United States Environmental Protection Agency Research and Development Risk Reduction Engineering Laboratory Cincinnati, OH 45268 EPA/600/S2-91/030 Sep. 1991 «rEPA Project Summary Waste Minimization Opportunity Assessment: Naval Undersea Warfare Engineering Station Keyport, Washington The Environmental Protection Agency (EPA) has developed a systematic ap- proach to Identify, select and imple- ment options to reduce or eliminate hazardous waste. The approach Is pre- sented in a report entitled, "Waste Mini- mization Opportunity Assessment Manual" (EPA/625/7-88/003). To encour- age use of this manual, EPA is con- ducting a series of assessment projects. This report describes the ap- plication of the waste minimization as- sessment procedures to a torpedo maintenance facility at the Naval Un- dersea Warfare Engineering Station in Keyport, WA (NUWES Keyport). This facility volunteered to participate in the project and provided technical support during the study. This Project Summary was developed by EPA's Risk Reduction Engineering Laboratory, Cincinnati, OH, to announce key findings of the research project that Is fully documented In a separate report of the same title (see Project Report ordering Information at back). Introduction The purpose of this project was to dem- onstrate the application of EPA's Waste Minimization Opportunity Assessment Manual to a federal facility. This manual provides a systematic, planned procedure lor identifying ways to reduce or eliminate waste. This project was conducted in coopera- tion with the Naval Energy and Environ- mental Support Activity (NEESA) of Port Hueneme, California and the Environmen- tal Division of the NUWES Keyport Civil Engineering Department. NUWES Keyport is located within the central Puget Sound area of northwestern Washington State. The functions of the Station include various undersea warfare weapons and systems engineering and development activities. The principal activities currently con- ducted at NUWES Keyport are the design and testing of torpedoes, including tor- pedo handling as well as other ordinance handling and related activities. Specific activities on the Station generate a variety of potentially hazardous wastes, including waste fuel, oil, hydraulic fluid, and grease; various metal and plating bath liquid wastes; waste paint and thinner; Freon™*, alcohol, mineral spirits, and other solvent wastes; waste resin; acid and caustic wastes; chromate and cyanide salts; pes- ticide rinsate; wastewater treatment sludge; waste dye; waste detergent; and other miscellaneous solid wastes A major component of waste manage- ment at NUWES Keyport involves a tor- pedo propellant, known as Otto Fuel II (Otto Fuel*). Otto Fuel is largely com- posed of propylene glycol dinitrate, with lesser amounts of 2-nitrodiphenylamine and di-n-butylsebacate. Otto Fuel is a monopropellant, meaning that it burns with- out oxygen. The Navy currently treats Otto Fuel-contaminated waste as an explosive, reactive waste. Procedure Waste minimization (WM) is a policy specifically mandated by the U.S. Con- * Mention of trade names or commercial products does not constitute endorsement or recommendation for use. /~X^y ^AA) Printed on Recycled Paper ------- gress in the 1984 Hazardous and Solid Waste Amendments to the Resource Con- servation and Recovery Act (RCRA). The WM assessment procedure used during this project is an acceptable approach for meeting one part of the WM required by the law for hazardous waste generators. The WM assessment procedure is a systematic framework that can be used by a facility's own employees to identify WM opportunities. As a structured pro- gram, it provides intermediate milestones and a step-by-step procedure to (1) un- derstand the facility's processes and wastes, (2) identify options for reducing waste, and (3) determine if the options are technically and economically feasible to justify implementation. These procedures consist of four major steps: 1) Planning and Organization - or- ganization and goal setting; 2) Assess- ment - careful review of a facility's opera- tions and wastestreams and the identifi- cation and screening of potential options to minimize waste; 3) Feasibility Analysis - evaluation of the technical and economic feasibility of the options selected and sub- sequent ranking of options; and 4) Imple- mentation - procurement, installation, implementation, and evaluation. The WM opportunity assessment manual contains a set of 19 worksheets which are de- signed to facilitate the WM assessment procedure. The project completed the first three steps of the procedures for two torpedo maintenance processes at NUWES Keyport. The fourth step, implementation, is at the discretion of the host facility. NEESA personnel are conducting WM as- sessments for all other industrial units at the Station. Building 514, the Mark 48 torpedo shop; and Building 489, the Mark 46 torpedo shop, were selected for evaluation. The Mark 48 shop handles about 20 to 22 torpedoes per month. These are disas- sembled into large sections and