United States
                    Environmental Protection
                    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).

                     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
                     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.

  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
         ^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
  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
  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-

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
  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
  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
  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
  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
Center for Environmental
Research Information
Cincinnati, OH 45268
   PERMIT No. G-35
Official Business
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