United States
Environmental Protection
Agency
Risk Reduction
Engineering Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/SR-94/156 September 1994
^ EPA Project Summary
Pollution Prevention Opportunity
Assessment, U.S. Coast Guard
Aviation Training Center, Mobile
Alabama
Bill Burch and Al Memon
An assessment of pollution preven-
tion opportunities at the U.S. Coast
Guard Aviation Training Center in Mo-
bile, AL, identified waste reduction op-
portunities in five major processing
areas: flight simulator operation, air-
craft maintenance, aircraft fueling, air-
craft washing, and general operations.
The assessment team observed evi-
dence of a concerted effort to reduce
wastes at the facility. This publication
summarizes additional opportunities for
waste reduction.
This Project Summary was developed
by EPA's Risk Reduction Engineering
Laboratory, Cincinnati, OH, to announce
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
A pollution prevention (P2) opportunity
assessment of the U.S. Coast Guard
(USCG) Aviation Training Center (ATC) in
Mobile was conducted under the purview
of the Risk Reduction Engineering
Laboratory's Waste Reduction Evaluations
at Federal Sites Program. The program
supports P2 research through joint as-
sessments at selected federal sites. The
study was conducted using the EPA
manual Facility Pollution Prevention Guide
(EPA/600/R-92/088), which outlines a pro-
cess for collecting and analyzing informa-
tion using detailed worksheets to
characterize waste streams and waste re-
duction alternatives.
The USCG ATC is located at Bates
Field adjacent to the Mobile, AL, Munici-
pal Airport. The training center was com-
missioned in 1966 to provide centralized
comprehensive training to Coast Guard
personnel in the operation of fixed-wing
and rotary-wing aircraft. The facility also
has fixed-wing search and rescue respon-
sibilities. Five hundred employees oper-
ate the facility on a 24-hr basis. Three
types of aircraft are maintained in opera-
tion: the Dauphin Helicopter (HH-65), the
Jayhawk Helicopter (HH-60), and the Fal-
con Jet (HU-25). Duties include cleaning,
maintenance, and repair of structural, me-
chanical, and electrical components, and
rescue and survival gear. The aircraft are
also fueled onsite. Approximately 20 air-
craft are operated at this facility.
The assessment team observed evi-
dence of a concerted effort to reduce
wastes at the facility. Opportunities for
further progress in waste reduction were
identified in each major process area: flight
simulators, aircraft maintenance, aircraft
washing, aircraft fueling, and general op-
erations.
Flight Simulators
The ATC houses three flight simulators,
all of which use hydraulic equipment. Hy-
draulic fluid spills account for the major
portion of the waste generated from the
simulators. Recovered hydraulic fluid is
sold to a recycling facility for $0.03/gal
while spent hydraulic fluid filters and spill
absorbents are disposed of as hazardous
wastes. A recommended option was to
perform preventive maintenance on hy-
draulic pumps and pipe joints, thus reduc-
ing the leaks and subsequent cleanups.
Additionally, a wringer can be used to
-------
recover the fluid from the absorbents, and
the absorbent material can be reused with
an average of 75% absorption capacity.
Overall, these options have economic
advantages: a reduction in waste disposal
costs and a savings in the purchase of
raw materials.
Aircraft Maintenance
Several activities in the aircraft mainte-
nance area account for pollution gener-
ated at the ATC. As an example, the three
airframe shops and the engine shop each
have their own material lockers. Many of
the materials used in the shops are alike
or similar. A P2 option is to combine the
four lockers and establish a centralized
control point for management of mainte-
nance materials. Management responsi-
bilities would include tracking the material
shelf life extensions. This option would
reduce material usage and losses at little
or no increase in personnel costs.
Alternative cleaning agents were identi-
fied to replace the numerous cleaning
materials containing organic solvents which
are collected and disposed of as hazard-
ous waste, or which evaporate. As an
example, instead of toluene to clean rub-
ber surfaces, alternatives such as acetone,
isopropyl alcohol, orterpene-based clean-
ers could be used.
Currently, preventive maintenance on
the airframe engines in the Dauphin Heli-
copter and Falcon Jet require replacing
the engine oil every 150 hr of operation
and gearbox oil every 450 hr of operation.
