Much of the loss is attributable to leaks around
loose fittings. Although there is no planned schedule for changing the hydraulic oil in the system, site
personnel indicated that the oil is drained and replaced approximately every 10 to 20 years.
The main hydraulic oil system has functioned property since its installation over 30 years ago,
and there are no plans for replacing it. However, if it is replaced in the future, it would be
environmentally preferable to install a system with localized hydraulic oil units, like the system
currently used at Emsworth to operate the tow haulage and retriever system. This option is further
discussed in Section 4.2.2.
3-1.3 Painting and Deoaintinq
All gate depainting and painting is conducted by work crews located at PEWARS. These
operations are discussed in Sections 3.2.1 and 3.2.2.
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3.2 PEWARS
3.2.1 Depainting
3.2.1.1 Description-
Routine maintenance on lock gates within the Pittsburgh District includes renewing existing
coating systems (such as removing rust and paint from the gates and repainting), performing
structural repairs, renewing cathodic protection systems, and repairing various gate operating
components. The lock gates in the District come in a variety of sizes and designs. The Pittsburgh
district has 25 lock chambers with widths of 56 feet, 84 feet, and 110 feet. These lock chambers
incorporate ten different gate heights, depending on the head differential. Gate heights range from
21 feet 7 inches to 43 feet. 1 inch. The District possesses at least one spate set of each size of the
56 foot lock changer gates which are stored at PEWARS. The primary gate rehabilitation work that is
performed at the PEWARS is on these 56-foot changer lock gates. Nearly all other gate
rehabilitation work on the 84-foot and 110 foot lock gates is performed in the field by the PEWARS
repair party. Many of the gates int eh district were originally coated with a lead based primer and/or
a lead-based or vinyl top coat. Approximately four years ago, PEWARS converted its coating
standard to a two-part epoxy system. Vinyl paints are still used but only rarely in touch-up
applications. Lead-based coatings are no longer applied at amy of the facilities in the District.
Gate rehabilitation, which includes departing and repainting, is performed on different
schedules depending on the size of the lock gate, the location, and the water conditions. In general,
56-foot lock gates are rehabilitated on a 10-year cycle. The larger gate rehabilitation cycle is longer
due to a number of factors including original coating system integrity, delays to navigation (since
locks are closed during rehabilitation work), difficulty of work due to the larger gate sizes, and the
unavailability of spare gates.
3.2,1.2 Pollution Prevention Issues-
Because of the non-routine painting schedule for the large gates, there are a number of gates
with lead-based paint currently in operation. Lead-based paint waste can constitute a hazardous
waste, depending on the lead concentration, and must be managed and disposed of accordingly.
PEWARS personnel estimate that it will take 15 or more years before all lead-based paint on
Pittsburgh District equipment is removed and disposed of.
17
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The blasting material currently used by PEWARS is a coal by-product, trade name Black
Beauty® Due to its hardness and angularity, this slag abrasive has been the most effective paint
removing abrasive used at PEWARS. PEWARS has estimated that approximately ten pounds of
Black Beauty® are used to remove one square foot of paint from a gate. However, this amount can
vary depending on the gate condition, sandblasting equipment and media condition, or operator
experience.
PEWARS utilizes a vacuum conveyor system to collect and contain spent blast media. The
spent sandblasting material and paint are collected by a vacuum feed system and sent to a cyclone.
The cyclone extracts the spent material from the air. Cyclone waste is then collected in a dumpster,
and the waste is tested for lead content. If the lead concentration is greater than 5 parts per million
(ppm), it is considered a hazardous waste and disposed of accordingly. The cost of disposing of this
material as a hazardous waste is $200 per ton. If the lead content is below 5 parts per million, it is
considered non-hazardous and disposed of in an appropriately licensed landfill at a cost of $60 per
tori. Generally, on coating systems containing a moderate porportion of lead, through th enormal
abrasive blasting process, a large volume of spent abrasive is mixed with the hazardoous paint
partiles such that the resulting residual waste mixture contains less than 5 ppm lead and can be
disposed of as a less than hazardous material.
A number of alternatives were identified for departing operations which could reduce solid
waste volumes generated in the depainting process. These options are discussed in Section 4.3.1.
3.2.2 Painting
3.2.2.1 General-
As described above, the routine maintenance performed at PEWARS includes periodically
stripping paint from lock gates and repainting them. The paint system used to repaint the gates
consists of a primer base and a paint coating recommended by USAGE. Both the primer and paint
are similar two-part epoxies. although the primer is enriched with zinc to reduce biological fouling.
The primer and paint are thinned with T-10 Thinner®, which consists of a combination of solvents
(i.e., 40 percent xylene. 40 percent n-butyl alcohol, and 20 percent methyl n-amyl ketone). This
solvent combination is added at a ratio of one unit volume of solvent for every ten unit volumes of
primer or paint. Standard operating procedure is that no more primer or paint is mixed than can be
used in one workday. An advantage of the epoxy system over previous types of paint used at
PEWARS is that once mixed, the unused portion can be allowed to harden, and then can be
18
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disposed of as a non-hazardous waste. However, this hardening allows the remaining solvents in the
paint to escape to the atmosphere
The two-part epoxy paint is applied by an airless spray gun. First, the primer coat is applied,
followed by an application of the epoxy paint. Then a second primer coat is applied, followed by a
second epoxy paint coat. On average, a 56-foot lock gate will require a total of 40 gallons of paint to
complete the coating system to a thickness of 14 to 16 mils. The gates are generally painted at
PEWARS, within a recently constructed metal building which serves as a departing and painting
booth. Occasionally, gates may be painted while in place at a lock and dam. The facility estimates
that 2 to 4 gates are depainted and repainted at PEWARS facility annually. Every few years,
depainting and repainting activities will be conducted at a lock and dam facility with the assistance of
the floating barge.
3.2.2.2 Pollution Prevention Issues-
PEWARS has already undertaken major steps to reduce pollution generated by painting. The
use of an airless spray system with epoxy paint complies with EPA requirements for VOC levels in
paints, which must contain less than 2.8 pounds of VOC per gallon of paint. This system is also
easily applied and has shown reasonable durability. However, there are alternative systems that are
being developed which may prove to be reliable and reduce waste generation. These alternative
paint systems are discussed in Section 4.4.
PEWARS currently uses T-10 Thinner® to clean the paint guns after use. This waste is
sprayed into an open drum at which time some of the thinner is vaporized. Any remaining waste
liquid is placed into a closed drum for proper disposal as a hazardous waste. Further pollution
prevention might be achieved by the use of alternate products for paint gun cleaning. Products such
as Citrabake® and EP921®. which are manufactured by Inland Technology Inc., represent
biodegradable alternatives which would reduce the usage of hazardous materials and the volume of
VOC emissions generated during cleanup. However/cleaning waste would still have to be disposed
of as a hazardous waste, so there would be little to no financial savings in a conversion to alternative
cleaning products.
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3-2-3 Major Lock and Dam Maintenance and Repair
3.2.3.1 General-
Major maintenance and repair often requires complete dewatering of a lock chamber and may
include the following activities: installation of new lock gates, repair of hydraulic systems, repair or
replacement of lock chamber parts and equipment, and dredging of chambers and approaches. Most
of these activities involve construction such as removal and replacement of concrete, lumber, and
steel structures. The waste streams generated from these activities typically include scrap metal,
lumber, and concrete. , '
3.3.3.2 Pollution Prevention Issues-
Scrap metal is accumulated at the PEWARS. Carbon, stainless and brass metals are
separated and sold for recycling. Lumber is collected in dumpsters which also are used for the
accumulation of typical construction waste. These materials are disposed of off-site at a licensed
landfill. Used oil is generally collected in 55-gallon drums and tested by independent laboratories for
disposal classification. Currently, all used oils are transported off-site by an independent certified
disposing agent, and are used as an alternate fuel source.
PEWARS has taken a proactive approach to handling the wastes generated during major
maintenance and repair. Whenever feasible, wastes are recycled. Oil wastes are recovered for use
as an alternative energy source if possible. Few pollution prevention opportunities exist for these
activities, as recycling and reuse measures have already been implemented. Methods of source"
reduction could be considered; however, such as reducing the amount of metal or lumber needed to
complete the work.
3.2.4 Storage and Inventory
3.2.4.1 General-
As stated earlier, one of the missions of PEWARS is to provide storage for equipment, parts,
raw materials, and waste generated by the Pittsburgh District's operation. In the past. PEWARS
purchased materials in bulk quantities to save money. However, this resulted in the expiration of
some materials before their use. As a result, expired supplies often were disposed of.
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3.2.4.2 Pollution Prevention Issues-
In the last few years, PEWARS has been able to reduce its waste production by 50 percent
through adjustments in its supply management methods. PEWARS no longer purchases in bulk and
describes its purchasing practices as "just-in-time." According to PEWARS personnel, this system
has helped to minimize the potential for expiration of on-site.materials before their use.
