INVESTIGATION OF WASTE RAG GENERATION
AT NAVAL STATION MAYPORT
by
Southern Research Institute
Birmingham, AL 35255
and
Pacific Environmental Services, Inc.
Mason, OH 45040
EPA Contract No. 68-D2-0062
Work Assignment 1/32, Task 2
PROJECT OFFICER
N. Theresa Hoagland
Sustainable Technology Division
National Risk Management Research Laboratory
Cincinnati, OH 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 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 Technologies Division hi Cincinnati.
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DISCLAIMER
11
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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
ItXNTtr **,-«, 11, ..*.—--.!.„ ,..CC*_ —A t 1*1. < . * . _ *
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 regulatoW 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 EP|'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
m
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ABSTRACT
This report presents the results of ari investigation examining pollution prevention
alternatives for reducing the volume of waste rags generated at Naval Station Mayport, located
near Jacksonville Beach, Florida. Hazardous and non-hazardous waste rags are generated as a
result of maintenance and repair operations
and onboard ships which frequent the Naval
hat take place at various shore-based Commands
Station.
Five specific pollution prevention alternatives that should be considered for
implementation by the Naval Station to redube or prevent the generation of waste rags:
1.
2.
3.
4.
5.
Better operating practices;
Installation of equipment cleaning stations to remove contaminants normally
removed with rags;
Replacement of SERV MART rigs with disposable wipers;
Use of recyclable rags for oil and grease removal; and
Confirmation that used'rags are jfully contaminated prior to disposal.
Implementation of these alternatives is anticipated to significantly reduce the volume of
waste rags generated by the Naval Station. Alternatives 1 and 5 require no additional capital
investment, but generate a reduction in waste. Alternatives 3 and 4 were estimated to generate
a net cost savings to the Station, if implemented, in addition to reducing waste. Use of
disposable wipers is somewhat more attractive from a cost perspective than recycling of non-
hazardous waste rags, however. Alternative 2 is only recommended for high volume rag use
areas. Each alternative is a proven technology that has already been implemented by at least
one Command at the Naval Station.
This report was submitted in fulfillnu nt of Contract Number 68-D2-00062 by Southern
Research Corporation and Pacific Environmental Services, Inc. under the sponsorship of the
U.S. Environmental Protection Agency. Thfe report covers a period from 7/27/94 to 9/30/94-
work was completed as of 9/30/94.
IV
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TABLE OF CONTENTS
DISCLAIMER . . .
FOREWORD
ABSTRACT
LIST OF TABLES
1.0
2.0
3.0
4.0
5.0
6.0
EXECUTIVE SUMMARY
INTRODUCTION
WASTE RAG GENERATION,
. 11
iii
iv
vi
DANDLING, AND DISPOSAL
3.1 TYPES OF RAGS USED
3.2 WASTE RAG GENERATfON
3.3 WASTE RAG HANDLING AND DISPOSAL
3.4 REFERENCES FOR CHAPTER 3 .
A!LI
POLLUTION PREVENTION ALTERNATIVES
4.1 IMPLEMENT BETTER OPERATING PRACTICES
4.2 REDUCE WASTE THAT REQUIRES WIPING
4.3 REDUCE WASTE RAG DISPOSAL VOLUMES . . .
4.4 REFERENCES FOR CHAPTER 4
COSTS AND BENEFITS OF POLLUTION PREVENTION
ALTERNATIVES
5.1 BASE CASE VALUES ANT) ASSUMPTIONS
5.2 ALTERNATE CASE VALUES AND ASSUMPTIONS
5.3 SUMMARY OF BASE CA,SE AND ALTERNATIVES
5.4- REFERENCES FOR CHAPTER 5
. 1-1
. 2-1
. 3-1
. 3-1
. 3-6
3-10
3-12
. 4-1
. 4-1
. 4-2
. 4-3
. 4-6
RECOMMENDED POLLUTION PREVENTION ALTERNATIVES
6.1 IMPLEMENT BETTER OPERATING PRACTICES
6.2 REDUCE GENERATION JDF RAG CONTAMINANTS
6.3 REDUCE WASTE THAT REQUIRES WIPING
6.4 SUMMARY
. 5-1
. 5-1
. 5-1
. 5-8
5-10
. 6-1
. 6-1
. 6-1
. 6-2
. 6-2
v
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TABLE 1.1:
TABLE 3.1:
TABLE 5.1:
TABLE 5.2:
TABLE 5.3
TABLE 5.4
TABLE 5.5
TABLE 6.1:
LIST
OF TABLES
Page
SUMMARY OF POLLUTION PREVENTION ALTERNATIVES
FOR WASTE RAG GENERATION 1-3
1993 SUMMARY OF HAZARDOUS AND NON-HAZARDOUS
RAG USAGE AT NAVAL STATION MAYPORT ....
3-3
BASE CASE VALUES FOR BOTH HAZARDOUS AND NON-
HAZARDOUS WASTE RAG USAGE . 5.2
INSTALL WASH STATION FOR HELICOPTER SQUADRON
PARTS CLEANING ..
USE OF DISPOSABLE WIPERS FOR HAZARDOUS AND NON-
HAZARDOUS WASTES
USE OF RECYCLABLE RAGS FOR NON-HAZARDOUS
WASTES
SUMMARY OF BASE CASE AND ALTERNATIVES
ON WASTE RAG GENERATION, CAPITAL COSTS
AND ANNUAL COSTS
5-4
5-6
5-7
5-9
SUMMARY OF POLLUTION PREVENTION ALTERNATIVES
FOR WASTE RAG GENERATION 6_3
VI
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1.0 EXECUTIVE SUMMARY
This report presents the results of an
investigation examining pollution prevention
alternatives for reducing the volume of waste rags generated at Naval Station Mayport, located
near Jacksonville Beach, Florida. HazardouL and non-hazardous waste rags are generated as a
result of maintenance and repair operations tiat take place at various shore-based Commands
and onboard ships which frequent the Naval Station.
The report recommends five specific pollution prevention alternatives that should be
considered for implementation by the Naval Station to reduce or prevent the generation of
waste rags:
1. Better operating practices;
2. Installation of equipment cleaning stations to remove contaminants normally
removed with rags;
3. Replacement of SERV MART ra >s with disposable wipers;
4. Use of recyclable rags for oil anc grease removal; and
5. Confirmation that used rags are fully contaminated prior to disposal.
Implementation of these alternatives is anticipated to significantly reduce the volume of
waste rags generated by the Naval Station. Alternatives 1 and 5 require no additional capital
investment, but generate a reduction in waste. Alternatives 3 and 4 were estimated to generate
a net cost savings to the Station, if implement jd, in addition to reducing waste. Use of
disposable wipers is somewhat more attractive from a cost perspective than recycling of non-
hazardous waste rags, however. Alternative 2 is only recommended for high volume rag use
areas. Note that each alternative is a proven technology that has already been implemented by
at least one Command at the Naval Station.
