EPA
United States
Environmental Protection
Agency
Office of
Research and Development
Washington, DC 20460
EPA/625/7-91/015
October 1991
Guides to Pollution
Prevention
The Marine Maintenance
And Repair Industry
Printed on Recycled Paper
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EPA/625/7-91/015
October 1991
Guides to Pollution Prevention
The Marine Maintenance and Repair Industry
Risk Reduction Engineering Laboratory
and
Center for Environmental Research Information
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, OH 45268
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Notice
This guide has been subjected to the U.S. Environmental Protection Agency's peer and
administrative review and approved for publication. Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.
The document is intended as advisory guidance only to marine maintenance and repair yards
in developing approaches for pollution prevention. Compliance with environmental and occupa-
tional safety and health laws is the responsibility of each individual business and is not the focus
of this document.
Worksheets are provided for conducting waste minimization assessments of marine yards.
Users are encouraged to duplicate portions of this publication as needed to implement a waste
minimization program.
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Foreword
Marine repair service yards are highly diversified in terms of the types of services and
products supplied. Services typically include repair and maintenance of mechanical systems,
structural components, upholstery, electrical systems, and finished surfaces. Typical wastes
generated from these operations include oils, coolants, lubricants and cleaning agents; various
chemicals; paints and coatings; as well as dusts from sanding, sand blasting, polishing and
refinishing operations.
Reducing the generation of these wastes at the source, or recycling the wastes on or off site,
will benefit the marine yards by reducing raw material needs, reducing disposal costs, and
lowering the liabilities associated with hazardous waste disposal. This guide provides and
overview of the maintenance and repair operations that generate waste and presents options for
minimizing waste generation through source reduction and recycling.
111
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Acknowledgments
This guide is based on waste minimization assessments for the Marine Maintenance and
Repair Industry performed by SCS Engineers for the California Department of Health Services,
Alternative Technology Division, Toxic Substances Control Program under the direction of
Benjamin Fries. Teresa Harten of the U.S. Environmental Protection Agency, Office of Research
and Development, Risk Reduction Engineering Laboratory, was the Project Officer responsible
for the preparation of this guide, which was edited and produced by Jacobs Engineering Group,
Inc. J.D. Shoemaker and Rajeev Krishnan served as authors of this guide.
We would like to thank the following people, whose review of this guide contributed
substantially to its development:
Rodney Marsh
Dr. Daryl Davis
Bob Michell
Ben Swenson
- SCS Engineers
- East Carolina University
- South West Marine Ship Repair
- Al Larson Boat Shop
Much of the information in this guide that provides a national perspective on the issues of
waste generation and minimization was provided originally to the U.S. Environmental Protection
Agency by Versar, Inc. and Jacobs Engineering Group, Inc. in Waste Minimization - Issues and
Options, Volume II, Report No. PB87-114369 (1986)
IV
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Contents
Section
Notice ii
Foreword iii
Acknowledgments iv
1. Introduction 1
Overview of Waste Minimization Assessment 1
Waste Minimization Opportunity Assessments 1
References 3
2. Marine Maintenance and Repair Industry Profile 5
Industry Description 5
Raw Materials 6
Description of Services ..6
Waste Description 7
References g
3. Waste Minimization Options for Marine Maintenance and Repair Yards 11
Chemical Stripping Wastes 11
Abrasive Blast Wastes 12
Paint and Solvent Wastes 13
Equipment Cleaning Wastes 15
Machine Shop Wastes 15
Engine Repair Shop Wastes 15
Specialty Shop Wastes 15
Vessel Cleaning Wastes 16
Spill Control 16
References 17
4. Waste Minimization Assessment Worksheets ; 21
Appendix A 38
Marine Maintenance and Repair Yards Assessments
Caste Studies of Yards A, B and C
Appendix B 59
Where to Get Help: Further Information on Pollution Prevention
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Section 1
Introduction
This guide is designed to provide marine maintenance
and repair yards with waste minimization options appropriate
for this industry. It also provides worksheets designed to be
used for a waste minimization assessment of a marine repair
and service yard, to be used in developing an understanding
of the yard's waste generating processes and to suggest ways
to reduce the waste. The guide should be used by site
operators and environmental engineers of marine repair and
service yards. Others who may find this document useful are
regulatory agency representatives, industry suppliers and
consultants.
In the following sections of this guide you will find:
• A profile of marine maintenance and repair yards
and their operations (Section 2);
Waste minimization options for marine mainten-
ance and repair yards (Section 3);
• Waste minimization assessment guidelines and
worksheets (Section 4);
• Appendices, containing:
Summaries of three waste minimization
assessments;
Where to get help: Additional sources of
information on pollution prevention.
The worksheets and the list of waste minimization op-
tions for marine maintenance and repair yards were devel-
oped through assessments of three repair and maintenance
facilities commissioned by the California Department of
Health Services (Calif. DHS 1989). The three yards' repair
and maintenance operations, and waste generation and man-
agement practices were surveyed, and their existing and
potential waste minimization options were characterized.
Economic analyses were performed on selected options.
Overview of Waste Minimization Assessment
Waste minimization is a policy specifically mandated by
the U.S. Congress in the 1984 Hazardous and Solid Wastes
Amendments to the Resource Conservation and Recovery
Act (RCRA). As the federal agency responsible for writing
regulations under RCRA, the U.S. Environmental Protection
Agency (EPA) has an interest in ensuring that new informa-
tion is made available to the industries concerned. This guide
is one of the approaches EPA is using to provide industry-
specific information about waste minimization. The options
and procedures outlined can also bs used in efforts to mini-
mize other wastes generated in a business.
In the working definition used by EPA, waste minimiza-
tion consists of source reduction aind recycling. Of the two
approaches, source reduction is considered environmentally
preferable to recycling. While a few states consider treatment
of waste an approach to waste minimization, EPA does not,
and thus treatment is not addressed in this guide.
Waste Minimization Opportunity Assessment
EPA has developed a general manual for waste minimi-
zation in industry. The Waste Minimization Opportunity
Assessment Manual (USEPA 1988) tells how to conduct a
waste minimization assessment and develop options for
reducing hazardous waste generation at a facility. It explains
the management strategies needed to incorporate waste mini-
mization into company policies and structure, how to estab-
lish a company-wide waste minimization program, conduct
assessments, implement options, and make the program an
ongoing one.
A Waste Minimization Opportunity Assessment
(WMO A), sometimes called a waste minimization audit, is a
systematic procedure for identifying ways to reduce or elimi-
nate waste. The four phases of a waste minimization oppor-
tunity assessment are: planning and organization, assess-
ment, feasibility analysis, and implementation. The steps
involved in conducting a waste minimization assessment are
outlined in Figure 1 and presented in more detail in the
paragraphs below. Briefly, the assessment consists of a
careful review of a plant's operations and waste streams and
the selection of specific areas to assess. After a particular
waste stream or area is established as the WMOA focus, a
number of options with the potential to minimize waste are
developed and screened. The technical and economic feasi-
bility of the selected options are then evaluated. Finally, the
most promising options are selected for implementation.