Currently, PEWARS conducts major purchases for the District sites. Each of the sites within
the District purchases small quantities of raw materials for their own use. This may lead to higher
levels of waste generation than necessary, as one site may purchase chemicals that could be
available from and are no longer required at another site. These chemicals may expire even though
they could have been consumed elsewhere in the District. A further discussion of PEWARS supply
management system is presented in Section 4.5.
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SECTION 4
OPPORTUNITY ASSESSMENT
4.1 GENERAL
During the site visit at PEWARS and Emsworth Locks an* nom* *h
nh^n/oH off«rt K «=mswonn LOCKS and Dams, the assessment team
observed efforts by personnel at both facilities to rprfnro u/o<-t u
t t -IL. euuws wastes. However, additional opportunities
for further progress in waste reduction were identified. This section discusses the ongoing
as well as additional options which
and Dams and PEWARS.
4.2 EMSWORTH LOCKS AND DAMS ROUTINE OPERATIONS AND MA.NTENANCE
4-2.1 Use of Conventional
4.2.1.1 Current Practices-
As previous* discussed, there are a number of components in the lock operating system which
oe lubricated, includinq bearinas ae>ar«s anH ^h-,;,,* -n, • u - ..
,
Tn '" upa '° lubtote me »*«» - these
. The grease protects the components in the equipment from environment contaminants and
a»o»s movement of the various Joints in the units. Spent crease is siowly reused to (he
,ub,ion
tor lubrication and cleaning is provided in Table 1.
The vast majority of locks and dams currency operating were constructed with components
o rr 9rease r*** ™ese systems require the c°nsumpti°n
to enter the surround.ng water. However, there are alternatives to these systems which do not
require greasing. These alternatives are summarized in Section 4.2.1.2.
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4.2.1.2 Alternative Lubricant Materials--
There are a number of manufacturers that make non-grease lubricated materials for use in
apphcatjons like locks and dams. Specifically, seven manufacturers of such material, were located
during the research for this report. These companies are Thordon Bearings Incorporated, Giles '
Orkot, capraton. Deva Corporation, Lubron Bearing Systems, and Voist-Alpine. All of the systems
manufactured by these companies are composed of synthetic materials. Most rely on some form of
asbestos, nylon, or teflon as a coating for the joints where they are placed. Some use a synthetic
mater* bonded. to metal, but even in these systems, the synthetic material is the exposed portion in
the joint. '
The makeup of each of the systems investigated for this report is proprietary. However there
are three general classes of alternative materials that are commonly found among the non-grease
lubricated systems. These classes are as follows:
'
'
The first of these classes may be appropriate for the relatively low-pressure environments found in
ock and dam systems. However, they do not function well in environments with high contaminant
loads, as they are susceptible to damage by contaminating undissolved solids. If solid particles
scour the surface of this class of synthetic material the .ubricant wi.l be ,ost. and the material wil, not
allow easy rotation of the joint It is ,ike.y that the submerged joints containing this c.ass of material
wh,ch are exposed to waterborne contaminants would not function well in a lock and dam setup The
second and third types of materials appear to be applicable for use in high pressure heavy
part.culate-.oad environments, as they can be scoured to some degree and still maintain lubrication.
Synthetic bearing systems have been installed in hydroelectric power plant wicket gate
beanngs. turbine main bearings and other bearings in the turbine and wicket gate system, and in
23
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marine craft bearings. Synthetic systems have been used in water containing relatively high
concentrations of undissolved solids, as might be found in lock and dam systems. However, there is
no proven history of the application of synthetic materials in lock and dam systems. It is likely that
there are wide variations in performance of various manufacturers' synthetic materials. There is also
variation in the proper application for the different types of materials. Before any system or material
is installed, it must be studied and tested thoroughly to determine its applicability and durability
Several systems investigated for this report are discussed below.
One system studied for this report, the Lubron® system, manufactured by Lubron Bearing
Systems in California, uses a teflon base in a bronze substrate. The teflon has lubricant in its matrix
and additional lubricant can be deposited in machined recesses in the bearings. This system
appears to be a hybrid of the second and third synthetic systems listed. Lubron has experienced
successful runs in several types of marine bearing systems, such as hydroelectric power plants and
sh.p rudders. Lubron is currently being tested by USAGE for use in gate applications. The USAGE
test, which is being conducted at the Carter Dam project in Georgia, should help determine the
applicability of Lubron in other lock and dam assemblies throughout USAGE.
Another system studied operates with a coating of a material called Thordon®. Thordon. which
is manufactured by Thordon Bearings, Incorporated of Canada, appears to fall into the third category
oi lubricated synthetics listed. It functions as a lubricant-impregnated spongelike matrix
Unfortunately, officials at Marine Industries Corporation, which is the American distributor of Thordon
were unwilling to divulge information relating to any lock and dam facilities that may have
implemented Thordon in their systems.
According to PEWARS personnel, it is their understanding that two attempts have been made
•n the District to use non-lubricated bushings in its larger machinery applications. The first was a
graphrte impregnated bushing in which small pockets of graphite were made into the bushing. This
application was not successful, as dirt from the river water appeared to accummulate and combine
w,th the graphite pockets. The mixture hardened and became an abrasive, rather than a lubricant.
The second involved the Thordon product on valve machinery bushings. This product has not been
in place long enough to determine its effectiveness.
4.2.1.3 Recommendations- =
Table 3 contains a general comparison of the implementation of the grease lubrication system
and the non-grease lubricated systems. While the greaseless systems have superior environmental
24
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25
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characteristics, the systems have no proven history of operations in lock and dam environments.
Also, refurbishing a lock and dam with a greaseless system is a major undertaking. In addition to the
time and expense required for refurbishment, the facility's lost availability while it is being refurbished
must also be considered. If a facility requires refurbishment, it would be logical to install greaseless
systems at that time. However, if a facility's systems are functioning well, it might be economically
prohibitive to take the facility off line in order to implement a greaseless system.
Each case of potential refurbishing must be considered individually for its productivity loss and
overhaul costs. The tests currently being conducted on the Lubron system by USAGE should further
indicate the applicability of greaseless systems in lock and dam operations. Certainly, if a lock and
dam system relying on grease lubrication is to be refurbished, greaseless materials appear to be an
environmentally preferable alternative.
4.2.2 Hydraulic Oil System
As previously discussed, the lock system at Emsworth contains gate and valve systems that
are hydraulically operated. These systems are powered by three vane pumps which distribute oil
from a centralized 400-gallon oil reservoir. The electrically powered pumps send hydraulic oil to the
hydraulic units in the gates and valves throughout the locks and dams through a network of
aboveground and underground lines. The pumps are only active when a unit is in use. Otherwise,
the system remains shut down. According to onsite personnel, oil added to the reservoir each year
averages approximately 50 gallons.!
According to USAGE personnel, there are occasional rapid oil losses from these systems.
These losses are normally caused by a line failure, although occasionally a pump or hydraulic unit
may develop a rapid leak. It is possible that during a rapid release, a significant amount of oil may
leak out of the system. Facility personnel estimate that 200 to 500 gallons could be lost before the
system could be shut down and line loss stopped. In addition to rapid losses, there are also slower
losses due to wear in the lines, pumps, and units. These losses are very difficult to locate within the
system because of the length and number of lines. Emsworth personnel estimate that 50 gallons a
year of oil are added to the hydraulic oil system due to losses from the system.
The hydraulic system has functioned well over its lifetime. It does not appear that the system
will require replacement in the near future. However, if the units are replaced, an alternative design
for the system would likely reduce pollution by minimizing releases. The current system uses one oil
26
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reservoir and a network of oil lines to transmit oil to the various hydraulic mechanisms in the lock
system. By localizing the units, the length of the oil transmission lines could be reduced drastically.
Currently, a localized hydraulic unit powers the tow haulage and retriever system. This smaller
system does not have long oil lines connecting the oil reservoir to the unit. This system has
operated effectively at Emsworth for over 30 years.
In addition to localizing the units, placing the oil lines aboveground and ensuring that they are
accessible would further improve their potential to reduce oil loss. The lines of the current system
travel underground through concrete channels, making portions of the lines inaccessible, and greatly
increasing the likelihood of slow losses not being located and having major breaks not easily
repaired. Any future replacements for the hydraulic units should have accessible lines.
With smaller line lengths and accessible lines, both rapid and slow spills would be much
easier to localize and remedy. In the event of a rapid spill, the smaller hydraulic oil tanks and line
volume in the localized units would not contain as much oil as the current centralized tank, and
therefore, could not leak as much oil at one time. A localized hydraulic oil system would appear to
significantly reduce the potential for oil spillage over time.
Since the current hydraulic oil system is operating effectively, it would be difficult to justify
removing and replacing it with a localized oil system. However, when Emsworth's system is at the
end of its useful lifetime in the future, a localized hydraulic oil unit sending system appears to be
environmentally preferable to the current centralized system. It is noted that on newer structures
within the District, and when major rehabilitation work is performed on older structures, the District
has eliminated the extensive runs of hydraulic line in favor of localized electro-hydraulic actuator
units, thus reducing the potential for pollution from hydraulic oil spills.
