United States
                    Environmental Protection
                    Agency
National Risk Management
Research Laboratory
Cincinnati, OH 45268
                    Research and Development
EPA/600/SR-95/127    August 1995
&EPA         Project  Summary
                    Pollution  Prevention  Alternatives,
                    Naval  Station  Mayport,  Florida
                     The two  reports summarized here
                    present the results of an investigation
                    examining pollution prevention alterna-
                    tives at Naval Station Mayport, located
                    near Jacksonville Beach, FL. The waste
                    streams considered were: (1) non-aque-
                    ous liquid wastes generated by the Pub-
                    lic  Works  Center -  Transportation
                    (PWC-T) and  (2) hazardous and non-
                    hazardous waste rags generated base-
                    wide.
                     The first  report, "Pollution  Preven-
                    tion Alternatives for Public Works Cen-
                    ter  (Transportation)  Waste Fluids at
                    Naval Station Mayport" describes the
                    different non-aqueous liquids,  includ-
                    ing solvent  for parts cleaning; the pol-
                    lution prevention alternatives that could
                    be utilized to  reduce the generation of
                    non-aqueous liquid  wastes and the
                    technical and economic benefits and
                    problems created by implementation of
                    each alternative. The second report, "In-
                    vestigation  of Waste Rag Genera-
                    tion  at  Naval Station   Mayport"
                    recommends five specific pollution pre-
                    vention alternatives that should be con-
                    sidered for  implementation to  reduce
                    or prevent the generation of waste rags.
                     This Project Summary was developed
                    by EPA's National Risk Management
                    Research Laboratory, Cincinnati, OH,
                    to announce  key findings of the re-
                    search project that is fully documented
                    in two separate reports (see Project
                    Report ordering information at back).

                    Introduction
                     Since  1988,  EPA's Waste Reduction
                    Evaluations  at Federal  Sites (WREAFS)
Program has identified and promoted pol-
lution prevention opportunities at Federal
facilities, including the Department of De-
fense (DOD) facilities. The Naval Station
Mayport project was one of a series of
pollution prevention studies conducted un-
der WREAFS. The project was funded by
the DOD  Strategic Environmental  Re-
search and Development Program
(SERDP).
  The purposes of this project were  to:
(1) develop a Pollution Prevention Oppor-
tunity Assesment (PPOA)  for non-aque-
ous liquid wastes generated by the Public
Works Center -  Transportation (PWC-T)
at Naval Station Mayport; and (2) investi-
gate base-wide rag usage  at the Naval
Station to  reduce the volume and toxicity
of  waste rags generated. The results of
the PPOA for the non-aqueous liquid
wastes  are presented  in the report en-
titled "Pollution Prevention Alternatives for
Public Works Center (Transportation)
Waste Fluids at  Naval Station Mayport."
The results of the waste rag investigation
are reported  in a separate report, entitled
"Investigation of Waste Rag Generation at
Naval Station Mayport." The findings are
summarized  here.

Results  and Discussion
  The mission of Naval Station Mayport is
to provide  support services for U.S. Navy
ships and  helicopters that operate from
the Mayport, FL Naval facility. The station's
Public Works Division  currently services
671 different pieces of equipment to sup-
port approximately 12 ships. This is ex-
pected to increase significantly in the future
due to base consolidations. Support equip-

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ment includes automobile and truck fleets,
road and light construction equipment, air-
craft ground  support equipment, and ma-
rine support equipment.