Planning and Organization Phase
Essential elements of planning and organization for a
waste minimization program are: obtaining management
commitment for the program; setting waste minimization
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The Recognized Need to Minimize Waste
I
PLANNING AND ORGANIZATION PHASE
• Get management commitment
• Set overall assessment program goals
• Organize assessment program task force
Assessment Organization &
Commitment to Proceed
ASSESSMENT PHASE
Collect process and site data
Prioritize and select assessment targets
Select people for assessment teams
Review data and inspect site
Generate options
Screen and select options for further study
Select New Assessment
Targets and Reevaluate
Previous Options
Assessment Report of
Selected Options
I
FEASABILITY ANALYSIS PHASE
Technical evaluation
Economic evaluation
Select options for implementation
Final Report, Including
Recommended Options
IMPLEMENTATION PHASE
Justify projects and obtain funding
Installation (equipment)
Implementation (procedure)
Evaluate performance
Repeat the Process
Successfully Implemented Waste Minimization Projects
Figure 1. The Waste Minimization Assessment Procedure
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goals; and organizing an assessment program task force.
Assessment Phase
The assessment phase involves a number of steps:
Collect process and site data
Prioritize and select assessment targets
Select assessment team
Review data and inspect site
Generate options
Screen and select options for feasibility
study
Collect process and facility data. The waste streams at a
facility should be identified and characterized. Information
about waste streams may be available on hazardous waste
manifests, National Pollutant Discharge Elimination System
(NPDES) reports, routine sampling programs and other
sources.
Developing a basic understanding of the processes that
generate waste at a facility is essential to the WMOA process.
Block diagrams should be prepared to identify the quantity,
types and rates of waste generating processes. Also, prepar-
ing overall material balances for the facility can be useful in
tracking various waste stream components and identifying
losses or emissions that may have been unaccounted for
previously.
Prioritize and select assessment targets. Ideally, all
waste streams in a facility should be evaluated for potential
waste minimization opportunities. With limited resources,
however, a plant manager may need to concentrate waste
minimization efforts in a specific area. Such considerations
as quantity of waste, hazardoiisxproperties of the waste,
regulations, safety of employees, economics, and other char-
acteristics need to be evaluated in selecting a target stream.
Select assessment team. The team should include people
with direct responsibility and knowledge of the particular
waste stream or area of the plant. Operators of equipment and
the person who sweeps the floor should be included, for
example.
Review data and inspect site. The assessment team
evaluates process data in advance of the inspection. The
inspection should follow the target process from the point
where raw materials enter the facility to the points where
products and wastes leave. The team should identify the
suspected sources of waste. This may include the mainte-
nance operations and areas for storage of raw materials and
finished product and for work in progress. The inspection
may result in the formation of preliminary conclusions about
waste minimization opportunities. Full confirmation of these
conclusions may require additional data collection, analysis,
and/or site visits.
Generate options. The objective of this step is to gener-
ate a comprehensive set of waste minimization options for
further consideration. Since technical and economic con-
cerns will be considered in the llater feasibility step, no
options are ruled out at this time. Information from the site
inspection, as well as trade associations, government agen-
cies, technical and trade reports, equipment vendors, consult-
ants, and plant engineers and operators may serve as sources
of ideas for waste minimization options.
Both source reduction and recycling options should be
considered. Source reduction may be accomplished through
good operating practices, technology changes, and input
material changes. Recycling include use andreuseof a waste
stream and reclamation.
Screen and select options for feasibility study. This
screening process is intended to select the most promising
options for full technical and economic feasibility study.
Through either an informal review or a quantitative decision-
making process, options that appeal' marginal, impractical or
inferior are eliminated from consideration.
Feasibility Analysis Phase
An option must be shown to be technically and economi-
cally feasible in order to merit serious consideration for
adoption at a facility. A technical evaluation determines
whether aproposed option will work in a specific application.
Both process and equipment changes need to be assessed for
their overall effects on waste quantity and product quality. An
economic evaluation is carried out using standard measures
of profitability, such as payback period, return on investment,
and net present value. As in any project, the cost elements of
a waste minimization project can be broken down into capital
costs and operating costs. Savings and. changes in revenue
also need to be considered.
Implementation Phase
An option that passes both technical and economic
feasibility reviews should then be implemented at a facility.
It is then up to the WMOA team, with management support,
to continue the process of tracking wastes and identifying
opportunities for waste minimization by periodic reassess-
ments. Such ongoing reassessments and the initial investiga-
tion of waste minimization opportunities can be conducted
using this manual.
References
Calif. DHS. 1989. Waste audit study: marineyardsfor
maintenance and repair. Report prepared by SCS
Engineers, Inc., Long Beach, CA, for the California
Dept. of Health Services Alternative Technology
Section, Toxic Substances Control Division. August
1989.
USEPA. 1988. Waste minimization opportunit assess-
ment manual. Prepared by Jacobs Engineering
Group Inc. for the U.S. Environmental Protection
Agency. Hazardous Waste Engineering Research
Laboratory, Cincinnati, OH. EPA/625/7- 88/003.
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Section 2
Marine Maintenance and Repair Industry Profile
Industry Description
This study focuses on those marine repair and service
facilities that fall under the S tandard Industrial Classification
(SIC) codes 3731 and 3732 that include ship and boat
building and repair facilities. The establishments in this
industry are engaged in general ship and boat painting and
repair, both to the ship or boat structure and the engines or
power plants. The industry is comprised of approximately
700 establishments and employs over 176,000 personnel.
The total value of shipments including new products, repair,
and maintenance services for this industry was estimated at
$14 billion (USDC1989). Table 1 lists the valueof repair and
maintenance services alone executed by these industries,
namely boat building and repair (SIC code 3731) and ship
building and repair (SIC code 3732).
There are two distinct marine repair and service industry
subsets, boat yards and ship yards, with different character-
istics. Boat repair yards are more numerous, comprising over
75 percent of the total, and smaller, with over 80 percent of
the yards employing fewer than 20 people. Boat repair yards
concentrate primarily on recreational and some small com-
mercial craft, usually constructed of wood, fiberglass, or
aluminum. Services offered are generally limited to painting
hull and topside structures and engine repair, while other
required services are subcontracted out. However, some boat
yards include full repair.
Table 1. Value of Marine Repair and Maintenance Services
The smaller ship yards typically service smaller com-
mercial fishing vessels and barges, while the larger yards
build and repair freighters, tankers, naval vessels, liners. A
variety of services may be offered, depending on the particu-
lar yard. The smallest yards generally limit their activities to
painting and/or servicing engines. A large shipyard resembles
, an industrial complex; its operations include structural re-
pairs, painting, engine or power plant maintenance, machine
shops, electroplating, air conditioning and refrigeration ser-
vice, electrical repair, and other clraning and repairing ser-
vices.
Some of the repair services offered, particularly hull
maintenance, require that the vessel be removed from the
water. There are basically three mechanisms by which this is
accomplished, all of which affect waste generation and
management. Large yards frequently use conventional dry
docks in which the ship is floated into the dock, sea walls are
closed, and the water is removed, leaving the ship supported
in a dry basin. The interior of a dry dock is below mean sea
level. The second mechanism is the railway dock, whereby
the ship is moved up onto dry land via a railway extending
down into the water. The third mechanism suitable only for
small vessels, is the traveling hoist, which lifts the vessel out
of the water and sets it on supports: on dry land.