4.3 PEWARS
4.3,, 1 Depaintinq
4.3.1.1 Alternative Methods-
As discussed in Section 3.2.1, PEWARS is responsible for departing and painting operations
for all 27 Pittsburgh District flood.control and navigation sites. Departing and painting are usually
performed at the PEWARS warehouse departing and painting booth. However, for large lock gates,
depainting and painting may be performed in place. PEWARS utilizes a product called Black Beauty
27
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applied with a Chemco sandblaster for paint removal. Black Beauty is made up of bituminous coal
Once a gate is depainted. the blast material is tested for lead content. If the lead content is greater
than 5 ppm, the waste is disposed of as hazardous waste.
The industrial Lead Paint Removal Handbook' provides a list of 18 currently utilized methods
for pant removal and surface preparation. These methods are listed in Table 4. The source material
for th,s summary includes a number of publications by the Steel Structures Painting Council which is
a group formed by industries in the steel paint field, as well as a variety of other documents
addressing state of the art and innovative technologies for removal of paint and surface preparation
for steel structures. Chapter 5 of the Handbook provides a summary, rating, critique and discussion
ol each of these 18 methods: Each method is rated with respect to the following characteristics:
Equipment required and expense
Debris created and dust generated
Type of containment used and containment requirements
Productivity/production rate
Table 5 compares all 18 methods by numerical rankings given for each of these
characteristics.
The current method used for departing at PEWARS for both the maintenance shop and
on.-s.te operations is a modification of method 3, closed abrasive blast cleaning with vacuum The
modification to the method is the use of Black Beauty. The Handbook mentions only sand or slag as
examples of expendable abrasives used in this application, and gives no specific information about
the use of bituminous coal like the Black Beauty compound used for all departing operations at
PEWARS. However, this system's performance cost, and environmental characteristics appear
similar to those of standard method 3. Note that if the Black Beauty compound is considered a slag
and the vacuum is used recover the spent abrasive, but is not an inherent part of the departing
method, it could be said that PEWARS uses Method 1; however, the analysis of alternative methods
would be the same in either case.
28
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Method 1:
Method 2:
Method 3:
Method 4;
Method 5:
Method 6:
Method 7:
Method 8:
Method 9:
Method 10:
Method 11:
Method 12:
Method 13:
Method 14:
Method 15:
Method 16:
Method 17:
Method 18:
Open abrasive blast cleaning with expendable abrasives
Open abrasive blast cleaning with recyclable abrasives
Closed abrasive blast cleaning with vacuum
Wet abrasive blast cleaning
High pressure water jetting
High pressure water jetting with abrasive injection
Ultra-high pressure water jetting
Ultra-high pressure water jetting with abrasive injection
Hand tool cleaning
Power tool cleaning
Power tool cleaning with vacuum attachment
Power tool cleaning to bare metal
Power tool cleaning to bare metal with vacuum attachment
Chemical stripping
Sponge jetting
Sodium bicarbonate blast cleaning
Carbon dioxide blast cleaning
Combinations of removal methods
Lead-containing wastes generated from the open and closed abrasive cleaning methods
(methods 1 through 3) can sometimes be disposed of as a nonhazardous waste, due to the large
volume of blasting material that is consumed in these methods. Other methods which generate lead-
containing wastes have a smaller volume of blasting material used, and therefore have a higher
concentration of lead in the waste. All of the alternative methods discussed in this section are
designed to reduce the overall volume of abrasive in the process waste stream, which will result in
increased lead concentrations and possible increases in per-unit disposal costs for the operation.
Any pollution prevention effort for the departing operation should significantly reduce the
volume of debris generated from departing without allowing unacceptable degradation of the quality
29
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of surface preparation or the production rate. Differences in containment and disposal requirements
should also be considered, as these can markedly effect the overall cost and pollution generation of
the methods. The two open abrasive cleaning methods have the highest containment requirements;
all other methods require substantially lower amounts of effort to control the removed paint and other
debris. In many methods, particles are entrained in a vacuum or water as a primary part of the
cleaning method. However, water contaminated with lead might comprise an additional disposal
concern.
The following discussion describes key differences between the methods listed in Table 4. A
more complete assessment of potential feasibility of specific methods would require testing of several
alternatives on-site at PEWARS to determine their effectiveness in the desired applications.
4.3.1.2 Evaluation of the Methods-
The following observations can be made with respect to the potential applicability of the
methods listed in Table 4 for PEWARS depainting operations. These observations are grouped into
categories of similar methods, and are compared to Method 3 (or Method 1), which is currently used
in modified form at PEWARS. These preliminary assessments may be confirmed or contradicted by
on-site testing. An attempt has been made to address costs involved with changes in technology or
blasting media. However, it is likely that only field testing would generate accurate cost estimates for
the various methods.
Methods 1 and 2: Method 1, open abrasive blast cleaning with expendable abrasives, is
the oldest and least expensive method of depainting large steel
structures, and is one of the best-performing methods. Method 1 is
one of three methods with universally high rankings for the quality of
surface preparation provided. Method 2, open blasting with recyclable
abrasives, and method 4, wet abrasive Wasting (which is described in
the next method group), rank equally high. The two open abrasive
cleaning methods, methods 1 and 2, are also the only methods which
have "very high" production rates. However, method 1 results in a
larger volume of debris created and more dust generation than almost
any other paint removal method. Only method 4, wet abrasive blast
cleaning, is also ranked as producing "substantial" debris.
31
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Method 4 :
Methods 5 through 8:
Methods 9 through 17:
Method 2, open abrasive blast cleaning with recyclable abrasives.
would reduce the amount of debris and dust in comparison to the
levels generated with expendable abrasives, with the least overall
impact on other performance criteria. According to the Handbook
rankings, essentially no change would be expected in performance; or
production rate but equipment investment would-be significant.
Wet abrasive blast cleaning would result in marginal improvements in
quality, production and containment requirements, and would reduce
dust generation significantly, but would actually increase waste-related
concerns due to the introduction of water into the process. Clean-up of
the wet slurry and wastewater generated by the method itself may be
considered hazardous waste if contamination levels are high.
Method 4 is classified as producing "substantial" debris, which is more
than all methods except method 1.
The four high and ultra-high pressure water jetting methods, methods 5
through 8. have similar benefits and drawbacks to those described for
Method 4, except that debris volume would not be as large. The
quality of surface preparation would likely be unacceptable for method
5. high pressure jetting without abrasive, but the use of abrasive
injection and/or ultra-high pressure in methods 6 through 8 would likely
prove adequate for most PEWARS applications. However, plain water
jetting at either pressure provides little capability for rust removal from
any type of surface.
Hand tool cleaning and power tool cleaning of all types, methods 9
through 13, would not provide the quality of surface preparation and
production rate required at PEWARS. This is also true of three of the
other final four methods (i.e., chemical stripping, sodium bicarbonate
and carbon dioxide blast cleaning). Sponge jetting appears to have
adequate surface preparation and debris reduction properties, but has
a low to moderate production rate, which, although above the rates of
these other methods, is probably not adequate for the volume of work
and time constraints involved in the PEWARS operation.
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The aPP|ica«°n of Method 18 would likely entail cleaning the surface
with hand tools and power tools combined with blast or jet cleaning.
While various combinations of Methods 1 through 17 might provide
certain advantages in performance, the complication of using two
different sets of equipment in production-scale cleaning operations
would likely be prohibitive.
Based on this evaluation, the possible substitutes for the current depainting method at
PEWARS are:
Method 2, open abrasive blast cleaning with recyclable abrasives
Method 6, high pressure water jetting with abrasives
Method 8, ultra-high pressure water jetting with abrasives.
Table 6 contains a direct comparison of these three methods.
4.3.2 Painting
4.3.2.1 Current Practices-
The most significant pollution prevention alternative in the area of painting is the use of
alternative panto. Alternative paints could reduce the emissions of VOCs to the atmosphere
Alternative paints that could be used in Jock and dam maintenance will be discussed in this section.
The lock gates in the Pittsburgh District system were originally painted with a lead-based paint
Due to health concerns, the USAGE switched to two-part epoxy paints in the late 1980's and vinyl
res,n paints for touch up applications. Vinyl resin paints have proven to be extremely durabte with
We expectancies of 20 to 40 years. These paints cure in ,ess than one day and cost approximately
u . ! 7JJT£* ^ aPP'ied H°WeVer' dUe t0 their high VOC «*««*• ^ ™* ^ in limited
us, by USAGE. The two-part epoxy which has been used by PEWARS since the late 1980's has
delayed reasonabte durability, arthough not dose to the levels of vinyl resin paints because of its
sensrtMty to abrasion impacts. The life expectancy of the two-part epoxy paint is typical* 15 to 20
years. However, if the gate is subjected to water with high particulate content, the life expectancy
may be reduced to 3 to 5 years.