sent to appropriate depots on base, where they are disassembled to components, updated, cleaned, repainted, parts replaced, and sections reassembled. The hydraulic fluid and fuel tanks are drained and refilled in Building 514. The fuel tanks and other major sections from depots on base are then reassembled in Building 514. Wastes generated in Building 514 during these processes include cyanide-containing liq- uid wastes and sludges (formed as a byproduct of combustion of Otto Fuel; con- taminated solvents and oils (generated during cleaning of parts); wastewaters; solids (primarily clothing and rags); used oil; and hydraulic fluid. The major activities in the Mark 46 Shop consist of defueling, disassembling, clean- ing, reassembling, and refueling Mark 26 torpedoes. About 2800 unproofed torpe- does and 500 proofed torpedoes were processed through the Mark 46 Shop dur- ing 1989. Proofed torpedoes are first rinsed to remove salt water. The remaining fuel in proofed torpedoes is emptied into a 1500- gal, epoxy-lined, concrete sump located outside Building 489. Other Otto Fuel-con- taminated wastewaters (e.g., mop wa- ter) also are placed in the sump. Diethylene glycol (DEG) is used to clean the fuel tanks after draining, each fuel tank is rinsed twice, and the second rinse is reused as the first rinse for the next tank. About 9 pounds of DEG is used per rinse. Torpedo parts are cleaned in six dip tanks containing a mixture of mineral spir- its and lanolin called Agitene. Plans are underway to replace three of the six Agitene dip tanks with an automated parts washer unit. The proposed washer is ex- pected to reduce the quantity of Otto Fuel- contaminated solid waste. Results and Discussion The technical feasibility evaluation ini- tially determines the nature for the WM option - whether it is equipment-related, personnel/procedure-related, or materials- related. For each of the three types of WM options, specific information and data are required. For equipment-related op- tions, the information requirements relate to the state of the technology, availability of equipment, performance specifications, testing, space and utilities, production ef- fects, and training. For personnel/proce- dure-related options, the required infor- mation relates to training and operating instructions changes. Materials-related options require information on production impacts, storage and handling, training and testing. The WM options evaluated during this project were equipment-related and personnel procedure-related. The technical and economic results of the feasibility analysis phase are summa- rized in Table 1. This table indicates the total capital investment, the net operating cost savings, and the payback period (to- tal capital investment/net operating cost savings) for each option. Five options were identified that were considered to be po- tentially applicable to the Station. Option 1. Volume Reduction of Otto Fuel-Contaminated Clothing Option 1 involves the increased segre- gation of discarded clothing to minimize the volume of Otto Fuel-contaminated solid wastes to be disposed. By removing con- taminated portions of protective clothing such as sleeves and leg cuffs, only those portions of clothing that are truly contami- nated will require disposal as a hazardous waste. This option requires a minimal capi- tal outlay; however, the magnitude of po- tential waste reduction is difficult to quan- tify. Option 2. Automated Cleaning of Parts Some automated cleaning of parts and fuel tanks planned at Keyport will result in more efficient and faster cleaning, smaller amounts of hazardous waste liquids, and smaller amounts of contaminated cloth- ing. Future plans at the Mark 46 Shop include replacement of three of the six Agitene dip tanks with automatic parts washers using biodegradable cleaning liq- uids. This automation will involve a clean- ing media of water/detergent in an agita- tor or washer system or an ultrasonic cleaner. More extensive (or complete) au- tomation of cleaning operations within the two shops will aid in reducing waste Agitene, waste mineral spirits, and con- taminated cbthing. Initial capital cost for automatic equipment will have a relatively short payback period because of de- creased costs for labor and hazardous waste disposal, and reduction in the pur- chase of cleaning solvents. The decreased demand on manpower should result in staff available in other areas at NUWES Keyport where WM may require additional human resources. Option 3. Automated Fuel Tank Draining At the time of this survey, automated torpedo fuel tank disassembly by robotics had been used at the Mark 46 Shop for about 4 years; the result has been more efficient and faster operations, smaller amounts of waste liquids, and smaller ------- amounts of contaminated clothing. Be- cause fueling and defueling are handled in one self-contained closed unit, there is no need for frequent cleaning or decon- tamination and there is less incidence of spills. Future plans at the Mark 46 Shop include a robot that will rinse