SIC Code
Product
Value of Services
(in million dollars)
37314
37316
37310
37328
37320
Ship repair, military 1927.7
Ship repair, non-military 806.2
Ship building and repairing, not covered above 253.8
Boat repair, military and non-miliatry 203.0
Boat building and repair, not covered above 723.8
Source: 1987 Census of Manufacturers (USDC 1989)
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Raw Materials
Many of the services provided by the industry involve
the use of materials and operations that are widely used in
many other service industries, such as automobile repair,
painting services, body shops, and home maintenance. Typi-
cal input materials used in the more common processes as
listed below are:
Processes
Paint removal
Painting
Engine repair
Machine Shop
Specially repair shops
Metal finishing
Fiberglass-reinforced
and composite
plastic fabrication
Input Materials
Chemical paint strippers, blast
media
Antifouling paints
Degreasing solvents, carbure-
tor cleaner
Degreasing solvents, cutting
fluids
Cleaning solvents, acids and
alkalies, chlorinated solvents
Cyanide, heavy metal baths,
acids and alkalies
Fiberglass and reinforcement,
resinsandsolvent,curingand
mold release agents
Description of Services
The services offered by marine maintenance and repair
yards involve a number of operations that generate waste:
painting activities, engine and power plant service, specialty
repairs, vessel cleaning, and fueling and marina services. In
the following paragraphs, the operations and waste genera-
tion are described.
Painting Activities
Painting is probably the most common operation in
marine maintenance and repair yards. There are three basic
painting-related activities that generate hazardous wastes:
Surface preparation, painting, and equipment cleaning.
Surface Preparation
Very few surfaces, whether marine or otherwise, can be
painted without suitable preparation. Proper surface prepara-
tion is essential to ensure adequate adhesion, durability, and
dependability of the surface coating. Abrasive blasting and
chemical stripping, described next, are some of the common
surface preparation techniques used in the industry.
Repainting of a vessel hull generally requires removal of
any marine growths and the existing paint coat. The most
common method for removal of paint from vessel hulls is
abrasive blasting, an efficient and relatively inexpensive
approach. Often, the blasting medium itself is not hazardous.
The most common materials are garnet or flint grit, and steel
shot Because lead shot and copper slag are or may be
inherently hazardous, their use is limited to situations where
the blasting medium can be recovered for proper disposal.
Grit blasting is not effective on aluminum or fiberglass hulls
or delicate steel parts, but plastic media blasting can be used
(Bollard 1991). Chemical stripping is also widely used for
removing paints. The most common stripping agents are
based on methylene chloride, although some users have
switched to aqueous solutions of caustic soda.
Painting
Both interiors and exteriors of vessels are painted to
improve appearance and/or provide corrosion protection.
Surfaces are generally spray painted, but small parts are
sometimes hand painted. Most top side and interior paints are
not nearly as toxic as antifouling bottom paints, which
generally contain toxic pigments such as chromium, titanium
dioxide, lead, or tributyl tin compounds.
Equipment Cleaning
Paint spray guns, brushes, and equipment must be cleaned
after use to render them reusable. Water and detergent are
used for cleaning brushes used for water-based coatings,
while brushes that were used for solvent-based coatings are
cleaned with suitable cleaning solvents. Although it may be
possible to sewer water-based coating rinsate, the spent
solvents require management as a hazardous waste.
Engine and Power Plant Service
Engine repair service may be done by the marine main-
tenance and repair yard or subcontracted out Engine service
for small craft differs little in terms of materials and hazard-
ous wastes derived from automotive engine service. Typical
wastes are spent lube and engine oils, degreasing and clean-
ing solvents, spent batteries, and coolants (USEPA 199 la).
Power plant service for larger vessels may consist of more
extensive cleaning operations, boiler and turbine mainte-
nance, and possibly parts fabrication and electroplating.
Specialty Repairs
Large yards may operate several specialty repair shops,
such as sheet metal shops, patterns shops, electrical repair
shops, reinforced plastics fabricating, and metal finishing.
Wastes from these shops include solvents, acid and alkaline
cleaning wastes, electroplating wastewaters, resins and fugi-
tive air emissions.
Sheet metal fabrication and metal finishing operations
typically are comprised of welding, cutting, pressing, boring,
milling, machining, buffing and polishing.
Electroplating operations involve two major steps, namely
pretreatment and electrodeposition. Alkali and acid rinsing
of metal parts are the primary pretreatment steps, although
sometimes cyanide stripping is also carried out in this step.
Electrodeposition is the process by which a heavy metal such
as copper, nickel or chromium is deposited on carbon steel,
aluminum and stainless steel surfaces to provide additional
corrosion protection.
Reinforced and composite plastics fabrication use vari-
ous techniques, most commonly hand layup and spray layup,
for the combination of resin and reinforcing material. Please
refer to the pollution prevention guide for the fiberglass
industry for a more complete description (USEPA 1991b).
Vessel Cleaning
The holding tanks that most yards use to store bilge
wastes from vessels being serviced may also be used as the
repository for all liquid wastes generated at the yard. Wastes
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Table Z. Marine Maintenance and Repair Facility Wastes
No.
Operation Origin
Waste Description
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
All
Air emissions from storage tanks and
open processing equipment emissions
Grit blasting and chemical stripping
Spray painting, resin application
Engine repair
Electroplating/metal finishing operations
Machine Shops
Equipment cleaning, area washdown,
Degreasing, equipment cleaning, chemical
paint stripping, reinforced plastic fabrication
Vessel bilge cleaning
Leftover raw material containers (e.g.
bags, fiber drums) with residual raw
materials
Volatile organic compounds (VOC)
emissions
Wastewater containing blasting media,
organic paint sludges, heavy metals,
stripping chemicals, VOC emissions
Waste paints, thinners, degreasers,
solvents, resings and gelcoat, VOC
emissions
Waste turbine oil, lubricants, degreasers,
mild acids, batteries, carburetor cleaners,
VOC emissions
Cyanide solutions; heavy metal sludges,
corrosive acid and alkali solutions
Spent cutting and lube oils, scrap metal,
degreasers, VOC emissions
Wastewater containing paints, solvents,
oils and degreasers
Resin and paint contaminated solvents,
VOC emissions
Bilge wastes (oily water)
arecollected from the yards by vacuum trucksfor appropriate
disposal. Recognizing to the potential risks associated with
on-site storage of liquid wastes, some yards subcontract the
cleaning work to outside businesses, which generally take
responsibility for appropriately collecting and disposing of
these wastes.
Fueling and Marina Services
Most marinas provide routine fueling and related gen-
eral services for boats; however, the nature of the facilities
and the services provided depend on the size and type of the
marina. Besides selling fuel and related products and provid-
ing for short-term and/or long-term dockage or storage ves-
sels, some marinas may also be equipped to service vessels,
and they may specialize in a particular size range of vessels.
Inland marinas normally sell gasoline, outboard motor oil,
and oil-gas mixtures for outboards. Facilities located on
larger rivers, bays, and coastal harbors typically provide the
same products plus diesel fuel and other lubricants and fluids
(Davis and Piantadosi 1988).
Waste Description
The services offered by different marine yards vary
widely, and the quantity of wastes produced varies both with
the size of the marine maintenance and repair yard and the
type and size of vessel serviced. However, the wastes do not
vary widely within a given operation; therefore, waste gen-
eration and management will be discussed on an operation-
specific basis, rather than in terms of a yard as a whole. Table
2 summarizes the wastes and their operational sources.