33
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c « If
I Milss
3 .2 * S g £ .2
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The two-part epoxy paint used by PEWARS has application difficulties, as it is sensitive to
temperature during application and may require up to seven days to cure. The epoxy paint costs
approximately $1.60 per square foot of paint applied. Also, the two-part epoxy tends to chalk when
exposed to long periods of direct sunlight. In some cases, the paint can lose up to 1 mil per year
due to chalking, reducing the average life expectancy to 12 to 14 years. Chalking can be prevented
with the application of a urethane top coat, although this substantially increases the cost and
complication of the coating operation.
Advantages to the epoxy paint systems include the fact that they can be applied at
temperatures well below 40 degrees, which is important in the maintenance function at PEWARS. In
addition, with the advent of epoxy PRE-PRIME coatings, surface preparation requirements are
becoming somewhat more forgiving than for vinyl systems.
4.3.2.2 Requirements of Alternative Systems--
When analyzing alternative paints for the lock and dam it is important to have an
understanding of the following two characteristics of the paint:
abrasion resistance
level of corrosion resistance
• resistance to fouling by microorganisms in the water
The paint must perform well in all of these areas in order to function properly in a lock and dam
operation. In addition, it is important to determine the conditions to which the paint will normally be
exposed. In a lock and dam, the gate may be completely submerged at all times or submerged at
times and exposed to the atmosphere at times. Certain paint formulations have better durability
characteristics for atmospheric exposure than water exposure and vice versa.2
In addition to having preferable environmental characteristics, it is important that the paint
application be an effective and environmentally acceptable method. Certain paint application
methods produce high volumes of paint overspray, thus wasting paint and generating excessive
waste. Alternative painting methods will be discussed in Section 4.3.2.3, while alternative paints will
be discussed in Section 4.3.2.4. This is followed by a summary of painting options in
Section 4.3.2.5.
35
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4.3.2.3 Alternate Painting Application Methods-
Currently, there are five methods for applying paint to a surface: brush, paint pads, roller, mitt
and spray. For large structures, such as the gates on a lock or dam, spray methods have proven to
be the most cost efficient and expedient method. There are many types of spray equipment used in
paint application. This discussion will focus on four of these methods, three of which have been
proven effective in steel structure painting, and one of which is an emerging technology that may
prove applicable in the future. The three currently applicable methods are air spray airless spray
and high-volume, low-pressure (HVLP) spray. Electrostatic spray is an additional, unproven method.
Currently, PEWARS utilizes an airless spray system.
Air spray was the method originally developed for paint spray application. In this method, air is
supplied by a compressor to a spray gun which atomizes the paint and projects it onto the structure
or part. This method causes a large amount of overspray and paint loss, up to 40 percent in some
applications. This method is no longer frequently used because of the volume of overspray. and
concern for worker safety due to the atomized paint deposited in the ambient air.
Airless spray allows for a reduction of overspray while continuing high product throughput.
This method utilizes hydraulic pressure of 1,000 to 6,000 pounds per square inch to force paint
through a gun. The gun is designed to separate the paint into small streams, causing atomization of
the paint as it exits and is projected onto the structure or part. This method is faster, cleaner, less
expensive, and easier to use than the conventional air spray system. In addition, paint lost due to
overspray is 10 to 15 percent less than in air spray systems.
The HVLP spray method uses a turbine to generate a high volume of air that atomizes the
paint at a low pressure and projects'the paint on to the structure or part at a low velocity. This
method has proven successful with high solid coatings. The paint loss to overspray is minimal and
the system is easy to clean. However, there are several drawbacks to this method. The capital and
maintenance costs for the HVLP equipment are high. Because of the low velocity at which the
coating is applied, the speed of application is much lower than the airless spray method. In addition
no currently utilized high solids coatings researched for this report are suited for use in lock and dam
environments.
An additional method that has not been adapted to large steel structures, such as lock and
dam gates, is electrostatic spraying. In this method an electrostatic charge is generated between the
applirator and surface, which allows for distribution of an electrically charged paint spray to all
36
-------
exposed conductive areas. This method has the lowest overspray potential of all spraying methods
developed to date, as it ensures that the paint is active.y attracted to the surface being painted
However, the method has on,y been used on smal, parts, and may not prove appiicab.e for lar^e
structures ,,ke lock gates. A.so, in current applications the method is expensive, has a s.ow
throughput, and paint can only be applied in thin coats.
Based on the information gathered on paint application technologies, the airless spray gun
currently utilized at PEWARS appears to be the most effective and efficient process for large scale
pa.nt.ng operations. As discussed above, none of the other technobgies presented are currently
echn.cal.y feasible for use at PEWARS. However, the HVLP method could be used if a suitable
h,gh- solids paint formulation is deve.oped and the application speed proves acceptable, .n addition
ongomg research may generate advances in the electrostatic spray method. ,„ the future this may'
prove to be an environmental preferable and functionally effective alternative to the airless system.
4.3.2.4 Alternative Paints-
in th T3ble \ *T* 3 C°mPariSOn °f P3intS 3nd theif Pr°PertieS- Altemative Pain's are discussed
in the remainder of this section.
h f. . I0 .-i-i—.— •••-•—="»'='/thick coating, are being tested
by the U.S. Army Corps of Engineers Construction Engineering Research Laboratory (CERL)
Results to date have shown a limited life expectancy, generally less than five years. In addition
because of the increased thickness of the coating, the cost can be two to three times the cost of viny,
rssin p3int.
Another type of two-part epoxy paint that is currently undergoing development is a coal-tar
epoxy. The performance levels of these oaints are not «,„»„«» available as ftey are stj|| ^
— — ••-"•«7 vj.anauic, eia uiey are still oeino
developed. However, due to their potential toxicity and ooncern for worker safety, these paints L,
no, prove, „*« Accord,n9 to PEWARS personnei, an existino ^pe of coa,.te, epoxy. lich as
^been used ,„ the Pmsburgh DisWc, is known ,o have shown breakdown when continual* submerged
Another class of paint that is being tested by CERL is an air-cured urethane. Tnere are
)l fliTTArAnt ff\r*t n ttf^tm^^.^^. ^.f AI_;_ i .
InTf ° ° ^^ WhJCh C°ntain ^ IevelS of 2inc - h» oxide
•n the formu.at.on. These paints typicaliy cure in ,ess than one day and require .ess significant
surface preparation than either vinyi resins or epoxies. CERL is current* testing these paints to
37
-------
Wrf
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38
-------
determine life expectancy and performance levels.
The application of moisture-cured urethane paints can be very difficult, especially if paint is
appted to the gate while it is still in p.ace on the .ock or dam. This is because the moisture from the
water flowing near the gate cou.d cause the paint to prematurely cure. There may be .imitations to
aPP.,cat,on methods in the Pittsburgh District, depending on the relative humidity, if the humidity is
low, the curing process may proceed s.ow.y. However, during periods of high humidity application
may prove difficult due to premature curing. Currently, CERL is comp.eting testing to determine the
me expectancy and performance levels of these paints.34
CERL has completed preliminary testing of 100 percent solids paint in both one-component
and mulfcomponent formulations. These paints do not contain or emit VOCs. However the one-
component system does not perform well when immersed in water for long periods of time The
paint will blister and peel off, reducing the life expectancy. The multicomponent system is also
difficult to apply. Further testing is necessary to definitively determine its life expectancy3 However
performance limitations in the current formulations make the systems unacceptable at this time.
Another paint that emits no VOCs is powder coatings. These coatings are difficult and time
consuming to apply. ,„ addition, they are very sensith/e to abrasion. CERL tests have determined
that even in quiet immersion, with .ittle or no abrasion caused by the water, the paint detaches from
the surface, exposing the metal within five years.3
4.3.2.S Painting Summary-
At this time, it is premature for PEWARS to consider converting to an alternate paint or
appl.cat.on method. The two-part epoxy currently in use complies with the EPA requirement for
products with VOC content of .ess than 2.8 pounds per ga.lon. However. non-VOC containing paint
formulations are continuing to be developed and tested, such as the 100 percent solids powder
coatmge, and organic antifouling paints. Advances in the paint development area could result in
effective, environmentally preferable paints.
Although none of the coatings discussed above are currently ready for industrial use PEWARS
might prove an ideal test site for the evaluation of these alternatives.
39
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4'4'3 Storage and Inventory
As discussed in Section 3.2.4. PEWARS has been successful in changing their method, of
_en, ,0 he,p preven, oversupply of raw materia.s that would normally^,, in so t
educTth , ' PUrChaS'"9 °" a" "" "eeded" baSiS' PEWARS has -*— *• «-» "-e
reduced their waste generation by 50 percent.
r, "9
hasing responses. Th,s would require further reduction of individual ste's suppf/ purchases
would h.,p prevent purchasing duplicate ma,eria,s. and therefore reduce she«etses
addmon. a centralized frackin, system should b. devetoped to keep an inventory of a,, mate a,
pTircr rr° "• quamities avaiiabie' and sheif '^ -*- •» -^ - ~-
Ll h , re"U"ed '° Ch6Ck ^ da'abaSe '°r applicabte "«««* ^ oversupply
«* be made ava,,ab,e to the Pittsburgh District sites. By tracking material and expirafcn d",es
and nsunng that al, facilities have access ,o chemicals stored throughout the d*tnct PEWAR
-hould be ab,e to greatly reduce the losses due to shelf ,i,e exceedance and purchasing redundancy.