Waste Fluids
  The  non-aqueous liquid wastes that are
generated at the PWC-T are primarily the
result of scheduled and unscheduled main-
tenance activities. These wastes  include
used motor oil,  hydraulic fluid,  transmis-
sion  fluid, antifreeze, and waste  solvent
from the washing of parts.
  While amounts  vary  according  to
workload,  purchase records indicate that
2,838 gal of motor oil, 564 gal of hydraulic
fluid, 206 gal of transmission fluid,  and
441  gal of antifreeze and approximately
2,640 gal of  PD-680 (a petroleum-based,
non-chlorinated solvent) were purchased
by PWC-T in 1993, indicating the approxi-
mate amount of waste  liquids generated
at the  PWC-T. Some small amount may
be lost due to spills.
  It is  recommended that an oil sampling
and  by-pass filtration pilot study be initi-
ated on two large pieces of equipment,
such as a  bulldozer and a road  grader.
The  pilot study is recommended to con-
firm that the number of motor oil changes,
and  hence motor oil usage,  can  be  re-
duced  significantly through  implementa-
tion  of an  oil  sampling program  and
installation  of by-pass  filtration units  on
each piece of equipment. The report also
recommends that  an  antifreeze recycling
unit be obtained by the PWC-T to evalu-
ate the merits of recycling the spent radia-
tor  fluid and reducing waste generation.
Finally,  the report recommends that an
automatic  parts washer be  obtained for
testing by the PWC-T to replace the four
parts washing  stations used to manually
clean parts with the PD-680 solvent.
  These alternatives  are  recommended
because of their potential to reduce pollu-
tion as well as the economic advantages
and  cost savings they generate. Table 1
presents each  of the pollution  prevention
alternatives identified for waste fluids.
  In the report, the base case and associ-
ated assumptions with current  operations
are compared  to  each pollution preven-
tion alternative. As an example, the report
presents the costs and benefits of each of
Table 1.  Summary of pollution prevention altern-
        atives for waste fluids at the naval sta-
        tion May port PWC-T
Source of
Waste Stream
  Alternatives
   Identified
Motor Oil
Hydraulic
Fluid

Transmission
Fluid

Antifreeze

Parts
Washing
  Oil Sampling
By-pass Filtration
 Synthetic Oils

By-pass Filtration
 Batch Recycling

By-pass Filtration
 Batch Recycling

   Recycling

 Automatic Parts
    Washer
the by-pass filtration systems identified for
motor oil for a bulldozer, which represents
one of the  largest motor oil capacities (48
qt)  of any piece of equipment serviced by
the PWC-T.  Table 2 presents the  alter-
nate case  assumptions  and  resultant
payback associated with installing by-pass
filtration  for the  bulldozer analysis. The
information is listed alphabetically by ven-
dor.

Waste Rags
  Approximately 86,440 Ib of non-recycled
hazardous and non-hazardous waste rags
are generated annually as a result of main-
tenance  and repair operations at various
shorecommands and on board ships which
frequent the Naval Station.  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 (base
    supply  store)  rags  with disposable
    wipers;
  4. Use of  recyclable rags  for oil  and
    grease removal; and
  5. Confirmation that used  rags are fully
    contaminated prior to disposal.

  Alternatives  1  and 5 require no  addi-
tional capital  investment,  but generate a
reduction in waste.  Alternatives 3  and 4
Table 2.  Motor Oil By-Pass Filtration Cost/Benefit Analysis: Bulldozer Alternate Case Assumptions


Annual Costs
Total Costs
Costs less
revenue)
Vendor

Enviro
Filtration
Fil-max
Gulf Coast
TF Purifiner
Filtration
Unit
Cosf
$226

463
675
845
Other
Coste*

$118.62

118.62
118.62
118.62
Sampling
+ New
Filters0
$116

69
22
56
Revenue^
(from
used oil)
$2.64

2.64
2.64
2.64
First
Year3

$457.98

647.98
812.98
1,016.98
Subsequent
Annual
Costs
$231.98

184.98
137.98
171.98
Payback
(yr)

1.0

1.7
2.1
2.9
a  Cost of by-pass filtration unit (including a by-pass filter) plus installation.
b  Includes costs for new oil (capacity of 48 qt, one oil change/yr, and new oil cost of$0.69/qt); filter disposal (2 by-pass and one full flow filter/yr at a cost of
   $0.50/filter); full flow filter (one new full flow filter/yr at a cost of$20/filter); downtime (for oil change, one oil change/yr, and a downtime cost of$50/hr); and
   Labor (1 hr of labor to change the oil, one oil change/yr, and a labor cost of$14/hr)
c  Includes vendor-specific costs for replacement filters and $14/yr for sampling oil based on 2 samples/yr at $7/sample.
d  Based on 48 qt of used oil/yr sold at $0.055/qt.
e  Includes filtration unit cost.

