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

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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.

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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

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