'U POTENTIAL DEMONSTRATION PROJECTS AND SUMMARY
nd P6WARS "aVe areas Of ** "^'^ that could
from the addition of the following pollution prevention initiatives.
1.
2.
3.
4.
Substitution of the current departing method with a lower-waste generating alternative
Substitution of the current paint and application method with a lower VOC-emitting system
5- Further implementing the centralization of and tracking system for the inventory control process
to any lock and dam site. Numbers 3 through 5 were described under the PEWARS
or Ci0rage0f "* "^ ^ ''"''"^ ™* ** * ** *"* that «"*"• "*« «*—"»
40
-------
Of the five initiatives listed above, initiative 3 appears to be an excellent candidate for a
demonstration projects. The most promising demonstration projects are:
Method 2, open abrasive blast cleaning with recyclable abrasives
Method 6, high-pressure water jetting with abrasives
Method 8, ultra-high pressure water jetting with abrasives
Any of these three methods would produce significantly less solid waste than the current operations
atPEWARS.
Initiative 4 could also prove beneficial if powder or 100 percent solid coatings progress to the
point where they are suitable for conditions such as those found at PEWARS and Emsworth Locks
and Dams.
Table 8 provides a list of wastestreams generated at Emsworth and PEWARS, and options
recommended for those wastestreams.
41
-------
IJf
x: S «
m n eft
c i 8
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= .£!•£ »
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o
I
i
42
-------
APPENDIX A
PPOA WORKSHEETS
44
-------
Firm USAGE
SH> Pittsburgh. Pennsylvania
Dai* September 30. 1994
Pollution Prevention
A»»«««nent Worksheet*
P«J. No. 01645-0111-00003
Prepared By Vitas (
By J. Smith _
ShMt_1__oM_ Pag* _ Of
WORKSHEET
1
EMSWOflTH LOCK AND 0AM
L
• Mvm «•>.««
-------
Ftaii_ USAGE
D«te September 30
Po«utk>n Prvvwition
Worksheet*
Pro|.No.Q1645-0111-QQOa
PreperedBy Vitas
Checked By J. Smith
Sheet 1 of
WORKSHEET
2
: U.S. Army Corps of Engineers
Punt: Emsworth Lock and Dam
stniet Addreee; 3500 Grand Avenue. Neville Island
; Pennsytvania 15225-1584
T«h>phot*! (412) 644-4184
Major Product*: None
EPA Qwumrtor Number:
, minor maintenance
: Dams originally construe hneen 1919 ^ 1922 Reconstructs
jgtween 1935 and 1938 and major rehabilitation wa. completed in 1984.
-------
Firm USAGE
-
Data September 30, 10
PolMlon Pravantten
Aa**a*mant Woricsha«ta
Pro|. No. Q1645-0111 -00003
Praparad By_ Vitas
Chackad By J. Smrth
Sh««t_1_of_2_ Pag* el
WORKSHEET
3
PROCESS INFORMATION
J»it>cw Unlt/0paf»tlen; Equipmart Ir^p^ctioo, Lubrkatkan. and Routing Mamtenanc*
Icontinuou*
D Batch or Saml-Batch
Q Otocrvt*
D Othar
Oocumant
Procwt Flow Diagram
Flow/Amount Maaawanwita
Op«*«flng Manuah
Equlpmmt Sp«clficatlon«
P»p>nfl and tnatrunwit Djaarama
PLet aod Evaluation Ptarrfa)
Work now Diagram*
Haairdout W«a1«
lEnvtrontmntat Audit
™ "• •" "i—i—^^Bl^,^^
Batch Sh»«K»
Itarttena Dtagrama
l-rexiuc* Com
fiOatartal Saf
OpjiatorLog,
-------
Hrm USAGE
SHta Ptttsburah,
P*.. September 30. 1994
Pollution Pravwttlon
Worfcaha^a
NO. 01 645-01 11 -00003
Praparad By Vrtas
Chockad By J. Smith
_2_of_2_ Paga of
WORKSHEET
3
PROCESS INFORMATION
Procoaa Un»JOparatton; Hydraulic Oi Syatam
Opatetfon Typa: C
O Baton or Saoil-Bateh
DOiacrata
D Othar
uocumant
»ea«a Flow Diagram
•• i •••••••——£—.
tarfaPEnar gy Batanea
aalgn
p« rating
w/Amount Uaaauramanta
traam
irawn
caea Da«cr^>tten
•rating Manuala
HpmantUat
Upmant Spedficattona
»HJ and (namimant Otograma
it and Evaluation Ptanft)
* Flow Diaorama
•nteiw Wa«ta ManHaata
acton Invantortaa
lual/Bfartnial Rapotta
fonmarrtal AudR Raporta
naVParmft Applieationa
ASftaa4(a)
trials ApplJcatJon* Dtagrama
wtol Safaty Data Shaata
ntory Raeorda
"uctlon SefMdulaa
Comptatal
(Y/N)
N
N
Y
Y
N
N
N
N
N
N
N
N
N
N
N
N
N
Y
N
N
N
Currant?
(Y/N)
Y
Y
Laat
Ravialon
1088
Uaadbtthia
Raport(Y/N
Y
Y
Decuman
Numbar
Locution
— 1
-------
Pr*par*dBy Vitas
PolMlon Prevention
3H* Pittsburgh
As**s*m*nt Worksh*«t»
Ch*ck*d By J. Smith
Oat* September 30
ProJ. No. 01645-0111 -00003
__ P»g« _ of
WORKSHEET
4
INPUT MATERIALS SUMMARY
SEE SECTION 2 OF PPOA
Str*am Nc._
Numt/ID
—
Seurca/Suppiter
CompenenVAttrfcut* of Concwn
Annual Consumption Rat*
Overall
>^**^m—n
Compon«nt{«) of Concern
PurehsM Prio>, $ p«f
Ovtrall Annual Cost
D«llv*ry Mod*
~
Shipping Container Size &
Mod**
••MMBMMI
Transfer Mod*4
•
gmptyComaltw Disposal Management*
Shelf Ufa
snipping container*; n/tn
jgvlM *xplratlon d«t*? (Y/N)
^•P^bto SubstKuto(s). If any
SuppB*t(*)
100 bfal tank uck, truck,
- •
•«., outdoor, warahous*. undarground,
. •*., pwnp,
crush and tondffll. d*«,
-------
Prepared By Vrtas
Ch+ckad By J. Smitfi
Pollution Pr«v»ntlon
Work»h*«t»
SHU Pittsburgh.
D«u September 30
Pro|. No. 01 645-01 1 1 -OQQfM
WORKSHEET
5
INPUT MATERIALS SUMMARY
NO PRODUCTS FROM OPERATION
ComporMnt/AttriMrt* of Concwn
Araw«> Consumption Rate
Overall
Compoiwrt(«) of Conctm
Shipping ContoltMf Sto 4 typ«
On«it«
Mod*
•ta^BB*H^
Rrtumtfate (Y/N)
Customer Would
_t»to ep^Mertion (Y/H)
contabMrs
-------
Firm USAGE
site Pittsburgh. Pennsylvania
Pitt* September 30, 1994
WORKSHEET
6
Pollution Prevention
Asaesament Worksheets
Pro). No. 01645-0111 -QQQOa
WASTE STREAM SUMMARY
Prepared By Vitas
Checked
Sh«et_1_of_2_ P*g«__.of_
Equipment Inspection. Lubrication, and Routine Maintenance
—"—«—•••—•
Description
Wast« ID/Name:
Stream No. 1
UsedLubncant
(Source/Origin
Component or Property of Concern
Annual Generation Rate (units
Lock/Dam Gates
Component(e) of Concern
Cost of Disposal
Unit Coat ($ per:
Overall (per year)
Method of Management1
Containers Returnable (Y/N)
Prteirfty Rating Criteria1
I Regulatory Compliance
I Treatment/Disposal Cost
Potential Uabinty
Wa4rte Quantfty Qenenrted
Wairte Hazard""
Safnty Hazard
Mlnimfzatlon Potential
"**'*™^"1I""I^™"^0™*^™^^^'I1*^^^""*^"""^"^™^^^MW^^^^
PoUmttol to Remove Bottleneck
Potential By-product Recovefy
Sum of Priority Rating Score*
Priority Rank
,,Wr«..i
2. Rate each stream in each category on « aoite from 0 (none) to 10
51
-------
FlraiJJSACE
Sfri Pittsburgh. Pennsylvania
Daia_ September 30.1994
Pollution Pravantion
Aaaaaamant Worfcahaata
ProJ. No. 01645-0111-00003
Praparad By___Vjjas__
Chackad By J. Smith
Shaat 2 ef 2 Paga of
:>*_
•^
WORKSHEET
6
WASTE STREAM SUMMARY
Hydraulic Oil System
StraamNo. 2
Waata ffi/Nama
Sourea/Origln
Oompooant or Property of Conom
AmH«al3«n«nrtiofi Rat* (unto
Lock/Dam Gst»s
OomjjofMnt(») of Concern
($p^; j
Ovoral (p«r VMT)
of ManagsfMnt
ConUJmra Rctumabl* (Y/N)
Off site «n«rgy
raoovery
Ralathr*
WtfW)
Prteffty Rating
Bagutrtoiy Oonytonet
Waste Quantity Qawatad
Safety Haaart
P®tafiiUal to Ramova Bottianack
Byproduct Racovafy
Scan <>m terity Rating Scorea
Prfority Ra
-------
Firm USAGE
Pollution Prevention
Prepared By Vitas
A«*e»*ment Worksheet*
SHe Pittsburgh.