Surface preparation and equipment cleaning are the
major sources of paint-related hazardous wastes. Many hull
paints are antifouling coatings, containing toxic biocides to
prevent or minimize marine growths that eventually foul
hulls. Most of these toxic agents arc heavy metal or organo-
metallic compounds, such as cuprous oxide, lead oxide and
tributy 1 tin compounds. Paint chips containing these antifoul-
ing agents are generally hazardous,, but in practice the con-
centration of toxic compounds is reduced by dilution with the
blasting medium. The resulting mixed waste may be
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nonhazardous, however, it is necessary to classify the waste
by testing samples before managing it as nonhazardous
waste.
Wastefrom nonblastingmechanical stripping (e.g., scrap-
ing, thermal stripping) tends to be predominantly paint resi-
dues and, if antifouling paints are involved, is almost cer-
tainly hazardous. Since most chemical paint strippers are
themselves hazardous, wastes from chemical stripping will
probably be hazardous even if the original paint contained no
toxic materials. In addition to the above wastes, some chemi-
cal strippers can emit high concentrations of volatile organic
compounds (VOQ into the air.
Equipment cleaning generates hazardous waste in the
form of solvents, thinners, and acids. Paint spray equipment,
brushes, and other paint application equipment are generally
cleaned with solvents or thinners after use. Evaporation of
solvent is associated with solvents applied with rags, and
hazardous residuals may be generated during the application
of acids by rag or brush. Also, wastewater contaminated with
acids is generated by washing off acid-etched hulls.
For recreational boats and small ships, inboard engine
repair work differs little from automobile engine repair, and
the same types of wastes are generated. These wastes will
include lube oils, hydraulic fluids, waste fuels, carburetor
cleaner, hydrocarbon solvents (mineral spirits, hexane, or
gasoline), oil filters, and batteries. Options for minimizing
wastes in automobile repair shops are described in EPA's
Guides to Pollution Prevention: The Automotive Repair
Industry (USEPA 1991a).
Engine repair shops at large yards may be much more
sophisticated, since they include machine shops. The quanti-
ties of wastes produced are significantly greater than at
smaller yards, and may include additional wastes such as
machine shop cutting fluids and other degreasing and clean-
ing solvents, for example, acetone, methyl ethyl ketone
(MEK), and possibly chlorinated solvents. The yard may
generate solvent-based or caustic boiler cleaning wastes as
well.
Machine shops at marine maintenance and repair yards
may generate degreasing solvents and cutting oil wastes and
at larger yards may perform electroplating, which generates
wastes consisting of spent acid, alkali and cyanide cleaning
solutions and heavy metal sludges.
Large shipyards frequently operate a variety of special-
ized on-site repair shops for maintenance and repair of
systems unique to large vessels or beyond the capabilities of
small yards. These shops and their wastes can include:
• Sheet metal shop for fabrication of structural
components. Wastes include degreasing solvents,
acid and alkaline cleaning wastes, chromic acid,
and contaminated rinse waters.
• Reinforced and composite plastics fabrications.
Wastes consist of spent cleaning solvents, gelcoat
and resin oversprays, styrene emissions and scrap
material.
• Pattern shop. Wastes generated by pattern shops
are isocyanates, alcohol, toluene, and other
hydrocarbon solvents, and contaminated sawdust
• Electrical repair. Electrical repair wastes are
trichloroethylene, trichloromethane, acetone,
methylene chloride paint strippers, and some
electroplating wastes.
• Pipe fitting shop. Wastes associated with pipe
fitting include chemical paint stripping wastes,
degreasing solvents, and acid and caustic cleaning
solutions, and metal chips, and cutting oil.
• Air conditioning and refrigeration repair. Wastes
consist of phenols, cresols, solvents, and chloro-
fluorocarbon refrigerants.
Wastes associated with vessel cleaning are typically
generated outside the shipyard when the vessel is in use.
However, because of the nature of the wastes and the way
they are handled, the repair yard is frequently the generator
on record. The most common of these wastes, called bilge
waste, is composed of wastewater containing oil and fuel
removed from vessel bilges. Virtually every yard has facili-
ties for handling this waste. Larger vessels also may generate
sanitary wastes, which usually can be sewered directly, and
chemical cleaning wastes associated with the cleaning of
sanitary systems, which cannot be sewered.
Another waste sometimes generated in the refurbish-
ment of larger, older vessels is asbestos, formerly a common
thermal insulating or fire protection material. However, it is
being replaced by non-asbestos materials.
References
Ballard.R. 1991. Safe and gentle strippping.
Products Finishing, January, 1991.
Calif. DHS. 1989. Waste audit study: marineyards for
maintenance and repair. Report prepared by SCS
Engineers, Inc., Long Beach, CA, for the California
Department of Health Services Alternative Technol-
ogy Section, Toxic Substances Control Division.
Davis, D. and L. Piantadosi. 1988. Marine maintenance
and repair: waste reduction and safety manual
Prepared for Pollution Prevention Pays Program,
North Carolina Department of Natural Resources and
Community Development, Raleigh, N.C.
USDC. 1989. U.S. Department of Commerce, Bureau of
the Census. Ship and Boatbuilding, Railroad and
Miscellaneous Transportation Equipment. 1987
Census of Manufacturers. MC87 - 137c (P). Wash-
ington, D.C.: U.S. Government Printing Office.
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USEPA. 1986. U.S. Environmental Protection Agency.
Waste minimization - issues and options, volume III.
NTIS PB87 -114377. Prepared by Versar Inc. and
JacobsEngineering Group Inc.
USEPA. 199 la Guides to pollution prevention: the auto-
motive repair industry. Prepared by Jacobs Engineer-
ing Group Inc. for the U.S. Environmental Protection
Agency, Office of Research and Development. Cin-
cinnati, OH. EPA/625/7-91/013.
USEPA. 199 Ib. Guides to polution prevention: fiber-
glass-reinforced and composite plastics industry.
Prepared by Jacobs Engineering Group Inc. for the
U.S. Environmental Protection Agency, Office of
Research and Development. Cincinnati, OH. EPA/
625/7-91/014.
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Section 3
Waste Minimization Options for
Marine Maintenance and Repair Yards
This section discusses potential waste minimization
methods for marine maintenance and repair operations. These
methods come from accounts published in the literature and
through industry contacts. The primary waste streams asso-
ciated with maintenance and repair operations are listed in
Table 4 along with potential waste minimization methods.,
The major waste streams are chemical paint stripping wastes;
abrasive blast and surface preparation wastes; painting and
solvent wastes; equipmentcleaning wastes; engine overhaul-
ing and repair wastes; machine shop wastes; specialty shop
wastes; and vessel cleaning wastes. The waste from a particu-
lar operation often enters wastewaters and air as well as
having a solid component. For example, abrasive blast and
surface preparation wastes may become air paniculate mat-
ter, trace metal pollutants of potable and navigable water, and
contaminants in soil and groundwater.
The waste minimization methods in Table 4 can be
classifiedgenerally as source reduction, which can beachieved
through material substitution, process or equipment modifi-
cation, or better operating practices; or as recycling.