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were estimated to generate  a net cost
savings in addition to reducing waste. Use
of disposable wipers is  somewhat more
attractive  from  a  cost perspective than
recycling  of  non-hazardous  waste rags,
and  because of increased absorbency, the
ratio  of contaminate  per unit  volume  is
increased, thus  reducing overall genera-
tion  of rag waste.  Alternative 2 is  recom-
mended  only 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.
  The five alternatives identified are rec-
ommended for implementation because of
their potential to reduce  pollution as well
as the cost  savings that they generate.
Table 3 presents the  pollution prevention
                     alternatives identified and the type of rag
                     that is best suited for implementation.
                       Table 4 presents a summary of the base
                     case  and alternatives in terms of (1) the
                     amount (Ibs) of waste rags generated, (2)
                     the capital costs, if  any, associated with
                     implementing the alternatives, and (3) the
                     annual costs associated with the base case
                     and each alternative.

                     Conclusions
                       Several potential areas for pollution pre-
                     vention and waste reduction exist at Na-
                     val  Station Mayport.  In the case of waste
                     fluids (motor oil, hydraulic fluid,  transmis-
                     sion fluid,  antifreeze, and  parts washing
                     liquids),  several alternatives are offered,
                     but further investigation by  on-site per-
                     sonnel is needed to  determine  which al-
                                  ternative is most appropriate for the Naval
                                  Station. Rag generation could be curtailed
                                  by several methods including: improved
                                  operating  practices; installation of equip-
                                  ment  cleaning  stations to remove  con-
                                  taminants normally removed  with  rags;
                                  replacement  of  SERV MART  rags  with
                                  disposable wipers; use of recyclable  rags
                                  for oil and grease removal; and confirma-
                                  tion that used rags are fully contaminated
                                  prior to disposal.
                                    The full reports were submitted in fulfill-
                                  ment of Contract No. 68-D2-00062, Work
                                  Assignment No.  1-32 by  Southern  Re-
                                  search Institute and Pacific Environmental
                                  Services,  Inc. under the  sponsorship  of
                                  the U.S. Environmental Protection Agency.
Table 3. 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
Non-hazardous
only
Non-hazardous
only

Non-hazardous
only

Could also be use
for non-hazardous

Not recommended
for hazardous rags

Limit to high volume
rag use areas
Table 4.  Summary of Base Case and Alternatives on Waste Rag Generation, Capital Costs, and Annual Costs
Type of Rag
Hazardous

Scenario
Base Case
Wash Station
Disposable Wipers
Recyclable Rags
Amount of Waste
Generated (Ib/yr)
42,750
NA
4,840 to 7,753
NA
Capital Costs
NA
NA
NA
NA
Total Annual
Costs
$116,844
NA
20,701 to 34,079
NA
Non-Hazardous
Total (Hazardous
plus non-
hazardous)
                         Base Case
                         Base Case
  Wash Station
Disposable Wipers
 Recyclable Rags
                                                       43,690
                                  86,440
   81,364
9,786 to 15,697
   42,829
                                                                                      NA
                                                                                      NA
21,000
 NA
 NA
                                                                                      119,414
Wash Station
Disposable Wipers
Recyclable Rags
38,614
4,946 to 7,944
79
21,000
NA
NA
111,259
21,156 to 34,828
48,596
                                                       236,258
   228,103
41,857 to 68,907
   165,440

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 Southern Research Institute, Birmingham, AL 35205-5305, and Pacific Environ-
   mental Services, Inc., Research Triangle Park, NC 27709-2077 authored the
   reports.
 N. Theresa T. Hoagland is the EPA Project Officer (see below).
 The complete reports, entitled: "Pollution Prevention Alternatives for Public
     Works Center (Transportation) Waste Fluids at Naval Station Mayport, FL,"
     (Order No. PB95-260386; Cost: $19.50,  subject to change); and "Investi-
     gation of Waste Rag Generation at Naval Station Mayport," (Order No.
     PB95-260394; Cost: $17.50, 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:
        National Risk Management Research Laboratory
        U. S. Environmental Protection Agency
        Cincinnati, OH 45268
United States
Environmental Protection Agency
Technology Transfer and Support Division (CERI)
Cincinnati, OH 45268

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