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potential to reduce pollution as well as the
The five alternatives identified are recommended for implementation because of their
cost savings that they generate. Table 1.1 presents
the pollution prevention alternatives identified and the type of rag that is best suited for
implementation.
1-2
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TABLE 1.1: SUMMARY OF POLLUTION PREVENTION ALTERNATIVES FOR
WASTE RAG GENERATION
Alternative Identified
Recommended Rag
Type
Notes
Implement Better Operating
Practices
Use Disposable Wipers
Use Recyclable Rags
Dispose of Only Fully
Contaminated Rags
Install Equipment Cleaning
Stations
Both Hazardous and
Non-Hazardous
Hazardous
^on-Hazardous only
^on-Hazardous only
^on-Hazardous only
Could also be used for
Non-Hazardous
Not recommended for
hazardous rags
Limit to high volume
rag use areas
1-3
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2.0 INTRODUCTION
Since 1988, the Waste Reduction Evjluations at Federal Sites (WREAFS) Program has
identified and promoted pollution prevention opportunities at Federal facilities, including the
Department of Defense (DoD) facilities in each of the three services and the U.S. Coast Guard
Service. Twenty-six on-site pollution prevention opportunity assessments (PPOA) have been
conducted by the Risk Reduction Engineering Laboratory (RREL) and DoD through
WREAFS, generating over 130 pollution prevention technical options. This project is the
latest of a series of pollution prevention studies conducted under WREAFS.
The purposes of this project were to:
wastes generated by the Public Works Centei
(1) develop a PPOA for non-aqueous liquid
- Transportation (PWC-T) at Naval Station
Mayport and (2) investigate base-wide rag usage at the Naval Station to determine how and
r
where waste rags are generated. The non-aqueous liquid wastes studied were used motor oil,
hydraulic fluid, transmission fluid, antifreeze
the PWC-T. This report presents the results
, and waste solvent from the washing of parts at
of the investigation of base-wide rag. generation.
The results of the PPOA for non-aqueous liquid wastes generated by the PWC-T are included
in a companion report entitled "Pollution Pre
(Transportation) Waste Fluids at Naval Statioh Mayport.
mention Alternatives for Public Works Center
As noted above, this report presents the results of the investigation of base-wide rag
generation. Including the executive summary
report contains six chapters. Chapter 3 descr
(Chapter 1) and the introduction (Chapter 2), the
bes the different types of waste rags and how
they are generated, handled, and disposed. Chapter 4 presents pollution prevention
alternatives that could be utilized to reduce th; generation of both hazardous and non-
hazardous waste rags at the Naval Station. The chapter also discusses the benefits and
alternative. Chapter 5 discusses the costs and
2-1
problems created by implementation of each
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benefits of the alternatives presented for waste rags. Finally, Chapter 6 summarizes the
pollution prevention alternatives considered and recommends selected alternatives for
implementation.
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3.0 WASTE RAG GENERATION, HANDLING, AND DISPOSAL
The mission of Naval Station Mayport is to provide support services for U.S. Navy
ships and helicopters that operate from the Mayport, Florida Naval facility. A significant
portion of the Naval Station's mission is to
provide maintenance services for the airborne and
sea-going vessels stationed at or visiting Mz.yport as well as hundreds of pieces of equipment
that support the aircraft and ships. Support
equipment includes automobile and truck fleets,
road and light construction equipment, airciaft ground support equipment, and marine support
equipment.
As a result of the maintenance activities that are required for the equipment described
above, a large volume of hazardous and non-hazardous waste rags are generated. This chapter
discusses the types of rags used by the various work centers and Commands at Mayport and
provides a summary of the volume of waste
rags generated in 1993. The chapter concludes
with a discussion of how waste rags are handled and disposed.
3.1 Types of Rags Used
There are three types of rags that are currently in use at the Naval Station. The most
prevalent type of rags used are those that are purchased through SERV MART, the supply
organization for the Base. Rags are purchased hi either 25 pound or 50 pound bales (National
Stock #7920-00-205-1711). A 25 pound ba
inspection of several bales found the rags cc nsist primarily of discarded synthetic clothing
(e.g., polyester pants, cotton/polyester shirts, etc.) cut into pieces, of varying dimension and
thickness. The general consensus from on-
site Commands was negative concerning the
absorptivity of oil and grease by these wiping rags.
e costs $22.08 and contains about 150 rags. An
3-1
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The second type of wipe rags used a
paper and special synthetic fiber disposable
the Naval Station are commercially manufactured
wipers. These are specifically manufactured to
absorb oil and grease. Disposable wipers are available in several sizes and are manufactured
to satisfy general and special purpose requirements. For example, lint-free rags are purchased
specifically for maintenance activities associated with hydraulic systems, which are very
sensitive to contamination.
The third type of rags used at the NaVal Station are recyclable rags. These are cotton
rags designed specifically for oil and grease
wiping and cleanup. They are commercially
washed in industrial strength detergents to remove oil and grease, then reused repeatedly.
Currently, two commercial vendors are under contract to provide several Commands (e.g.,
Ship Intermediate Maintenance Activity (SIMA) and PWC-T) at the Naval Station with
recycled rags. Recyclable rags are collected
from each activity by the contractor, cleaned, and
returned for reuse. Only worn out reusable rags are disposed in landfills. Vendors estimate
that a rag can be recycled up to 200 times before it must be replaced. The rags are provided
through a commercial launderer at $0.18 per rag. The vendor charges $0.23 for replacing a
rag that is lost from the inventory. Recyclable rags missing from the inventory are suspected
to have been incorrectly used with a hazardous material and were discarded as hazardous
waste.
Table 3.1 reflects the estimated number of pounds of both hazardous and non-
hazardous waste rags generated by each Command or activity during calendar year 1993. The
data were taken from two sources. First, daia on the generation of hazardous waste rags was
taken from the 1993 Mayport Hazardous Waste Report1. Secondly, non-hazardous rag data
was taken from the refuse incinerator records for 19932.
The records classify rag amounts in pounds, bags, and drums. To enable reporting in
pounds, two conversion factors were assumed . A "bag" of rags was assumed to weigh 10
pounds, while a "drum" of rags was assumed to have a weight of 70 pounds. These
assumptions were based on discussions with shop personnel throughout the Naval Station.