Source reduction is achieved through better operating
practices by employing procedural or administrative policies
that result in a reduction of waste. They include:
• Waste stream segregation
• Personnel practices
Management initiatives
Employee training
Employee incentives
• Procedural measures
Documentation
Material handling and storage
Material tracking and inventory control
Scheduling
In addition to the specific recommendations provided
below, rapidly advancing technology makes it important that
companies continually educate themselves about improve-
ments that are waste reducing and pollution preventing.
Information sources to help inform companies about such
technology include trade associations and journals, chemical
and equipment suppliers, equipment expositions, confer-
ences, andindustrynewsletters.Bykeepingabreastof changes
and implementing applicable technology improvements,
companies can often take advanta,ge of the dual benefits of
reduced waste generation and a more cost efficient operation.
Chemical Stripping Wastes
Methylene chloride is the most commonly used paint
stripping agent, although it is increasingly being replaced by
solvents such as dibasic esters which are less volatile and
hazardous. Chemical stripping wastes consist primarily of
the stripping agent and paint sludges. The following waste
reduction methods are suggested to minimize the generation
of chemical stripping wastes.
Waste segregation. Segregating the stripping age'nts
from other waste streams will help facilitate cost-efficient
reuse and recycling of contaminated strippers. Extreme care
must be taken to avoid cross-contaminating the stripping
agents.
Use of less toxic stripping agents. Inorganic strippers,
usually consisting of aqueous solutions of caustic soda, can
substitute for methylene chloride-based strippers in many
applications. Although the waste stripper is still hazardous, it
is relatively less toxic and easy to treat on site, generating a
non-hazardous waste that can possibly be disposed of to the
public sewer. Several new less hazardous and toxic degreasing
and stripping agents are currently available in the market
Substitutes include dibasic esters (DBE), semi-aqueous ter-
pene- based products, detergent-based products and C9- to
C12-based hydrocarbon strippers. Manufacturers claim that
these products are non-chlorinated, biodegradable, exhibit
low volatility and are not listed as hazardous substances.
Store and reuse stripping agents. Solvent strippers,
particularly stripping baths, can generally be reused several
times before their effectiveness is compromised. Appropri-
ate collection and storage systems need to be installed if the
stripper is to be reused.
Recycle spent strippers. Both spent organic and caustic
stripper solutions can be treated to remove contamination.
One method of treatment uses centrifuge or filtration systems
to separate the paint sludge from the stripper; then makeup
chemicals are added to the stripper, which then can be reused.
Stripping baths equipped with such treatment systems can
11
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Tabla 4. Waste Minimizatbn Methods for Marine Maintenance and Repair Yards
Waste Stream
Waste Minimization Methods
Chemical paint stripping wastes
Abrasive blast waste (wet solids and wastewater)
Paint and solvent wastes
Equipment cleaning wastes
Engine repair wastes
Machine shop wastes
Specialty shop wastes
Vessel cleaning wastes
Spills and floor washdowns
Waste segregation.
Non-toxic stripping agents.
Maximize stripper usage by reuse.
Recycling stripper using appropriate recycling techniques.
Better operating practices.
Use alternate blasting media and techniques.
Segregation and recycle of blast media.
Use blast dust collection systems.
Tighter inventory control and good housekeeping.
Use water-based and less toxic coatings
Solvent reuse and recycling
On-site waste exchange.
Off-site waste exchange.
Waste segregation.
Minimization of fugitive overspray.
Segregation of cleaning agents.
Recycling of cleaning solvents.
Replace solvent cleaners with detergents wherever possible.
Use aqueous degreasers.
Use dedicated solvent sinks for parts washing.
Segregation of spent engine and lube oils.
Recycling of oils and solvents.
Waste exchange.
Use of water soluble cutting fluids.
Recycling of cutting and lubrication fluids.
Segregation and waste exchange of metal and plastic turn-
ings and scrap.
Good operating practices.
Process and equipment modifications.
Use of detergent cleaners instead of solvent cleaners.
Use of detergent cleaning agents.
Good housekeeping.
Proper storage.
Spill control measures.
often be used almost indefinitely. While the paint sludge that
is separated may have to be treated as a hazardous waste, the
quantity is much smaller than the quantity of combined
sludge and stripper usually discarded. In addition, recycling
and reuse considerably reduces the need for fresh or make-up
stripping solution and thus results in substantial savings.
Better operating practices. Chemical stripping of small
parts employs dip tanks and generate wastes consisting of
spent stripper that clings to the part after rinsing (drag-out).
Somereduction in drag-outand contaminated rinse water can
be achieved by allowing the dipped parts to drain longer
above the dip tank, or by improving the way in which dipped
parts are stacked before draining to prevent "pooling" of
stripper on the parts.
Abrasive Blast Wastes
Abrasive blasting is often used in preference to chemical
stripping for removing paints. While this procedure avoids
disposal of chemical strippers, it does not eliminate wastes
altogether. The most commonly used blasting media is sand
or grit with a large volume of water.
12
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The presence of paint chips containing hazardous metal-
lic and organometallic biocides makes abrasive blasting
wastes potentially hazardous. Blast waste water generally
constitutes the largest single waste stream from many repair
yards. For instance, wet abrasive blasting of an average-sized
naval vessel (DDG class) can generate up to 180 tons of wet
abrasive and 500,000 gallons of contaminated water (Adema
and Smith 1987). Some of the waste minimization options
available are:
Use alternate blasting media and techniques. Research
and testing is underway on a number of innovative alterna-
tives to both grit blasting and chemical stripping. The alter-
nate techniques include: plastic media blasting, water jet
stripping, thermal stripping, dry ice pellets, laser paint strip-
ping, and cryogenic stripping. Descriptions of each of these
alternatives are provided below.
Plastic media blasting. When chemical stripper is ap-
plied to a large area and men washed off, large volumes of
hazardous wastewater can be created. The military has ex-
perimented extensively with plastic media blasting (PMB) as
a substitute for chemical stripping, with mixed results. Three
disadvantages are that PMB will not work well on epoxy or
urethane paints, and the blasting equipment is more expen-
sive than conventional grit blasting equipment and requires
more highly trained operators. On the positive side, the same
types and quantities of solid wastes are generated as with grit
blasting, but the plastic media tend to be more easily recy-
clable through the use of pneumatic media classifiers that are
part of the stripping equipment. Thus, the main waste to be
disposed of is the paint waste itself. Abrasion eventually turns
die plastic media into fine dust, that must be disposed of.
Based on research conducted by the military, chemical strip-
ping a fighter aircraft will generate about 250,000 gallons of
stripper waste; by contrast, PMB will generate two 55-gallon
drums of paint chips, and 200 pounds of nonrecoverable dry
spent plastic medium (Calif. DHS 1989). In addition, PMB
can be used on fiberglass boats, which cannot be stripped
chemically (Ballard 1991).
Water jet stripping. A cavitating water jet stripping
system has been developed to remove most paints, separate
the paint chips from the water, and treat the water to eliminate
dissolved toxic materials. Relatively little hazardous waste is
generated by this process. However, it is not as efficient as
conventional grit blasting and the equipment has higher
capital and operating costs.
Thermal stripping. Thermal stripping utilizes a flame or
stream of superheated air to heat and soften the paint layer,
thus allowing it to be peeled relatively easily. This method is
applicable only to some situations; for instance it is not
applicable to surfaces that might be heat-sensitive. In addi-
tion this process is more labor-intensive than other stripping
methods. The advantage of this method is that it generates
only one waste stream, namely a waste paint.