the fuel tanks and eliminate the need for the 9 pounds of DEG per tank. A similar fueling/defueling system could be installed in the Mark 48 Shop. This form of automatic equipment will have a short payback period because of de- creased costs of labor and reduced con- taminated clothing disposal and spill cleanup. Staff made available can be uti- lized in other areas at the Station where waste minimization may require additional human resources. Option 4. Modify the Deep Sink Draining Schedule Deep sinks, used for parts cleaning in both buildings, are currently drained on a weekly basis. The deep sinks in the Mark 48 Shop usually contain mineral spirits and oils; those in the Mark 46 shop con- tain Agrtene. These sinks are emptied from a standpipe on the outside of each build- ing; the weekly schedule is maintained whether or not the cleaning liquids require changing. A more efficient use of the liquid clean- ing agents involves a revised schedule for draining the sinks. The personnel in the cleaning room can determine when the cleaning agents are actually spent so that draining would be conducted on an as- needed basis. Because one week is cur- rently the minimum time for solvent re- plenishment, the minimum interval on an as-needed basis will be no shorter than 1 week, and probably up to twice this pe- riod. Incorporation of this option will re- duce costs because less solvent would be purchased, less hazardous waste disposed of, and fewer man-hours expended. Option 5. Recycling of Mineral Spirits Mineral spirits (used to clean parts) is currently handled as a RCRA hazardous waste, combined with other liquid wastestreams, and sent to an offsite treat- ment storage disposal facility (TSDF) for incineration. Option 5 proposes recycling of the mineral spirits used in the Mark 48 Shop (Building 514) to recover the spent mineral spirits. This operation would be conducted on a batch basis. Because the unit has a cycle time of approximately 9 hours, batch operation could begin late in the week and continue during weekend hours, corresponding to the reduced de- mand for mineral spirits in the shop during that time. The proposed process involves heating the mineral spirits to destroy the Otto Fuel present. Hydrogen cyanide in the vent gases would be passed through a carbon absorption unit and the remaining liquid redistilled. The entire unit can be con- structed to eliminate any potential explo- sion hazard from the equipment. Conclusions and Recommendations The results of the study indicate that the fastest paybacks would be from Op- tion 4 and Option 1. Option 4 involves a very simple process of modifying the schedule for deep sink draining at both Buildings 514 and 489. Under this option, the shops would notify Civil Engineering when the sinks required draining (i.e. the cleaners are spent) rather than having the sinks being drained on a weekly basis. No capital outlay is needed for this option. Option 1, the reduction of Otto Fuel- contaminated clothing, also requires a minimal capital outlay. The cost analysis was conducted assuming that a 20% re- duction in solid Otto Fuel-contaminated wastes could be realized with this method; however, this estimate maybe significantly high or low. Although Option 2 requires a capital outlay for the purchase of a parts cleaning unit that uses biodegradable detergents, it would allows NUWES Keyport to mini- mize the amount of cleaning solutions dis- posed of and greatly reduce the amount of raw materials that must be purchased. The payback period for this option is esti- mated to be only 0.4 year. Option 5, the recycling of mineral spir- its, also has a short payback period. Again, it involves a moderate to high capital out- lay, but the savings realized both in the decrease in disposal cost for contaminated mineral spirits and in the purchase of min- eral spirits make this an appealing option. The payback period for Option 3, the automated rinsing of parts, could not be determined because the capital equipment costs could not be verified. The full report was submitted in fulfill- ment of Contract No. 68-C8-0061, WA 2- 05 by Science Applications International Corporation under the sponsorship of the U.S Environmental Protection Agency. &U.S. GOVERNMENT PRINTING OFFICE: 1991 • MH-02V/40072 ------- This Project Summary was prepared by the staff of Science Applications International Corporation, Bothell, WA 98011 and Olympia, WA 98501. James. S. Bridges is the EPA Project Officer (see below). The complete report, entitled "Waste Minimization Opportunity Assessment: Naval Undersea Warfare Engineering Station, Key port, Washington," (Order No. PB91- 216457/AS; Cost: $23.00, subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Risk Reduction Engineering Laboratory U.S. Environmental Protection Agency Cincinnati, OH 45268 United States Environmental Protection Agency Center for Environmental Research Information Cincinnati, OH 45268 BULK RATE POSTAGE & FEES PAID EPA PERMIT No. G-35 Official Business Penalty for Private Use $300 EPA/600/S2-91/030 ------- |