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TABLE 3.1: 1993 SUMMARY OF
RAG USAGE AT NAJVAL
HAZARDOUS AND NON-HAZARDOUS
STATION MAYPORT
Command3
AIMD
CBU 420
FTC
Harbor Operations
HSL-40d
HSL-486
SIM A
USS Aubrey Fitch
USS Boone
USS Dale
USS Doyle
USS Gettysburg
USS Hue City
USS John Hancock
USS Mclnerney
USS Monterey
USS Montgomery
USS Phillipine Sea
USS Saratoga
USS Spruance
USS Stark
USS Underwood
Hazardov
(pound
a
2
4
1
•
i
2
•
11
1
L993
s Rag Wasteb
s per year)
,542
0
219
471
,116
,576
,107
519
0
107
0
>21
20
212
96
0
0
29
,749
0
0
74
1993
Non-Hazardous Rag
Waste0
(pounds per year)
3,152
70
80
920
4,360
5,793
4,076
675
1,670
0
40
100
190
1,670
470
565
655
200
4,743
990
370
203
Total
(pounds
per year)
5,694
70
299
1,391
6,476
10,369
5,183
1,194
1,670
207
40
321
310
3,882
666
565
655
329
16,492
990
370
377
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TABLE 3.1: 1993 SUMMARY OF HAZARDOUS AND NON-HAZARDOUS
RAG USAGE AT NAVAL STATION MAYPORT
Command2
USSVicksburg
USS Yosemite
Visiting Ships
Unknown Sources
Totals
Hazardo
(pounc
1993
is Rag Waste"
Is per year)
0
1,366
3,794
1)1,032
4
2,750
1993
Non-Hazardous Rag
Waste0
(pounds per year)
120
5,420
2,708
4,450
43,690
Total
(pounds
per year)
120
6,786
6,502
15,482
86,440
AIMD = Aircraft Intermediate Maintenance Depot; CBU 420 = Construction
Building 420; FTC = Fleet Training Center; HSL = Helicopter AntiSub Light
Squadrons; SIM A = Ship Intermediate Maintenance Activity
1993 Mayport Hazardous Waste Report
1993 Mayport refuse incinerator records
Includes HSL-42 waste rag usag'e
Includes HSL-44 and HSL-46 waste rag usage
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Table 3.1 also summarizes the total volume
1993.
Inspection of Table 3.1 revealed se'
generation in 1993. Eighty-five percent oflthe
from three sources: 1) Ships visiting or based
Squadron (HSL) activities (19 percent); am
of waste rags generated by each Command during
'eral key Commands that contributed to waste rag
total waste rags generated at Mayport came
at the Naval Station (48 percent); 2) Helicopter
3) "Unknown Sources" (18 percent).
The USS Saratoga dominated the volume of waste rags generated by ships with a total
of 16,492 pounds. This represents 40 percL of the volume attributable to ships. The
helicopter squadrons generated a total of 16,845 pounds. Note that although the helicopter
squadrons generated 19 percent of waste rags on the Base, the majority of them were non-
hazardous rags. The waste rags generated from "Unknown Sources" were dominated by
hazardous rags. In addition, there are seven ships home-ported at Mayport that have no
hazardous rags listed under the ship's name These ships may represent a large portion of the
"Unknown Sources" as a result of personnel using a general hazardous waste activity
nomenclature instead of a specific ship name to record the hazardous waste.
The assessment team also queried Ba ;e personnel to obtain rough estimates of 1994
waste rag generation based on current work levels at each particular work center. Based on
their estimates, SIMA may already have achieved an 85 percent reduction in waste rag
disposal due to recycling. SIMA has recently begun using approximately 1,500 commercially
provided recyclable rags per week to clean non-hazardous waste from equipment. Their
estimate of waste rag generation for 1994 is about 800 pounds versus the 5,183 pounds
generated in 1993. SEvIA's use of this contacted service may account for such a major
reduction. Similarly, the CBU-420 has demo'
generation through recycling. The estimated
the 70 pounds that required disposal in 1993.
nstrated an 87 percent reduction in waste rag
1994 waste rag generation is 540 pounds versus
The 470 pound difference is a result of CBU-
420 washing and recycling their 1993 non-hazardous rags at the automobile hobby shop.
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engine repair). The waste rags are classified
3.2 Waste Rag Generation
Rags are typically used for the most simple of cleanup operations. A common use is to
remove oil, grease, and hazardous cleaning solvents from equipment during maintenance
operations. Rags are also used to wipe and clean up after painting operations. Occasionally
rags are used to clean up small spills that occur around activities within a work center (e.g.,
as being either "hazardous" or "non-hazardous".
Hazardous waste rags are those that have come in contact with a hazardous substance as
defined in Mayport's Hazardous Waste Management Plan:
"Hazardous Substance (HS) - A material included in the specific list of chemicals
designated by the EPA in 40 CFR 302 which, because of its quantity, concentration, or
physical, chemical, or infectious characteristics, may pose a substantial threat to human
health to the environment when dischirged to the environment. Reportable quantities
are listed in 40 CFR 302.3"
Some examples of hazardous materials induce, but are not limited to, PD-680, acids, paint
strippers, paints, and emulsifiers. Non-hazardous wastes are anything that is not a hazardous
waste; typical examples are lubrication oils, greases, and synthetic oils.
Each Command at Naval Station May port has one or more work centers that generate
waste rags. The activities that generate the v
aste rag and the types of contaminants vary by
Command. The following is a brief discussion of the types of operations that generate waste
rags and the contaminants deposited on the ra'gs, listed by Command. In every case, waste
rags are generated as specific parts, or the work areas themselves, are wiped or cleaned:
3-2.1 Aircraft Intermediate Maintenance Depot (AIMD1
AIMD provides preventative and intei
aediate maintenance for the aircraft that operate
at the Naval Station. Intermediate maintenance is defined as maintenance activities that are
more complicated than preventative maintenance operations (e.g., simple fluid replacements)
but not as involved as a complete overhaul of equipment. Some examples include bearing
replacement, electric motor winding replacement, and electronic circuit board repair. The
work centers located within AIMD are: 1) Ar Frames Repair; 2) Support Equipment Repair;
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and 3) Aircraft Engine Repair. Activities
discussed below:
that generate waste rags within each work center are
aircraft parts. The testing is done to
Air Frame?? Repair. This work cente r performs repair and non-destructive testing of
inspect aircraft structural members for defects due
to corrosion. The aircraft parts are sent to AIMD for testing and repair from the
helicopter squadrons. Contaminants deposited on the rags include machine shop oils,
greases, PD-680 (a mineral spirits-based cleanup solvent), emulsifiers, acids,
penetrants, oils, and paint strippers.
Support Equipment Repair. This work center maintains and repairs hi excess of 700
pieces of ground support equipment used by the helicopter squadrons. The equipment
includes, but is not limited to, items such as hydraulic fluid purifiers, air compressors,
:i
generators, and blowers. The squadrons turn in the equipment to this work center to
receive maintenance. Contaminants deposited on the rags include hydraulic fluid,
diesel fuel, grease, synthetic oils, and
PD-680.
Aircraft Engine Repair. This work ce nter repairs the gas turbine engines used by the
helicopter squadrons. Contaminants c eposited on the rags include lubrication oil,
synthetic oil, high temperature grease
sealants, and paint stripper.