Dry ice pellets. Carbon dioxide (CO2) dry ice pellets can
be used as a blast medium that generates no media waste.
After use, the dry ice evaporates, leaving only paint chips that
can be swept up and placed in containers for disposal. The
cost of the dry ice, storage, and handling equipment could be
substantial, limiting applicability of this method. (Yaroschak
1989).
Laser paint stripping. Laser paint stripping has been
developed that generates "zero" residue. A pulsed CO2 laser,
controlled by an industrial robot, is used as the stripping
agent. This method is complex, capital intensive and requires
highly-skilled operators. (Yaroscliak 1989).
Cryogenic stripping. In cryogenic stripping, parts are
immersed in liquid nitrogen, followed by gentle abrasion or
plastic shot blasting to remove (he brittle paint coating. This
process requires special equipment for handling the liquid
nitrogen and is applicable only for small objects.
Segregate and recycle blast media
Most abrasive blast media are recyclable or reusable. In
many cases, the contaminated grit can be reused several times
to blastadditional vessels before bscoming too contaminated
or worn for further use. Because of the difference in density
between the grit materials and the waste paint chips, it is
possible to separate the grit from the paint waste. Cyclone
separators, gravity shakers, air separators, water separators,
and other systems can separate the paint residues from the
grit, which can then be reused.
Recycling is routinely performed when using steel shot,
lead shot, or plastic media because of the cost of the blast
media. In the case of "sand" blasting, the sand does not have
enough value to justify recycling. However, if the sand blast
waste is determined to be hazardous, requiring off-site dis-
posal, then this medium may become costly enough to justify
recycling. Natural organic abrasives, like walnut shells or
rice hulls, do not recycle well and are susceptible to biologi-
cal growth and deterioration.
Use dust collection systems
Dedicated bag-house filters may be installed on en-
closed blasting stations to collect the blast dust emissions.
One approach to prevent fugitive dust emissions from open
space blasting operations would be to enclose the area with
plastic sheeting or screening, thus confining the waste to the
immediate vicinity of the blasting. After blasting has been
completed, the waste should be collected, transferred to
dumpsters or other containers, and transported off site.
Paint and Solvent Wastes
Methods for minimizing paint and solvent wastes in-
clude tighter inventory control and good housekeeping, input
material substitution, solvent recycling and minimizing fugi-
tive oversprays.
Tighter inventory control and good housekeeping. Rigid
inventory control provides a very effective means of source
reduction at virtually no cost to the operator and can be
implemented in several ways. In smaller yards, an owner may
monitor employee operations and make verbal or written
comments on product usage and suggested limits. In larger
yards where monitoring of employees can be more difficult,
the owner or manager can limit access to storage areas
containing raw materials, forcing employees to stretch the
13
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use of raw materials and providing the owner/manager a
means of monitoring raw material use. In an effort to mini-
mize paint waste, many small yards either purchase paint
specifically for each job or require the vessel owner to supply
the paint.
Good housekeeping can provide very effective source
reduction. Examples of good housekeeping for paints and
solvents include storage area leak control and containment,
which can be easily implemented at no cost, and improve-
ments in drum location, product transfer, leak collection, and
drum transport, which can limit product loss.
Raw material substitution. The bottoms of all vessels are
coated with special anlifouling paints, which are highly toxic
and thus hazardous materials. The purpose of such paints is
to prevent, or atleast retard, growth of marine organisms (e.g.
barnacles). Hence, there are no non-toxic alternative materi-
als for this service. Cuprous oxide and copper flake rank
among the least toxic, but effective, antifoulants, while
arsenic and mercurials rank among the most toxic. Tributyltin
compounds are also extensively used and are suspected to be
highly toxic.
Paints for parts of the vessel that are not immersed in
water can be non-toxic. Part of the paint waste problem can
be alleviated by using water-based instead of solvent-based
paints. This has become standard practice in many industries
and helps to reduce not only hazardous paint wastes, but also
solvent cleanup wastes. Some people believe that water-
based coatings do not provide the same protection that
solvent-based coatings do (Higgins 1985). Solvent-based
coatings are generally more durable, tend to be less corrosive
to the metals being coated, and dry quickly. The longer drying
time of water-based coatings is exacerbated by the high
relative humidity of marine air. Water-based coatings are
suitable for areas where decoration is more critical than
protection, such as vessel interiors or decorative topside
work.
Powder coatings, based on finely pulverized plastics,
have been substituted for paints in some industrial applica-
tions. This technique uses no solvent and eliminates VOC
emissions, but requires that the coated surface be oven-cured
at about 400°F. Hence, it not suitable for large or heat
sensitive components and is not used to any significant
degree for marine maintenance or repair. In addition, the
application equipment is more expensive than conventional
paintapplicators, and highly- trained operators are necessary.
Solventrecycling. Aside from raw material substitution,
the best way to minimize solvent waste generation is to
directly reuse the solvents as much as possible, and then
recover and recycle them. Processes for recycling thinners
and solvents are well established and widely used in many
industrial sectors especially the automotive paint industry. A
waste minimization study of the automotive paint industry
indicated that all companies contacted used some form of on-
siteoroff-sitethinnerreclamation. Those generators who did
not find it economical to recycle contaminated thinners on
site sent their solvents to commercial recyclers for recovery
(Calif. DHS1987). Reclaimed thinners were often sold back
to the generators after recovery. Thinner recyclers can repro-
cess 70 to 80 percent of the incoming spent thinners into
reusable products (Stoddard 1981).
There are several alternatives for resource recovery and
recycling on site. Gravity separation, for example, is inex-
pensive and easy to implement This method of reclamation
separates a thinner or solvent from the contaminant solids
under quiescent conditions. The clear supernatant thinner can
be decanted using a drum pump and a float valve, and can be
used as a cleaning solvent or where thinner purity is not
critical, as in parts washer systems. Gravity separation can
provide valuable savings to any marine or boat yard by
reducing both waste quantities and new solvent purchases.
For larger shipyards, on-site distillation may be cost
effective. Distillation of solvent and thinner wastes can
significantly reduce the quantities of waste solvents disposed
of, and the purchase of new materials. A waste minimization
guide for the automotive repair industry includes a descrip-
tion and evaluation of several of the leading solvent recovery
systems (USEPA 199 la).
On-site waste exchange. Larger shipyards should
also consider on-site waste exchange. Solvents contami-
nated in one process or shop may be usable as cleaning
solvents in a less demanding operation elsewhere in the
shipyard. Yard and shop managers need to discuss their
individual solvent needs and waste characteristics to
determine the potential for this type of on-site reuse.
Off-site services. In general, three types of off-site
services are offered. The simplest involves collecting all
recyclable wastes and hauling them to a commercial
recycler who either recovers them or processes them into
fuel, depending on the quality of the waste. This is similar
to the practice currently being followed at most yards for
bilge wastes.
In a second type of service, the marine maintenance and
repair yard purchases thinners from suppliers who also col-
lect and recycle the wastes, a common practice among
automobile painting companies. Some suppliers may include
the cost of waste collection and recycling in the price of their
thinner. This increases the thinner cost but eliminates sepa-
rate hauling and disposal or recycle costs, and also reduces
the administrative burden on the owner or manager of the
yard.