For the Jayhawk Helicopter, however, re-
placement is based on the condition of
the oil. A P2 option is to establish that
same practice for the Dauphin Helicopter
and Falcon Jet. A benefit would be the
extended life of the oil. A 10% increase in
oil life would reduce oil consumption by
an estimated 200 to 300 gal/yr at the
ATC. Implementation costs would include
periodic analyses to track the condition of
the oil.
Aircraft Fueling
Several easily implemented options
would significantly reduce pollution result-
ing from aircraft fueling. These include the
following: using spill absorbents to recover
spilled fuel; squeezing the absorbent to
recover additional fuel, and reusing the
absorbent; eliminating rainwater entry to
the bowser where waste is stored; and
segregating bowser wastes for later re-
covery. Bowser waste can be sold at
$0.03/gal, but since $0.50/gal of water is
deducted from the price, it is economically
beneficial to eliminate the water. All that is
needed to implement this option is to en-
sure that the inlet and funnel are not left
unattended during waste transfer to the
bowser.
Most spills from fuel transfer activities
are the result of unsupervised or unat-
tended transfer, especially at the fuel farm.
In addition, failure of automatic shut-off
valves results in overflow spills. Installa-
tion, careful inspection, and periodic test-
ing of overfill protection systems in all fuel
transfer facilities and equipment will sig-
nificantly reduce this source of pollution.
Another option is to limit the amount of
fuel used to satisfy the requirement for
visual testing of fuels. One pint is the
minimum required, but often two or three
times that amount is used. Adherence to
the minimum requirement is all that is
needed to reduce pollution from waste
fuel by two to three times.
Aircraft Washing
Considering future environmental re-
quirements, a P2 option is to use alterna-
tive washing soaps. The ATC currently
uses Aircraft Soap Types 1, 2, 4 and 5,
which contain the following compounds:
Type 1 — Dipropylene Glycol Methyl
Ether, Hexylene Glycol,
Morpholine
Type 2 — Dipropylene Glycol Methyl
Ether
Type 4 — Mineral Spirits, 2-Butoxye-
thanol, Hexylene Glycol
Type 5 — Naphtha, 2-Butoxyethanol,
Hexylene Glycol
These compounds are currently within
the requirements of the rinsate discharge
permit, but they may be regulated in the
future. Nonhazardous alternatives used by
the Air Force, such as AVIAWASH 4000*
and Turboclean, should be investigated to
determine if they meet the aircraft wash-
ing needs of the ATC.
General Operations
Several alternatives were identified that
could communicate ways that P2 relates
to specific job requirements. These in-
clude the following: issuing a written P2
management policy, tailoring training ma-
terial specifically to USCG aviation activi-
ties, incorporating P2 practices into
operating procedures, measuring P2
progress, conducting staff briefings on the
progress made, and recognizing P2 ef-
forts and progress.
Conclusion
The assessment team observed evi-
dence of a concerted effort to reduce
wastes at the facility. Opportunities for
further progress in waste reduction were
identified in each major process area. The
P2 options identified for the ATC require
minimum effort and expense and could be
easily implemented.
The full report was submitted in fulfill-
ment of Contract 68-D2-0181, WA 1/011,
by the TRC Environmental Corporation,
under Subcontract No. 1-645-999-222-004
to Pacific Environmental Services, Inc.,
under the sponsorship of the U.S. Envi-
ronmental Protection Agency.
* Mention of trade names or commercial products does
not constitute endorsement or recommendation for
use.
-------
Bill Burch, and Al Memon are with Pacific Environmental Services, Inc. (under
Subcontract to TRC Environmental Corporation), Herndon, VA 22070.
James S. Bridges is the EPA Project Officer (see below).
The complete report, entitled "Pollution Prevention Opportunity Assessment,
U.S. Coast Guard Aviation Training Center, Mobile, Alabama," (Order No.
PB95-100020; Cost: $27.00, 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
Telephone: 513-569-7683
United States
Environmental Protection Agency
Center for Environmental Research Information
Cincinnati, OH 45268
Official Business
Penalty for Private Use
$300
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT No. G-35
EPA/600/SR-94/156
------- |