3.2.2 Construction Battalion 420 rCBTJ-42m
CBU-420's current mission is to support a field hospital. Rags are generated by the
equipment repair and maintenance work center, which services battalion support equipment.
This equipment includes, but hi not limited to, concrete mixers, vehicles, small portable
generators, and pumps. Contaminants deposited on the rags generated by this work center
include lubrication oil, hydraulic fluid, and grease.
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3.2.3 Fleet Training Center
The FTC provides training to assist military personnel in learning the maintenance
f
procedures that are used by the different Commands and work centers at the Naval Station.
Rags are generated in the FTC labs as a resu
t of hands-on lab training for personnel.
Contaminants deposited on the rags generated by FTC include lubrication oil, diesel fuel,
hydraulic fluid, and greases.
3.2.4 Harbor
Harbor operations provide light preventive maintenance support to the tug boats,
barges, and marine service craft that are used at the Naval Station. Major repairs are not
performed by Harbor Operations personnel. Contaminants deposited on the rags generated by
Harbor Operations include lubrication oils, hydraulic fluid, grease, paint, and paint solvents.
3-2-5 Helicopter AntiSuh Light Squadrons (HSL-40r 4?. 44. 46. and 48)
routine and preventative maintenance service;
Five helicopter squadrons operate at Is aval Station Mayport. Each squadron provides
for each helicopter hi their squadron. The
activities range from mechanical and engine work to electronic equipment repair.
Contaminants deposited on the waste rags generated include lubrication oil, hydraulic fluid,
grease, and solvents.
3-2.6 Ship Intermediate Maintenance ^Tiyjtv (SIMAI
SIMA provides intermediate maintenance and repair services for ship equipment such
as electronics equipment, electric motors, boilers, and ship weapons. SIMA provides these
services for all ships stationed or visiting the Naval Station. Contaminants deposited on the
rags include oil, grease, anti-seize fluid, machine cutting oil, solvents, paint, and paint thinner.
3.2.7 Ships
Ships make up the single largest source of waste rags generated at the Naval Station.
Although the assessment team was unable to investigate rag generation onboard ships (other
3-8
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than to calculate total pounds used), the operations performed on ships are very similar to
those performed in the different shore-based
Commands listed above. Therefore, the types of
rags used, waste rag generation methods, ar d handling and disposal steps are assumed to be
very similar to those discussed above.
Two additional areas discussed below generate waste rags, but were not included in
Table 3.1. They are not listed in the Table because each currently recycles rags either through
a commercial launderer or by washing on site.
3.2.8 Public Works Center - Transportation fPWC-T>
The PWC-T provides maintenance service for the equipment used to support both
shore-based operations and th,e ships that frequent the Naval Station. The PWC-T provides
maintenance for almost 700 pieces of equipment including light and heavy duty trucks,
automobiles, buses, bulldozers, road graders, cranes, fork lifts, power generators, overhead
hoists, and other heavy equipment. Activities that generate waste liquids involve the periodic
replacement of motor oil, hydraulic fluid, transmission fluid, and antifreeze, and the cleaning
of parts removed from the vehicle for repair
Each of the fluids used at PWC-T is a potential
contaminant that may deposited on waste rags. PWC-T utilizes a commercial launderer to
supply clean rags for use on their equipmentj.
3.2.9 Morale. Welfare, and Recreation (MWR) Automobile Hobby Shop
The automobile hobby shop provides
a location for Base personnel to repair and
maintain personal automobiles and recreational equipment. Operations within the hobby shop
are identical to those in PWC-T, except that
the types of vehicles are limited to automobiles
and similar light-duty vehicles. Contaminants deposited on the rags generated by the hobby
shop include lubrication oil, hydraulic fluid, transmission fluid, antifreeze, PD-680, and
grease. The hobby shop has a washer and dryer on location that are currently used to clean
and recycle non-hazardous rags.
3-9
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3.3 Waste Rag Handling and Disposal
As noted earlier, waste rags generated by the various ships and other Commands
located at Naval Station Mayport are either classified as hazardous or non-hazardous in nature.
Each category of waste rag is handled and djisposed by separate methods. The following is a
discussion of waste rag handling and disposal, by category.
3.3.1 Hazardous Waste Rags
Rags contaminated with cleaning solvents, paint thinners, and paint are treated as
hazardous waste. These waste rags are cleatly labeled hazardous for disposal purposes. The
rags are placed in double plastic bags and temporarily stored (30 days maximum) in 55 gallon
steel drums. The drum tops are secured with clamping rings and are clearly marked as
hazardous waste. Drum storage is maintained hi each activity's hazardous waste material
storage area. After removing the waste rag!;, an empty barrel is returned to the site to receive
additional waste rags. In addition to the waste rags, data from the 1993 Mayport Hazardous
Waste Report indicated that paint rollers and paint brushes were included in the bags
containing waste paint rags approximately 16 percent of the time.
Hazardous waste rags generated from the helicopter squadrons are handled and
reported differently than at other Commands. HSL-40 is responsible for the temporary
hazardous waste storage facility, which contkins hazardous waste rags generated from
HSL-40 and HSL-42. USLAO and HSL-42
are located in the same building. HSL-48
provides this same service for HSL-44 and HSL-46, since these three squadrons are also
located in the same building. As a result of
this waste rag collection arrangement, all waste
rags from the helicopter squadrons are reported as originating from either HSL-40 or HSL-48.
3.3.2 Non-Hazardous Waste Rags
Non-hazardous rags contaminated with
and greases are handled as non-hazardous waste
petroleum-based motor oils, hydraulic fluids,
. The waste rags are clearly labeled non-
3-10
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hazardous and are disposed in a landfill. Rags containing oil and grease are excluded from the
definition of hazardous waste under 40 CFJR §261.4.
Previously, non-hazardous rags we-e collected and destroyed at the Naval Station's
refuse incinerator located on the Base. Ori May 31, 1994, the refuse incinerator was shutdown
permanently. The current policy is to coll ;ct non-hazardous rags at each work center at the
end of each shift. As with the hazardous waste rags, the non-hazardous rags are placed hi
double plastic bags and temporarily stored
drum tops are secured with clamping rings
(30 days maximum) in 55 gallon steel drums. The
and are clearly marked non-hazardous. Although
these waste rags are non-hazardous, drum storage is maintained in each activity's hazardous
waste material storage area because of convenience. After removing the waste rags, an empty
barrel is returned to the site to receive additional waste rags.
and
The Public Works Department is
storage areas and disposal of both the haza;
rags. Disposal costs for both hazardous
Mayport personnel to be $1.85 per pound4.
visited were hi full compliance with the NaVal
rags and hazardous waste rags.
responsible for collection from the hazardous waste
dous paint and solvent rags and non-hazardous
non-hazardous waste rags were estimated by
The assessment team found that all Commands
Station's policy for handling of non-hazardous
3-11
-------
3-4 References for Chapter
1.