Other companies provide a third type of service, in
which a parts washer system is leased to the client The parts
washer system can be as simple as a sink atop a drum of
solvent. Solvent is pumped out of the drum into the sink for
washing parts and equipment; used solvent drains back into
the drum, and solids settle to the bottom of the drum. Either
on a fixed schedule or whenever the solvent becomes too
contaminated for further use, the service company removes
the drum and leaves a drum of fresh solvent in its place. This
service is widespread among automotive repair shops and
other shops where large quantities of solvent are used to clean
small parts.
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Waste segregation. Regardless of whether on-site recy-
cling, on-site reuse, or off-site recycling is adopted, an
essential waste management practice is waste segregation—
placing different wastes into different containers for recovery
or disposal. This practice is critical to the success of any
program designed to reduce or recycle waste solvents, be-
cause solvents are much easier to directly reuse or recycle if
they are segregated, minimizing solvent contamination. Mix-
ing different solvents or putting wastewaters, oils, excess
paints, or paint strippers into common liquid waste drums can
make solvent reuse or recycling, difficult and impractical.
For instance, when an incompatible solvent or water is added
to a chlorinated solvent, hydrochloric acid can form slowly
due to hydrolysis. This renders the solvent unsuitable for
direct reuse until the acid is neutralized or otherwise re-
moved.
One related practice mat can facilitate segregation and
reduce the potential for solvent contamination is to standard-
ize the use of solvents at a yard. This would be useful
primarily alt larger shipyards, where different shops might
purchase their materials separately. Centralizing and control-
ling solvent purchases would reduce the potential for cross-
contamination, minimize the number of different solvents
purchased and increase the potential for on-site reuse.
Waste segregation can also reduce the overall quantities
of hazardous waste generated. When only a single container
is provided for collecting all waste materials, it is common for
nonhazardous wastes to be placed in the same container with
hazardous wastes, increasing the amount of hazardous waste
being generated. By providing separate, clearly- labelled
containers for each waste type, non-hazardous waste will not
be added to hazardous wastes. Many companies have noticed
a decrease in the total amount of hazardous waste being sent
off site after implementing waste segregation programs.
Minimization of fugitive oversprays. Paint overspray is
not usually collected or managed. However, at those
marineyards which conductpainting operations at the water's
edge or in uncontained areas, overspray can be a major
componentofrunoff into adjoining surface waters. Overspray
in non-marine industries is controlled by improved painting
techniques, including air-assisted airless; high volume, low
pressure turbine; air-atomized electrostatic; and airless elec-
trostatic application techniques (USEPA 199 Ic). However,
the compatibility of such techniques in marine applications
needs to be evaluated. Operators should be trained in ways to
minimize paint usage such as maintaining a fixed distance
from the surface while triggering the paint gun and releasing
the trigger when the gun is not aimed at the target. Overspray
can be confined by the use of plastic sheeting under and
around the vessel being painted.
Equipment Cleaning Wastes
Painting sprayers, brushes, and equipment must be
cleaned after use. Whenever possible, water-based coatings
should be used. If solvents are needed, the best way to
minimize solvent waste generation is by reusing the spent
solvents as much as possible, and then recycling them. These
options are discussed above.
Machine Shop Wastes
The major hazardous wastes from metal machining are
waste cutting oils and degreasing solvents. The currently
preferred method to reduce quantities of both is to substitute
a water-soluble cutting fluid. This practice has been adopted
in many machine shops without adversely impacting work
efficiency or quality, and without increasing the annual
operating cost appreciably.
Many machine shops successfully recycle spent coolant
from machining operations, and a number of proprietary
systems are available. This option may require monitoring
coolant strength (using a refractometer), removing tramp oil
and adding stabilizer and inhibitor chemicals. Recycling is
most easily implemented when a standardized type of coolant
is used throughout the shop.
Most shops already collect scrap metals from machining
operations and sell these to metal recyclers. Metal chips
which have been removed from the coolant by filtration
should be drained and included in this collection.
The solvents used in machine shops are those used in
automotive repair and other surface cleaning operations, and
they should be segregated for reuse as discussed under
"Waste Segregation." The waste cutting oils are amenable to
the same types of off-site oil recycling as engine lube oils. A
more detailed discussion on minimizing wastes from ma-
chine shops can be found in a waste audit report for finished
metal products (Calif. DHS 1989b).
Engine Repair Shop Wastes
Most marine engine repair woirk is similar to automobile
repair work. Typical wastes include solvents, waste turbine
oils, fuels, and batteries. Of these, the solvents are generally
the only wastes suitable for recoveiry and recycle on site. The
discussion of solvents above is applicable to solvents gener-
ated from engine repair.
In qualifying new or rebuilt turbines, thousands of gal-
lons of lightly-used turbine oil may be generated as waste.
The oil may be used for only a few minutes to a few hours and
holds excellent potential for recycling (Davis 1990). There
are a number of recycling operations equipped to re-refine
contaminated oil. Some states such as North Carolina operate
portions of theirmotor fleeton this waste oil. In addition there
are several waste exchanges that use the oil as a feedstock for
other processes. However to derive maximum economic
benefit, some care must be exerci;>ed in handling the waste
product. Waste oil containers should be clearly labelled and
kept secure to avoid cross contamination with other chemi-
cals and to keep water and general trash out. Incompatible
products should be kept separate, as directed by the firm that
will be accepting the waste. If the: waste is badly contami-
nated, then its value for burning, recycling, or other use is
greatly diminished, and the waste generator will be forced to
pay a much higher price for disposal. (Editor's note: Al-
though some marine yards are equipped to burn used oil as a
heating fluid, EPA does not consider this as waste minimiza-
tion).
15
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A discussion on the recycling of the other engine repair
waste streams can be found in a section on off-site recycling
in the waste audit study of the automotive repair industry.
This study also includes economic evaluations of two other
source reduction techniques, namely the use of aqueous
dcgrcasers and commercial solvent sinks for parts washing
(Calif. DHS 1987a).
Specialty Shop Wastes
Again the most common waste generated is spent sol-
vents, which should be handled as recommended in the
earlier sections on solvent wastes. However, many other
types of wastes can be generated depending on the nature of
the specialty shop operation. Some of the typical specialty
shops are pattern shops, sheet metal fabrication, electroplat-
ing, plastics fabrication, air conditioning and refrigeration
servicing and repair shops. Waste minimization techniques
specific to the above operations are discussed in other indus-
try-specific reports.
For instance, California Department of Health Services
has published waste minimization reports for the metal
finishing industry, mechanical equipment repair shops, and
several other operations and industries. For additional infor-
mation on the reports published by EPA and different states,
please consult the agencies listed in Appendix B.
Yards that work extensively with fiberglass-reinforced
plastic (e.g. repairing boat hulls) should refer to the EPA
pollution prevention guide for the fiberglass-reinforced plas-
tic fabrication industry, which describes specific waste mini-
mization techniques for such operations (USEPA 1991b).
Additional details have been published by the North Carolina
Pollution Prevention Pays Program (Davis and Piantadosi
1988).