Checked By J. Smith
Date September 30
ProJ. No. 01645-0111-00003
SheeM_of_J_ Page of
OPTION GENERATION
Mating form* (..g., bralr-tormlng, nomin.. group
Meeting Coordinator J.
Meeting Participant* D. Bowman, J V»ac Q Wala
Llet^SuggeetJon Optfone
ATTACHED
R«tten«le/Rem«fk> on Option
-------
EMSWORTH LOCK AND DAM
PITTSBURGH, PENNSYLVANIA
PPOA BRAINSTORMING SESSION
I. OPPORTUNITIES TO REDUCE WASTE GENERATION
A. INPUT MATERIALS
Identify areas that appear to be candidates for reduction or alteration of current
practices to reduce input materials
Investigate use of alternative materials which are environmentally preferable
Reduce consumption rates where feasible
B. WASTE MANAGEMENT
Segregate wastes and attempt to retain value of components
Recycle and reuse materials where possible
transferrinS
C. AWARENESS
Communicate environmental information and objectives to employees
Periodic "rnenoV inspections of areas to assess environmental status
Ensure employees understand environmental impacts of all processes and materials
** mlamaaa^ ******* n*thods to performing
54
-------
D. INVESTIGATION BY PROCESS
A. USE OF CONVENTIONAL LUBRICANTS
« Evaluate current lock and dam systems and grease and oil consumption requirements
* fa*ta"««' «• "* and dams that would not require
Determine applicability in current and future lock and dam systems
B. HYDRAULIC OIL SYSTEM
Evaluate current hydraulic oil control system for lock gates and butterfly valves
" SSS? ^^ ^^ ** WOUld rCdUCC Ae P0551^ for <*°™ and rapid oil
Determine applicability in current and future lock and dam systems
55
-------
Fkm USAGE
SRe Pittsburgh,
Pollution Prevention
A»*e*»ment Worksheets
P«»l- No. 01645-0111-00003
Prepared By Vitas
Checked By J. Smith
Sheet 1 of 2 Pag* _ Of _
September 30
OPTION DESCRIPTION
Option Name Installation of ^r^ ^ ^..^ h ^^ „.,
tn addfton. place the lines of the system
•tyve Qtouno TOT easy area*. t» ,T.J, t,^. ^\ ~
StTMnX*) Affected: Num
Jnput M«Urial(») Affected: Hydraulic ail
Pfe«Juct(e) Affected:
|lndteato Type: D Source Reduction
_x_ Equ^ment-Related Change
— PersonneVProcedure-RelaUd Change
Uaterials^elaled Change
O Recycling/Reuse
— S!H* — ««t^W reused for original purpoee
— Off.de —Material used for • towar-qualfty purpos*
Material sold
Origin* By proposed by;TRC
pleviewed byTRC
D«te: 6/20/94
Date:
tor atudy?
By; TRC
for Acceptance or Rejection Reduction of » ^nffeant wast,
56
-------
Firm USAGE
September 30. 1994
Pollution Prevention
Assessment Worksheets
_PjtteburghJ'ennsv1vania Checked By J. Smith
Pro). No. 01645-0111 -00003
Prepared By Vitas
Sheet_1_of_2_ p«g« of
WORKSHEET OPTION DESCRIPTION
o • ' I
8
Option Name Installation of alternative bearing material*
Briefly descrfce the option; Remove current Qfaase^ubricated parts from tack and dam aatas and refurbish
with a non-greasa lubricated system. '
Wa«te StretnXe) Affected; Number 1
Input Meter!al(e) Affected: Grease lubricant*
Product(«) Affect^:
Indicate Type: O Source Reduction
Equipment-Related Change
Personnel/Procedure-Related Change
x Materials-Related Change
D Recycling/Reuse
Onsfte ; Material reused for original purpose
. Offstte Material used for a tower-quality purpose
Material eold
Originally proposed by: TRC Oat,. 6/20/94
Reviewed by TRC, __________ ; Date:
Approved for study? x ves _no By: TRC
Reason for Acceptance or Rejection Reduction of a significant waste stream
57
J
-------
Finn USAGE
Pittsburgh.
September 30, 1994
WORKSHEET
1
Polhitlon Pr«v«ntion
No. 01645-0111-0000.1
Pr«p«r»d By Vitas
Ch»ck«d By J. Smith
0. ».»«*,.., u**~
-------
Rnri USAGE
Plnri
Site.
Pittsburgh. Pennsylvania
P«t«i September 30. 1994
Pollution Pr«v«rtk>n
Pro|.No. 01645-0111-0003
Vitas
Ch«ck»d By J. Smith
Sh««t 1 of 1
WORKSHEET
2
•MMMMMBIMMHMVMa,
: U.S. Army Corps of Engineers
; Pittsburgh Engineer Warehouse and Repair Shops
Oopairtmtnt:
"*'™l™^"cks and dams In the Pittsburgh District.
SICCodM:
EPA (3«n»frtof
; PA6960010050
Major Unit:
l^oduct or Sorvie*:
Qpt«itten«; Maintenance facility and warehouse for 27 sites within the Pittsburgh
District
F«cattt««/isqutpm«>nt Ay; Facfflty built in 1943 as part of U.S. Navy's effort to support
World War H. Facility was transferred to the U.S. Army Corps of Engineers in 1947 to provide"
maintenance services to the District Floating maintenance barge commissioned in 1989. "~
59
-------
Firm USAGE
Sttw Pittsburgh, Pennsylvania
Pollution Prevention
Assessment Workaheets
Bat, September 30. 1,394 ProJ. No. 0 1645^)111 -OOOO3
WORKSHEET
3
PROCESS INFORMATION
Prepared
Checked
Sheet 1
By Vitas I
By J. Smith
.of 4 Page of
process unit/Operation: Major Maintenance - PEWARS and Floating Bug*
OfMiratlon Tvps: D Continuous D Discrete
D Batch or Semi-Batch D Other
Document
Procsss Flow Diagram
IUat«riaVEnergy B«tene«
D*ilgn
Op«r«tlng
Flow/Amount Mc**ur*m*nt*
Stroam
ProoM* 0««cription
Cpoftting Manuel*
iquf|pm«nt U«t
iquipm«nt Specification*
Piping and (natrumant Diagram*
Ptot imd Evaluation Pfan(a)
Work Flow Diagram*
Hazardous Waate ManH**t*
Emlailon biv*ntori**
Annual/Btonnial Report*
Environmental Audit Report*
Pormtt/Pennit Applteation*
Botch Sheet(a)
Mat«1ate Appllcationa Ofaarain*
Product Composttten Sheets
Material Safety Data Sheets
Inventory Record*
Operator Logs
Production Schedules
Status
Complete?
(Y/N)
N
N
Y
Y
N
N
N
N
N
Y
N
N
N
N
N
N
N
Y
N
N
N
Current?
(Y/N)
Y
Y
Laat
Revision
1983
1993
•HMVWBH^WMW
Used in this
Report (Y/N
Y
Y
Y
Documen
Number
••^•^••^•••^•••ii
Location
1
60
-------
Firm USAGE
SHe Pittsburgh, P
-------
Pollution Pr«v»ntlon
Worfc»h««tfl
Sft«_PittSbufQh
WORKSHEET
3
-------
Finn USAGE
Pittsburgh. Pennsylvania
*rta September 30r IQ
Pollution Prevention
WorJcah««t»
Prol No. 01645-0111 -00003
Prepared By Vitas
Chackad BY J. Smith
Sh««t 4 of 4 Pag* of
WORKSHEET
3
PROCESS INFORMATION
>TOCMa Untt/Optration; Storage and Inventory Control - PEWARS
>Pwation Typ«: Dcontlnooua
O Batch or Swni-Batch
Prec^a Flow Diagram
Batanc*
R<«««mount Mwiauranwrrta
PrticaM D«acrtptk>n
Equlpmant Uat
Piping and Jnatrurnant Diagrama
Plot and Evaluation Planrt)
WorK Row Diaarama
Emtoaten tnvanterlM
lEnvlronnwrtai Audit Baortt
Applteattena
Ikarttena Diagram*
«ttfonSha«ta
Safaty Data Sh»ata
Operator Lopa
Production SctMdula*
-------
Rimy USAGE
SHe Pittsburgh.