2.
3.
4.
Station Mayport Environmental
"1993 Mayport Hazardous Waste Report". Provided by Naval Station Mayport
Mayport, Florida. '
Naval Station Mayport refuse incinerator records for 1993 provided by the Naval
Engineering Department.
Naval Station Mavoort Hazardous Waste Managemenf Plan Department of the
Navy. SOPA (ADMIN) Mayport Instruction 5090. IB. Naval Station Mayport
Mayport, Florida. April 1994
Telecon between Paul Grable oi
Santarone at Naval Station Mayport. Estimated rag disposal costs. September
1994.
Pacific Environmental Services, Inc. and Mr. Jim
3-12
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4.0 POLLUTION PREVENTION ALTERNATIVES
This chapter presents pollution prevention alternatives that could be utilized to reduce
the generation of both hazardous and non-hkzardous waste rags at Naval Station Mayport. The
chapter discusses the benefits and problems
created by implementation of each alternative.
During the visit to the Naval Station, the assessment team observed evidence of a
concerted effort by staff to reduce wastes al the facility. Several ongoing practices support a
pollution prevention ethic and reduced generation of waste rags. For example, AIMD and
SIMA use wash stations to clean equipment thoroughly prior to being disassembled. This
process removes large volumes of grease, op, and dirt that would normally be wiped with rags
during the repair process.
Additional opportunities were identified by the assessment team to make further
progress in waste reduction. These alternatives can be classified into three general categories:
1) better operating practices that reduce the amount of contamination generated; 2) methods to
reduce the volume of waste that requires rag1 wiping; and 3) methods to reduce the volume of
rags to be disposed. Each alternative is discussed in detail below.
4.1 Implement Better Operating Practices
The first step towards reducing the amount of waste rags generated at Mayport is to
reduce the amount of contamination generated that will require cleanup with rags. Reduction
in the generation of these contaminates can be most effectively accomplished through better
operating procedures. Many operations at Mayport can benefit from implementation of better
operating practices. Several of these practices are listed below:
4-1
-------
Personnel Practices
Utilize good housekeeping methods such as maintaining a clean and
orderly work area to minimize waste rag generation
Provide employee training related to steps to prevent waste rag
generation
Provide employee incentives to promote waste rag pollution prevention
through training and recognition programs
Procedural Measures
Improve maintenance procedures to avoid waste generation that must be
cleaned with rags
Re-evaluate maintenance periodicity to extend the time between
maintenance requirements
Review equipment repair history to replace units requiring high
maintenance
Use proper handling and application equipment to minimize cleanup
Although these practices are already Li place in many work centers, implementation of
these practices at all work centers should be c onsidered to reduce pollution and waste rag
generation at the Naval Station. Some specific examples include replacing worn seals on
pumps, replacing old or high maintenance equipment, and using drip pans under mobile
equipment. For more information related to improved operating practices, refer to the EPA
publication Guides to Pollution Prevention: The Marine Maintenance and Repair Industry
(October 1991)1. In addition, the Guide includes blank waste rriinirnization assessment
worksheets, which can be used to assess minimzation alternatives for all pollution sources. It
also includes the results of assessments performed on three different marine maintenance and
repair yards.
4.2 Reduce Waste That Requires Wiping
The second pollution prevention categ
try involves reducing the volume of waste that
requires wiping with rags, but not the amount of contaminants generated at the source. The
alternative identified is the installation of wash stations for equipment awaiting repair. As
4-2
-------
stated earlier, this procedure is currently being used at both AIMD and SIMA. By installing
wash stations at other Commands, the equipment to be repaired could be steam cleaned or
washed prior to initiation of the repair operation. Washing the equipment removes the
contaminants so that rags are not needed for this function. The contaminants removed,
however, would still be released in wastewater streams generated by the wash stations.
Requiring pre-cleaning before the equipment enters a shop for repair is estimated to result in a
50 percent or greater reduction in the use or rags.
This procedure must obviously be limited to equipment that can withstand vigorous
cleaning, such as engines and heavy equipment. Implementation of this procedure on items
such as electronic circuit boards is unrealistic. In addition, wash stations would, as noted
above, generate wastewater streams containing grease and oil that the Base sewage treatment
plant would be required to process.
4.3 Reduce Waste Rag Disposal Volumes
The final pollution prevention category is reduction hi the volume of rags that are
disposed. Three pollution prevention alternatives were identified that would result hi a
reduction hi waste rag generation: 1) replace' SERV MART rags with disposable wipers;
2) use recyclable rags for oil and grease removal; and 3) confirm that used rags are fully
contaminated prior to disposal. Each of the
alternatives is discussed hi detail below.
4.3.1 Use Disposable Wiper?
The relatively non-absorbent bale rags purchased at SERV MART for both hazardous
and non-hazardous waste cleanup could be replaced with commercially available disposable
wipers. SERV MART rags come hi random sizes, are difficult to tear or cut, and are typically
very poor absorbents of liquids. All personnel interviewed by the assessment team felt that the
SERV MART rags were inferior. Base pers jnnel also stated they would prefer a more
absorbent and manageable rag substitute.
4-3
-------
liquids, greases, oils, and common solvent
Disposable wipers, such as paper toWels, are specifically manufactured to absorb
Disposable wipers are marketed in different sizes
for different purposes, from economy to heavy-duty. Heavy-duty wipers have pulp and textile
fibers for strength and absorbency, reportedly tough enough for metal chips, rust, and
machined surfaces. Using uniform, absorb ;nt disposable wipers with an area of approximately
one square foot would increase the ratio of contaminate per unit volume of rag waste, reducing
waste rag generation. As with the SERV MART rags currently used for hazardous waste, the
used disposable wipers must be disposed as
hazardous waste.
4.3.2 Use Recyclable Rqgs
The use of recyclable rags for non-hazardous wastes could lead to a significant
reduction in waste rags generated and disposed from the removal of oils and greases.
Recyclable rags are made of cotton fibers fdr absorbency and man-made fibers for strength.
Washing with industrial detergents can remove petroleum products from recyclable rags, re-
establishing the high absorbency. Recycle rags can be reused until mechanical abrasion
during repeated use, and chemical effects from strong detergents, breaks down rag fibers. Rag
remnants are then landfilled. Each time a Kg is recycled, landfill requirements are reduced.
Rags could be recycled using either i commercial service or individual work centers
that clean and recycle their own rags. A commercial service is currently being used by SIMA,
while the automobile hobby shop cleans and
the simplest operation since they provide the
recycles their own rags. A commercial service is
clean rag for use and pickup used rags to be
cleaned. This completely removes the burden of purchasing and cleaning the rag. Although
the commercial operation also removes the burden of wastewater disposal from the Command,
the rag washing operation does generate a lie uid waste stream that requires processing.
Individual washing and recycling of rags is most attractive at small work centers that
generate few waste rags. Collection, cleaning, and redistribution of these rags is simple
because of the low volume and minimum am )unt of effort required. The major disadvantage
4-4
-------
is that wastewater generated by the cleaning operation must be processed through the Base
sewage treatment plant.
4-3-3 Dispose of Only Fullv Contaminated Rags
The assessment team inspected dirty
rags that were in containers at several Commands.
They found that a majority of rags had a significant amount of serviceability remaining. In
many cases, the rags were only lightly soiled and could be used again. The lightly soiled rags
could be the result of the very poor absorbe icy of the SERV MART rags, the ready
accessibility of clean rags, or rigid adherence to current rag disposal policies by Base
personnel. |
till servk
Periodic inspection to segregate still Serviceable rags from heavily contaminated rags
could reduce rag volume. This would require minor additional effort by personnel in each
work area to inventory the rags once a week! before they are sent to disposal. Lightly
contaminated rags could be separated and rejised until duty. In addition, limiting the
availability of rags would help ensure that rags are fully used before disposal. Because of
potential health hazards, this procedure is net practical for hazardous waste rags.
4-5
-------
4-4 References for Chapfgr 4
' r..^y.v>, Prevention: Tie Marine Maintenance and Repair Industry United
States Environmental Protection Agency. EPA/625/7-91/015. Office of Research and
Development. Washington, DC. October 1991.
. Industrial and Commercial F.qiijrment and Snpplfo 1QQ4
W.W. Grainger, Inc. Lincolnshire, Illinois. 1994.
4-6
-------
5.0 COSTS AND BENEFITS OF POI
LUTION PREVENTION ALTERNATIVES
This chapter provides a review of costs and benefits for selected pollution prevention
alternatives identified in Chapter 4. Costs ard savings quoted in this chapter are valid for
screening purposes only. The base case valufes for both hazardous and non-hazardous rag
usage are presented first. Base case values reflect the assumptions associated with current
operations. Next, each alternate case is presented. Alternate case values reflect the
assumptions associated with the related pollution prevention alternative. Note that the costs
used for each analysis are commercial costs and do not include any discounts that the Navy
may be able to negotiate with a particular vendor.
5-l Base Case Values and Assumptions
Table 5.1 presents the base cases used
for comparison with the pollution prevention
alternatives identified in Chapter 4.0. The cost associated with current practices for the
purchase and disposal of hazardous waste rags is presented first. Annual usage of rags is
based on the 1993 rag disposal inventory figures. SERV MART rag cost and rag disposal
costs were obtained from Base personnel. The analysis assumes that the same number of rags
will be used in future years.
The non-hazardous waste rag base ca* is also presented in Table 5.1. Annual usage of
rags is based on the volume of rags sent to thJ refuse incinerator in 1993. As with the
hazardous waste rag base case, SERVMART|rag cost and rag disposal costs were obtained
from Base personnel. The analysis assumes tl at the same number of rags will be used in
future years.
5-2 Alternate Case Values and Assumptfons
Other than the better operating practici
that were identified in Chapter 4, four
pollution prevention alternatives were identified that would result in a reduction in waste
5-1
-------
TABLE 5.1: BASE CASE VALUES FOR BOTH HAZARDOUS AND
NON-HAZARDO
US WASTE RAG USAGE
HAZARDOUS WASTE RAGS
Annual
Quantity
(Ibs)
42,750
Rags
per
Ib
6
Total
Rags
Used
256,500
Cost per
rag"
$0.1472
Annual
Purchase
Cost
$37,757
Disposal
Cost per
lbc
$1.85
Annual
Disposal
Cost
$79,088
Total
Annual
Costs
$116,844
National Stock #7920-00-205-1711.
SERV MART price
Mayport Environmental Engineering
From 1993 Hazardous Waste Report.
Assumptions: Ha7ardnus Waste Rags
1) Purchase 42,750 pounds
2) Assume 6 rags per pound
of rags'3 annually for hazardous waste cleanup
NON-HAZARDOUS WASTE RAGS
Annual
Quantity
(Ibs)
43,690
Rags
per
Ib
6
Total
Rags
Used
262,140
Cost per :
rag"
$0.1472
Annual
*urchase
Cost
$38,587
Disposal
Cost per
lbc
$1.85
Annual
Disposal
Cost
$80,827
Total
Annual
Costs
$119,414
a National Stock #7920-00-205-1
b SERV MART price
1711, From 1993 refuse incinerator records.
Mayport Environmental Engineering
Assumptions: Non-Hazardous Waste Rags
1) Purchase 43,690 pounds of rags'
2) Assume 6 rags per pound
annually for non-hazardous waste cleanup
5-2
-------
with rags; 2) use disposable wipers for both
use recyclable rags for oil and grease removal; and 4) confirm that used rags are fully
contaminated prior to disposal. The alterna
rag generation: 1) install equipment wash stations to remove contaminants normally removed
hazardous and non-hazardous waste removal; 3)
ives, which are discussed in detail below, are
compared to the appropriate base case presented above. Note that where rag substitutes are
evaluated, the alternate case assumes that the same number of rags are used as in either base
case.
5.2.1 Install Equipment Cleaning Stations
The installation of a pressurized hot water cleaning station represents the first pollution
prevention alternative analyzed. Equipment
the station will have less contaminants that v
containing non-hazardous wastes that is cleaned at
rould need to be cleaned with rags. Since SMA
and AIMD already use wash stations and the assessment team did not investigate ship-based
rag generation, the only Commands that migiht benefit from installation of a wash station are
the helicopter squadrons.
Table 5.2 presents the results of the alternate case analysis for helicopter squadrons.
The analysis assumes that the Base continues to purchase SERV MART rags for non-
hazardous wastes for all Commands except the helicopter squadrons. In addition to the wash
stations currently operating at AIMD and SIMA, one wash station is installed and used by the
five squadrons to clean aircraft parts prior to repair. The new wash station is assumed to
reduce the 10,153 pounds of non-hazardous rags used by the squadrons by 50 percent. Capital
and operating costs for the new wash station kvere obtained from an outside vendor. Unit rag
purchase and disposal costs are identical to those in the non-hazardous base case.