Date September 30, ia
Pollution Prevention
Aeeeeament Worfcsheeta
j. No. 01645-0111-QQOO3
Prepared By
Checked By J. Smith
Sheet_J__oM_ Pag* Of
WORKSHEET
4
INPUT MATERIALS SUMMARY
SEE SECTION 2 OF PPOA
[Sourca'Suppltor
CofTipontnVAtfrlbuU of Concern
Annual Con«umptlon Rate
Overall
Cotnponant(a) of Conoarn
P«llv«ry Mod*
Shipping Container She * type1
Storage Mode*
Trenitfer Mode*
Empty Container Dtepoeal I
[Supplier Would
- accept expired metertat? (Y/N)
dipping containers; (Y/H)
jj^vf«e explratton date? (Y/N)
Aeceptabie Subetitute(e).» any
I Alternate Suppflerfe)
Kotee: i. ».g.t pipaflna. tank car, 100 bbl tank truck, truck, etc.
2- ••0; 55 gal drum 100 •> paper beg, tank, etc.
3. e.g^ outdoor, warehouee, underground, aboveground, etc.
«. e^., pump, foridfft, pneumatic traneport, conveyor, etc.
e.g.. crueh and landfill, dean and recycle, return to euppiler. etc.
-------
Firm USAGE
gnu Pittsburgh. Pennsvtvqntfl
cm* September 30.
Pollution Prevention
A»*«s»m«nt WortuhMt*
Pro!. No. 01645-0111 -OQQOa
Pr«p*r»d By Vitas
Ch«ck«d By J. Smith
_pf 1 Pagt ot_
WORKSHEET
5
INPUT MATERIALS SUMMARY
NO PRODUCTS FROM OPERATION
AttrBxrtc
JNa
StTMmNe.
Conv©o«nVAarfcut« of Conctm
Annu«J Consumption R»t»
Compon«rt(«) of Concwn
Annual Bovtnu««, $_
Shipping Mod*
Shipping Contain* Sb» & typ«
Qtutto 9tong» Mod*
R
-------
Pr«P«rad By Vttas
Chackad By^ J. Smith
Pollution Pravantfon
Aaaasjimant Worfcah««ts
SHa Pittsburgh.
Data September 30, I
Pro|. No. 01645-0111 -POOPS
Sh*at_J_ofJi_ Paga__of
WORKSHEET
6
WASTE STREAM SUMMARY
Sourc«/Orig>n
Repair/R»plac«
~ •" -
LocVDam Gates
~
Unknown
Rftpaif/Rapiaca
Compon»nt or F¥op«ty of Coix^rn
Annum G>n»r«tten Rd of ManaganW
Ratumabte QT/N)
Polar ittal to Ramova Bottlanoek
By-product R*cov«fy
Priority Rating
Prterfty Rank
-------
Fkm USAGE
Pittsburgh. Pennsylvania
o«te September 30,1
-------
Firm USAGE
«»• Pittsburgh. Pennsylvania
j»ata September 30,1994
Pollution Pravantlon
Aa*«ftsm«m Worksheets
Prof. No. 01645-0111 -QfWtt
Prepared By Vrtas
Checked By J. Smith
Sh*«L2j>LL.
WORKSHEET
6
WASTE STREAM SUMMARY
Departing - PEWARS and Floating MaJntenance Barge
Stream No.JI
W«*t« ID/Nam«:
Sp«flt Blasting
Sourca/OrlgIn
Ccimpon«nt or Proptrty of Concern
I Annual Ganarttten RaU (unftt
jovarall
Lock/Oam Gates
•
Unknown
Compon*nt(») of Conewn
Unit Coat ($ fwrton
$200 (hazantoua)
$60(r>oo.
hazardous)
O^rall (p«r year)
MMhodofManaganwm1
Landfill or Off sit*
r»oovaiy
Contafn«r» Ratumabl* (Y/N)
Raiathr*
Wt(W)
Priority Rating Crttaria*
Raquiatory CempHanoa
Truatimm/Dlspoaal Coat
Potential Liability
Quantity Qan«ratad
Wnata Hazard
Salaty Hazard
rMliilmfaatlon Potantlal
"Poitantllal to Ramova Bottten«ck
Poliantial By-pcoduct Racovary
Sum of Priority Rating Scora*
PrterRy Rank
-------
Prepared By
Checked By J. Smith
Pollution Prevention
Awewment Worksheet*
Prt« September 30
Prol Ne. 01645-0111-Qnnns
Sheet,4 of 5 Page Of__
WASTE STREAM SUMMARY
Painting . PEWARS and Floating Maintenance Barg«
.6
Unused Paint
•••••^•••M
Paining {Cleaning
Stream No. 8
Spent Thinner j Paint brushes, rollers
Painting
•^•••••••MM
Lock/Dam Gates
Lock/Dam Gates j Spray Gum
Unknown
Amuai
Ov«raB
••I !•
Con»f>on«nt(«} of Conwm
Off site energy
recovery
LtebiHty
W««tt« Quantity
tlinirnizatkxi Potontirt
Remov* Bottleneck
By-product Becowy
dewaterlnfl, etc.
2. Rai* **/>h mtrmm^ I- •"-',-'*• -«-««»»nin, (wvraiwng, etc.
a. R^MchslrMmlne^chert^ofypn.afi.1. from o (none) to 10
-------
Firm USAGE
SHa Pittsburgh. Pennsylvania
Data Seotember 3QF 1994
WORKSHEET
6
Pollution Pravantion PMp*»d
Aaaaaamant Workahaata Chackad 1
Proj. No. 01645-01 11-OOOOa Sha«t $
Bv Vrt^s 1
5y J. Smith
of 5 Pa0a of
WASTE STREAM SUMMARY
Storag* and Ifwantory - PEWARS and Floating Maintenance Barga
Attrfcuta
W«ata ID/Name:
Source/Origin
Component or Proparty of Concatn
Annual Ganaratton Rat* (unto )
Overall
Componant(a) of Concam
Coirt of DlapOMl
Unit Coat ($ par. -ton 1
Ovarali (par year)
Mathod of Management'
Container* Returnable (Y/N)
Priority Rating Criteria*
Ragutetory Compllanca
Tr«wtm«nt/0l»poaal Coat
Potantial Liability
Witat* Quantity Qanaratad
W«»ta Hazard
SaiTaty Hazard
Minimization Potantial
Potential to Ramova Botttonack
PoUanttel By-product Raoovary
Ralatfva
Wt(W)
Sum of Priority Rating Scons
Priority Rank
Da«cription
StraamNo. 9
-
Landfai
Rating
(R)
E(RxW)
RxW
Rating
(R) RxW
£(RxW)
H
• H
Rating
(R) RxW
£(RxW)
Notiw: i. For axampla, aanftuy landfill, fuzvdoua waata tondfffl, on-aR* racycte. inckwation
eombuation wfth 1^ rtcovaiy, diatiHatkH!, o^wtt^i, ate. r
-------
r
Finn USAGE
3*t» Pittsburgh. Pennsylvania
September 30.1994
Pollution Prevention
As*«s*nwfiA Worksheet*
Prol No. 01645-0111 -00003
Prepared Bv Vitas
Checked Bv J. Smith
Sheet 1 of 1 Page of.
WORKSHEET
OPTION GENERATION
Meeting format (e.g., bralnstorming, nominal group todwlqu*) Bfalnstorming
W«*tlrig Coordkwtor J. Smith
Mxtirifl Partlctamto D. Bowman. J. Vrtas. S. Walata
U«t Suggestion Options
R«tion«l«/R«m«rics on Option
SEE ATTACHED
71
-------
PEWARS
PITTSBURGH, PENNSYLVANIA
PPOA BRAINSTORMING SESSION
t OPPORTUNITIES TO REDUCE WASTE GENERATION
A. INPUT MATERIALS
Investigates of alternative materials which a« cnvirom^nully prefoable
Reduce consumption rates where feasible
ar,
in volumes to prevem waste from
B. WASTE MANAGEMENT
' Segregate wastes and attempt to retain value of components
Recycle and reuse materials where possible
C. AWARENESS
• Communicate environmental infonnation and objectives to employees
• Periodic -friendly" inspections of areas to assess environmental status
Ensure employees understand; environmental impacts of all passes and materials
latitude to find environment^ preferable methods to performing
72
-------
IL INVESTIGATION BY PROCESS
A. DEPAINTING
Evaluate current method of depainting lock gates
Investigate alternative depainting methods that generate less waste than current system
and operate effectively '
Evaulate methods for feasibfity, cost and environmental factors
• Recommend potential alternative methods
B. PAINTING
• Evaluate current paint and method of paint application
Investigate alternative paints and painting methods that are environmentally preferable
to the current vinyl system * v«,»«uic
Evaulate methods for feasiblity, cost and environmental factors
• Recommend potential alternative methods and paints
C. STORAGE AND INVENTORY CONTROL
Evaluate current methods of inventory control, purchasing, and distribution
Further centralize purchasing to reduce redundant purchases
• Track material use and expiration dates
Make leftover chemicals available to all Pittsburgh District sites
73
-------
Firm USAGE
Site Pittsburgh. Pennsylvania
Put* September 30.