Based on the analysis, installation of •<. wash station for the helicopter squadrons is
slightly more attractive than existing operations. A savings of $5,585 was generated by the
reduction in rag usage. Based on the assumptions and analysis presented in Table 5.2,
5-3
-------
TABLE 5.2: INSTALL WASH STATION
PARTS
FOR HELICOPTER SQUADRON
CLEANING
Wash Station
Capital
Costs3
$21,000
Operating
Costs3
$2,300
Capital
Recovery
Costs'"
$3,419
To
Anr
Co
tal
ual
sts
$5,'
119
*
Base-wide
Annual Non-
Hazardous
Rag Usage
(lbs)c
38,614
Base-wide
Annual
Rag Usage
Cost"1
$105,540
Annual
Alternative
Case Cost
$111,259
Telecon with Consolidated Equipment Company, Raleigh, NC. Capital costs
(installed): concrete work platfotm = $8,000; oil/water separator = $6,000;
sewer connection = $3,000; and 3 hp electric hot water pressure washer =
$4,000. Annual operating costs:
pressure washer maintenance = $500; and
detergents = $1,800
Assumes useful life of 10 years 2nd an interest rate of 10 percent, which yields a
capital cost recovery factor of 0.1628 ($21,000 x 0.1628 = $3,419)
Assumes rag usage for non-hazaijdous wastes at helicopter squadrons only is
reduced by 50 percent (from 10,153 Ibs to 5,076 Ibs), dropping the total base-wide
non-hazardous rag usage to 38,614 pounds (from 43,690 Ibs)
(38,614 / 43,690) x $119,414 (from Table 5.1) = $105,540
Assumptions
1) Purchase 43,690 pounds of rags annually for base-wide non-hazardous waste
cleanup (from Table 3.1) I
2) Sewer connection is close to proposed cleaning station
3) One pressure cleaning station needed
4) Existing waste water treatment plant is capable of processing additional effluent
5) No hazardous materials will be involved at the pressure wash stations
5-4
-------
the wash station would need to reduce non-hazardous waste rage usage by 21 percent for the
wash station to "breakeven." Although this alternative is an improvement over current
operations, the other alternatives identified in Chapter 4, and evaluated below, generate
much higher savings and are thus much more attractive.
5.2.2 Use Disposable Wipers
This alternative involves replacing the SERV MART rags currently purchased by the
Base for both hazardous and non-hazardous waste cleanup with disposable wipers. Table
5.3 presents the results and assumptions for each alternate case. For both hazardous and
non-hazardous wastes, the analysis founc
that a significant economic incentive exists to
replace the SERV MART rags with disposable wipers. Replacement of the SERV MART
rags with disposable wipers could result in a savings of at least $82,000 per year for
hazardous waste rags and an additional $84,000 per year for non-hazardous waste rags.
The amount (Ibs) of waste rags generated is estimated to be reduced significantly, from a
total (hazardous plus non-hazardous) of approximately 86,400 Ibs per year to less than
16,000 Ibs per year.
The savings and reduction in the amount of waste rags generated are driven by the
much larger number of disposable wipers per pound that can be purchased versus the 6 rags
per pound currently received with the SERV MART rags. The analysis assumes that one
disposable wiper is equivalent in absorptivity to one SERV MART rag. Based on the very
poor absorptivity of the SERV MART rajjs noted by the assessment team, this assumption
appears to be valid. Even if three disposable wipers were assumed to be equivalent to the
absorbency of one SERV MART rag, the analysis would still show disposable wipers to be
preferred over the SERV MART rags.
5.2.3 Use Recyclable Rags
This alternative involves replacing the SERV MART rags used for non-hazardous
waste cleanup with recyclable rags. The alternative assumes that a commercial operation is
contracted to provide and launder the dirty rags. Table 5.4 presents the results and
5-5
-------
TABLE 5.3: USE OF DISPOSABLE WIPERS FOR HAZARDOUS AND
NON-HAZARDOUS WASTES
HAZARDOUS WASTE RAGS
Supplier*
Economizer
Scott Wypall
Plus
ScottCloth
Heavy Duty
Total
Wipers
Purchased
256,500
256,500
256,500
Wipers
per lba
53
39
33
Total Cost per
Weight wiper*
dbsj
4,84(
6,57
7,75;
) $0.0458
' $0.0601
I $0.0768
Annual
Purchase
Cost
$11,747
$15,416
$19,699
Disposal
Cost per
lb"
$1.85
$1.85
$1.85
Annual
Disposal
Cost
*" i in •! ii
$8,953
$12,167
$14,380
Total
Annual
Costs
—
$20,701
$27,583
$34,079
b Mayport Environmental Engineering estimate
Assumptions: Hazardous Waste Rags
1) One disposable wiper has th< same absorbency as one SERV MART rag
2) Purchase 256,500 disposable wipers annually for hazardous waste cleanup
NON-HAZARDOUS WASTE RAGS
Supplier*
Economizer
Scott Wypall
Plus
ScottCloth
Heavy Duty
Total
Wipers
Purchased
262,140
262,140
262,140
Wipers
perlb*
53
39
33
Total Cost
Weight per
Obs)| wiper1
4,946 $0.0458
6,72:
7,9*
: $0.0601
$0.0768
Annual
Purchase
Cost
$12,006
$15,755
$20,132
Disposal
Cost per
lbb
$1.85
$1.85
$1.85
Annual
Disposal
Cost |
$9,150
$12,435
$14,696
Total
Annual
Costs
$21,156
$28,189
$34,828
b Mayport Environmental Engineering estimate
Assumptions: Non-Hazardous Waste
1) One disposable wiper has the
same absorbency as one SERV MART rag
-, .^^^^v.^1^ T.i^wi m»o HAW acuutr auouiucilty as UiiC OEJt\.V JVl/vK.1 Tag
2) Purchase 262,140 disposable wipers annually for non-hazardous waste cleanup
5-6
-------
TABLE 5.4 USE OF RECYCLABLE RAGS FOR NON-HAZARDOUS WASTES
Number
of Rags
Used Per
Year3
262,140
Number of
Replacement
Rags Purchased
Per Year"
2,621
Annual Costs
Recycle
Costs0
$47,185.20
Replacement
Rag Costsd
$602.83
Disposal
Costs0
$808.14
1
Total Annual
Costs
$48,596
Use 262,140 rags annually for non-hazardous waste cleanup (from Table 5 1)
Based on a rag reduction ratio of 100. Telecon with Consolidated Equipment
Company, Raleigh, NC
Recycle unit cost of $0.18 per rag (from SIMA unit rag recycling costs) times
the total number of rags needed
Replacement rag unit cost of b.23 per rag (from SIMA unit rag recycling
costs) times the number of replacement rags purchased per year
Disposal cost of $1.85 per Ib (from Mayport Environmental Engineering
£*GfrlTT! O^£k 1 n*%>! n fi f++******* ±1 __ i.1 A ._ _ ««« _ _ _
estimate) and assumption that
rags (i.e., 6 rags per Ib)
recyclable rags weigh the same as SERV MART
5-7
-------
assumptions associated with the alternate case. The rag purchase and laundering costs used
reflect the costs that SIMA currently paJs for its recycling operation. The analysis also
assumes that the same volume of rags will be used in future years.
Based on the results of the analysis, rag recycling is less than half the cost the Naval
Station currently spends to purchase and
dispose of the SERV MART rags. In addition, if
all Commands were to participate in a recycling program, the launder and purchase costs of
the recyclable rags could probably be negotiated lower because of the magnitude of rags
used at Mayport. Note that although recycling does create a liquid waste stream, it
eliminates the cost of disposal and the ne;d to landfill these non-hazardous rags.
An additional part of the recyclab
e rag analysis looked at reducing recyclable costs.
The concept was to provide a civilian contractor a distribution center on Base to recycle the
more than 5,000 rags per week generated by the Base in 1993. The contractor would be
responsible for receiving, washing, and distributing recyclable rags. It became evident
early in the analysis that a quantity of api roximately 5,000 recyclable rags per week can not
be competitive with the price the contract :>r for SIMA charges.
5-3 Summary of Base Case and
Table 5.5 presents a summary of tie base case and alternatives in terms of 1) the
amount (Ibs) of waste rags generated, 2) t ic capital costs, if any, associated with
implementing the alternatives, and 3) the annual costs associated with the base case and each
alternative. As seen in Table 5.5, the Staiion is estimated to spend approximately $236,000
per year on waste rags. Under the three alternatives examined, expenditures are estimated
to range from approximately $42,000 to $^28,000 per year. Potential savings, therefore,
are estimated to be as low as $8,000 per Jear to as high as $192,000 per year. Reduction in
the amount (Ibs) of waste rags generated rknge from approximately 6 percent (wash station,
non-hazardous waste) to 89 percent (disposable wipes, hazardous and non-hazardous waste).
5-8
-------
TABLE 5.5 SUMMARY OF BASE CASE AND ALTERNATIVES ON WASTE RAG
GENERATION, CAPITAL COSTS, AND ANNUAL COSTS
NA = not applicable
Type of Rag
Hazardous
Non-Hazardous
*
Total (Hazardous
plus non-
hazardous)
Scenario
Base Case
Wash Station
Disposable Wipers
Recyclable Rags
Base Case
Wash Station
Disposable Wipers
Recyclable Rags
Base Case
Wash Station
Disposable Wipers
Recyclable Rags
A
,
t
9
mount of Waste
lags Generated
(Ibs/yr)
42,750
NA
K840 to 7,753
NA
43,690
38,614
,946 to 7,944
79
86,440
81,364
786 to 15,697
42,829
Capital Costs
NA
NA
NA •
NA
NA
$21,000
NA
NA
NA
$21,000
NA
NA
• _
Total Annual Costs
$116,844
NA
$20,701 to $34,079
NA
$119,414
$111,259
$21, 156 to $34,828
$48,596
$236,258
$228,103
$4 1,857 to $68,907
$165,440
5-9
-------
5.4 References for Chapter 5
1. Telecon between Paul Grable of Pacific Environmental Services, Inc. and Mr. Hemdon
at Consolidated Equipment Compakiy in Raleigh, North Carolina. Estimated equipment
and operating costs for non-hazardous rag cleaning operation. August 1994.
2.
Industrial and Commercial Equipment and Supplies 1994 General Catalog fjo
2£5_- W.W. Grainger, Inc. Lincolnshire, Illinois. 1994.
5-10
-------
6.0 RECOMMENDED POuJuTION PREVENTION ALTERNATIVES
This chapter summarizes the recommended pollution prevention alternatives for the
reduction of waste rags at Nava, Station Maypor, Chapter 6 a,so indudes recommendations
T01* imi"\J ja»-v-»ja *-!*«»•. rt, j.i_ _ f* •
for implementing the preferred pollution
prevention alternative.
6.1
Reducing the amount of contaminalion that is generated and eventually cleaned or wiped
rags „ the firs, step towards poUution prevention. Reduction in the generation of mis
waste shou,d be accompHshed through undenting the better operating practices detaned in
Chapter 4. taplementation of these practices can be accompHshed by increasing training and
reflnmg procedura, steps. These changes can be imptement* with minor increases in costs but
can have significant pollution prevention impacts.
6.2
Installation of an equipment wash
volume of waste that must be wiped wi
station for the helicopter squadrons to reduce the
h rags has an economic advantage over current
i „ . ~ww««uuw auvtuiiage over current
operations, bu, other alternatives are much more attractive. In addition, wash stations are
already iocated a, AIMD and SIMA, the two areas mat cou.d most utuize the benefits of mis
aitemative. If further investigation of L helicopter squadrons indices mat a larger
percentage of rags could be eliminated thrU installation of a wash station, mis atenative
m combination with recyclable rags or disposable wipers, might be more aKractive In any
case, the installation of wash stations should be limited to areas where a high volume of waste
rags are generated and equipment can be easily cleaned with steam or water
6-1
-------
6.3 Reduce Waste That Requires Wiping
Reducing the volume of waste rags generated can be best accomplished by replacing the
SERV MART rags currently used by iriany Commands throughout the Base with either
disposable wipers or recyclable rags. PES recommends that Mayport purchase disposable
wipers for cleanup of hazardous wastes tliroughout the Naval Station. This will result in a
significant savings in rag purchase and lisposal costs. For non-hazardous wastes, PES
recommends that the Base negotiate a contract with a commercial launderer to provide
recyclable rags for all Commands on the Bz se. Although recycling of the non-hazardous rags
is somewhat higher than the costs to use and dispose of disposable wipers, the Navy should be
able to negotiate better laundering prices if other Commands agree to consider recycling. Even
without more attractive laundering prices, recycling of rags is only slightly more expensive than
purchasing disposable wipers but could prevent the introduction of over 43,000 pounds of waste
rags each year to area landfills.
Periodic inspection to segregate serviceable rags from heavily contaminated rags is
recommended as an excellent way to reduce rag volume and rag disposal expense. This would
require minor additional effort by personnel hi each work area to inventory the rags once a
week before they are sent to disposal. Lightly contaminated rags could be separated and
reused until dirty. Because of potential he ilth hazards, this alternative is only recommended
for non-hazardous waste rags.
6.4 Summary
Table 6.1 presents each of the pollution prevention
as well as those that are recommended
implementation were based on the potential
economic advantages and cost savings
technology that has already been implemented
If these recommendations are fully implemented throughout
rags should be significantly reduced.
alternatives identified in this report
for implementation. The recommendations for
of the alternative to reduce pollution as well as the
In addition, each alternative is a proven
by at least one Command at the Naval Station.
Naval Station, generation of waste
generated
6-2
-------
TABLE 6.1: SUMMARY OF POLLUTION PREVENTION ALTERNATIVES FOR
WASTE RAG GENERATION
Alternative Identified
Recommended Rag
Type
Notes
Implement Better Operating
Practices
Use Disposable Wipers
Use Recyclable Rags
Dispose of Only Fully
Contaminated Rags
Install Equipment Cleaning
Stations
Both Hazardous and
Non-Hazardous
Hazardous
Could also be used for
Non-Hazardous
Non-Hazardous only
Non-Hazardous only
Non-Hazardous only
Not recommended for
hazardous rags
Limit to high volume
rag use areas
6-3
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