Pollution Prevention
Assessment Worksheet*
ProJ. No. 01645-0111 -00003
Prepared By Vitas
Checked By J. Smith
Shset_1_of 12 Page of.
WORKSHEET
8
IZ
OPTION DESCRIPTION
Option Nam* Open abrastve blast deaning with recvd«bl«
Brl.fly descrfee th. optten; Use a
f9placa
cod currantv
W*rt« Str*am(«) Affected; Number S
Input M«t«riaK«) Affected: Bituminous coal
Product(s)
Indicate Typa: O Source Reduction
- Equipment-Related Chang*
JL. P^»onneVProc«
-------
[ Flnn_JUSACE
SlU^PittSbUfQh. Pennsytvanta
Data September 3Q,
Polfcitton Pravantlon
Aaaaaamam Wortcsha«ta
Pro}. No. 01645-0111 -OOftft?
Prapar ad By_Vftes
Chackad By J. Smith
Shaat 2 of 12 P»a«__of.
OPTION OESCflJPTION
Option H*m* Wat abrasJv«_bU*
[Brtofljr d^wrfc* UM option:
««a»t th« abfasiva in ramavioo tha pamt from thi kxdc
W««t« Stra«nX«) Aff*a»d; Number 5
Indicate Typ*: D Sourc* Raduetion
_x_ Equipmant-Ratatad Change
_JL. P»*»onn*VProcadur*-Ralat»d Chano*
- UatariaUhRalatad Chang*
222* — £*^lrw»* tor ordinal puipoa*
Offsto **»rWu*>dfof
_ llatortel aoM
OVlglnalljr pmpotad by: TRC.
RcvSmwd birTRC
Oat*: 6^0/94
Oat*:
I Approvod foe atudy?
.no By:TRC
75
-------
Rrm__ySA£E_
SHa PtttSburoh.
Put* September ft), toct«d; Bhuminous CM!
Indicate Typ»: D Sourc* lUductten
_x_ Equlprmnt-R«i«t«d Chang*
_x_ P*r«ofln«VProc«dura-R«lat*d Chang*
_x_ Uat*rial*-R«lat«d Changa
_ Itotwlal rauaad for original purpo**
_ _ Offatt* - M«t*flaIu»«lforalowwH|uaHtypurpoa*
_ Matarialaokf
Oirlglnally pnspoaad by: TRC
Rovtawad by TRC
Data: 6/20/94
Data:
Approval for atudy7__jL_yaa no By; TRC
or Rafrctten May incfaaa*
tha amount of dust created
77
-------
Firm USAGE
Site Pittsburgh. Pennsylvania
Date September 30.1994
Pollution Prevention
A»»**»ment Worksheets
Pro}. No. 01645-0111-00003
Prepared By Vitas
Checked By J. Smith
Sheet 5
of 12 P*Qe__.of
WORKSHEET
8
OPTION DESCRIPTION
Option Name Ultra high pressure wsler letting with abrasive
tod?
f?0-000
to
W««t» StrMm(«) Affected: Number S
Input Mat«riaK«) Aff«rt«l: Bituminous coal
Produces) AffvcUd:
propoawf bytTRC
R*vi*wod by TRC
Pat*; 6/20/94
Date:
Approved for study?
tno By: TRC
Indlcata Typt: C3 Sourc* Reduction
_JL_ Equlpm»nt-R«l«t»d Chang*
_x_ P*r»onmVProc*dura)-Ralat»d Chang*
x Mttorials-R«[at«d Chang*
O R*eyelhg/R*uM
. Onait* Material r*u*«d for original purpo**
___ Offalt* Material u**d for a towar-qualfty purpoa*
Material *oM
Reason for Acceptance or Rejection May increase paint removal efficiency, reduces tha amount of dust
ounno oaoaintirtQ • ~•"•~~••"~~•
-------
Finn USACE
Stto Pittsburgh. P
-------
USAGE
siui Pittsburgh. Pennsylvania
Date September 30.1994
Pollution Pravantton
Aaaaaamant Workshaats
ProJ. No. 01645-0111-00003
Pr«p«r*d By Vrtas
Chadcad By J. Smith
Sheat 7 of .12 Paga of.
WORKSHEET
8
OPTION DESCRIPTION
Option Nam* Moittura-cured urathana paint
Briefly daacrfca th« option; Rsplac* 2-oart aooxy paint system with a moisture-cured urethana paint.
Wa*t« StraanX*) Affactad; Numbw 9
Input M«t«riaK«) Affactad: 2-oart apoxy paint
Product(a) Affactad:.
Indkata Typa: O Sourca Raduction
Equlpmant-Ralatad Changa
Paraonnal/Procadura-Ralatad Changa
x L Matarlala-Ralatad Changa
O Racydlng/Rauaa
___ OnaRa ___ Malarial rauaad for original purpoaa
__ Offalta __ Malarial uaad for a lowar-quallty purpoaa
Uatarialaold
Original^ propooad by: TRC
Ravtowad by TRC
Data; 6/20/94
Data:
Appiovwd for atudy? x yaa.
pno By; TRC
Raai«n for Accaptanca or RaJacUon May raduea VOC amisstena
80
-------
Pollution Prevention
WoricshMts
Stt* PtttSbUfQh.
Ch*c»c*d By J. Smith
September an
Prol No. Q1645-011
WORKSHEET
8
OPTION DESCRIPTION
Option Karn* too
dMerfc* tte
*OQW oajnt system wtti a 100 parent «»iu
StrMm(8) Aff*etod: Nu
b|]«JtM*«iaK«) Affect**
lndlc«to Typ«:
Score*
- Equiprntnt-fetated Chang*
- P*r*onn*l/Proo*duro-R«l«tod Chang*
_x_ U*t*ria!»fl*!at*d Chang*
for original porpOM
OrlglnaBy prepoMd by: TRC
Oat*: 6/20/94
tor study?
for AccMrtane* or
no By:TRC
VQK ^^^
-------
firm USAGE
SH* Pittsburgh,
Pat* September 30,19
-------
Firm USAGE
Sift* Pittsburgh.
Oat* September 30,
Pollution Prevention
AMMiunmt Worfc*h**t»
ProJ. No. 01645-0111-00003
Pr*p*r*dBy VTtas
Checked By J. Smith
Sh**t_10_oM2_ P*a*__of__
WORKSHEET
8
OPTION DESCRIPTION
Option Nam* Htoh-volum*
m« option; ^qu^ont that
Waste StrunXs)
Input MateriaK*} AffecUd: 2^wt aooxv paint
Produces) Afteetod:
Ondlcatt Typ«: D Sourc* FUductlon
_x_ EquipiTMnt-ftolatod Chang*
_x__ Pwsonn«l/Proc«duro-R«lat«d Chang«
Materiato^*lat*d Chang*
D R*cydingm*u**
On*»* Matorkil r*u**d for original purpo**
Offeft* Matertal u»»d for • tow-quality purpo**
Uaterialaold
Originally proposed by: TJRC_
R*vI*w«J by TRC
Pat*; 9/05/94
Oat*:
Approved for *tudy?
yM
.no By;TRC
83
-------
FUm USAGE
Site Pittsburgh. Pennsylvania
D«t« September 30. 1994
Pollution Prevention
A«**»om*m Worksheets
ProJ. No. 01645-0111-00003
Prepared By Vitas
Checked By J. Smith
Sheet 11 of 12 Page of.
WORKSHEET
8
I OPTION DESCRIPTION
Optton Nairn El«ctro«tatic tprav application _
Briefly deecrfce the option; Eoutoment oan«nrt«a • tarn* electrostatic ch«me which cause* tha paint to mat ail
jj
-------
Finn USAGE
stt» Pittsburgh. Pennsylvania
D«ta September 30.1994
Pollution Pr*v*ntton
Aaa*»am*nt Workah**ta
Pro}. No. 01645-0111-OQQOa
Pr*o*r*dBy Vrtas
Ch*ck»dBv J. Smith
8h*«t12of 12 P*9«_
WORKSHEET
8
OPTION DESCRIPTION
Option Nam* Cantrafaad purchasing
Briafly dMcrfee the option: Raquiro that ai tlM wthin tha Ptobumh DtXrict ourohaM material through
PgyVARS. Stora U m«t»naJ« «t PEWARS. ai-
W*BU
Aftaet*d: Numtw 10
kipJt UnUriaX*) Afftcted: All raw mat^iait
Producft(«) Afftetod: Variout
ndlc*U. Typ«: D Sourc* Reduction
Equlpm»nt-R«lat»d Chang*
K P*r»onn«VProc«dur*-R«lal*d Chang*
x Hat*rial*-R*lat*d Chang*
O R*cyding/R*u«*
Onaft* Material r*u**d for original purpoa*
___ Offstt* Itetarial ua*d for a (ow*r
------- |