Vessel Cleaning Wastes
Vessel cleaning wastes are generated on board. Upon
return to port, however, these wastes are removed and man-
aged by the repair yard, making the yard the generator of
record. Since the yard is not the source of vessel waste, there
is little that the yard can do to reduce that generation. Wastes
may also be generated from the cleaning of boiler tanks,
sanitary systems, and other tank systems on larger ships. If
chemical cleaners are used, these wastes will probably be
hazardous. It may be possible, in some cases, to substitute a
detergent cleaner or, in the case of a sanitary system, a
bacterial enzyme cleaner, either of which may be sewerable.
The generator must contact the local sewer authority to verify
whether the wastes are sewerable.
In order to reduce the risks associated with on-site
storage of liquid wastes, some yards subcontract the entire
cleaning operation to an outside firm specializing in the
collection and appropriate disposal of such wastes.
Spill Control
Spill control is especially important at marine mainte-
nance and repair yards, because most yards abut the ocean. It
is common for yards to be designed so that they slope toward
the ocean. Consequently, any spilled materials will be even-
tually washed into the ocean. Unless spills can be prevented
or contained in the yard, it may become necessary to imple-
ment run-on/runoff controls for the yard, consisting of curbs
or berms around the yard perimeter to confine all contamina-
tion to the yard, and having surfaces sloping toward a collec-
tion dump to allow all contaminated materials to be collected,
stored and disposed of properly. A detailed discussion on
waste containment and confinement strategies, including
design illustrations, can be found in Marine Maintenance and
Repair: Waste Reduction and Safety Manual (Davis and
Piantadosi 1988).
The potential for spills and leaks of thinners and solvents
is highest when a product is transferred from bulk drum
storage to the point of use. Spigots or pumps should always
be used when dispensing new materials, and funnels should
be used to transfer waste materials into storage containers.
Materials should never be poured directly from drums into
smaller containers.
If drum handling is necessary, the drums should be
moved correctly using powered equipment or hand trucks to
prevent damage or punctures to the drums. Under no circum-
stances should drums be tipped or rolled, even when empty.
Negligent handling may damage the seams, which could leak
or rupture in future use.
The risk of spills increases in both frequency and mag-
nitude when fueling services are included with yard services.
Storage tanks should have secondary containment. Other
ways to reduce the risk and to minimize spills include (Davis
and Piantadosi, 1988):
Watch the fuel tank vent to avoid overfilling.
• Be sure fuel flow has stopped before removing the
fuel nozzle from the fill pipe.
• Provide a drip pan for the fuel nozzle.
• Be sure the proper type of fuel is selected, to avoid
cross-contamination.
• Practice preventive maintenance on the entire
fueling system.
Derelict vessels can be one of the most intractable waste
problems facing a marine yard. Usable parts are generally
salvaged and reused, leaving a useless hull. Metal hulls often
can be sold as scrap, but wood and fiberglass hulls have
almost no commercial value. Burning of wooden hulls is
illegal in many places and strongly discouraged in most
others, so usually the wreck is left for eventual natural
decomposition. Fiberglass vessels can sometimes be used in
constructing artificial reefs, although this may be expensive.
The best advice to a yard regarding minimization of this type
of waste is to prevent derelicts from accumulating, since they
tend to attract even more derelicts (Davis and Piantadosi
1988).
16
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North Pomfret, VT.
Drabkin, M., and P. Sylvestri. 1988. Waste minimization'
audit report: case studies of minimization of solvent
wastes and electroplating wastes at a DOD installation.
EPA/600/2-88-010. U.S. EPA Hazardous Waste Engi-
neering Research Laboratory,, Cincinnati, OH. February
1988.
Freeman, H.M. 1989. Hazardous waste minimization -
industrial overviews. JAPCA Reprint Series. Published
by Air and Waste Management Association. Pittsburgh,
PA.
Freeman, H. M. 1989. Standard handbook of hazardous
i waste treatment and disposal. McGraw-Hill Book Com-
pany. New York, NY.
Hahn, W. J., and P. P. Werschulz. 1986. Evaluationof 'alter-
natives to toxic organic paint strippers. EPA/600/2-86/
063. U. S. EPA Water Engineering Research Labora-
tory. Cincinnati, OH. July 1986.
Higgins, T. E. 1989. Hazardous waste minimization hand-
book. Lewis Publishers, Inc. Chelsea, ML
Higgins, T. E. 1985. Industrial processes to reduce gener-
ation of hazardous waste at DOD facilities. Prepared for
DOD Environmental Leadership Project Office. Wash-
ington, D. C. February 1985.
17
-------
Kaminski.J.A. 1988. Hazardous waste minimization within
the Department of Defense, Part B. Journal of the Air
Pollution Control Association. 38(9):1174. September
1988.
Kaufman, A. J., and K. M. Jacob. 1987. Characterization
andsegregation of waste oils, solvents andfuels at naval
installations. In: Proceedings of the National Confer
cnce on Hazardous Wastes and Hazardous Materials,
Washington, D. C. March 16-18,1987. p. 335.
Kendall, D. 1975. The complete book of boat maintenance
and repair. Doubleday & Co. Inc. Garden City, NY.
Lamboume, R. 1987. Paint and surface coatings: theory and
practice. Ellis Harwood Limited, Chichester, England.
Lucas, D. F. 1990. The effective solvent alternative. In: CMI,
Marble Con '90, Charlotte, NC. February 22,1990.
Manzione.M. 1988. Waste minimizationfor electroplating
and aircraft paint-stripping wastewater treatment. In:
Process technology '88: the key to hazardous waste
minimization. Proceedings of a conference sponsored
by the Air Force Logistics Command. August 1988.
Roberts, J. 19Z4.Fiberglass boats: construction, repair, and
maintenance. W. W. Norton & Company. New York,
NY.
Saam.D., and P. J.Hearst. 1979. Chemical surface prepara-
tion for recoaling. TM-54-79-08. Naval Ship Engineer
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struction Battalion Center. Port Hueneme, CA. March
1979.
Saam, R. D., P. J. Hearst, L. K. Schwab, and D. B. Chan.
1977. Drydock waste treatment study. TN No. N-1490.
Naval Facilities Engineering Command, Civil Engi-
neering Laboratory, Naval Construction Battalion Cen-
ter. Port Hueneme, CA. July 1977.
Scarlett, J. 1981. Wooden boat repair manual. International
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SCS Engineers. 1987. Best management practices plan for
dry docks 1-6, Puget SoundNaval Shipyard, Bremerton.
Prepared for Naval Energy and Environmental Support
Activity, Port Hueneme, CA. September 1987.
SCS Engineers. 1988. Initial assessment study of Naval
Station San Diego, California.'NEESA. 13-087. Naval
Energy and Environmental Support Activity. Port
Hueneme, CA. May 1986.
SCS Engineers. \985.MareIslandNavalShipyardnew haz-
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Mare Island Naval Shipyard Public Works Department.
Vallejo, CA. November 1985.
SCS Engineers. 1980. Navy industrial waste emission
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Fort Detrick, MD. October 1980.
SCS Engineers. 1976. Oil spill prevention, control and coun-
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planfortheNavalShipyard(NAVSHIPYD)LongBeach,
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CA. December 1976.
SCS Engineers. 1987. Oil spill prevention, control and coun-
termeasure (SPCC) plan: Puget SoundNaval Shipyard
Bremerton. Naval Energy and Environmental Support
Activity. Port Hueneme, CA. September 1987.
SDC.1981.Hazardouswasteminimization.SanDieg,oCowty
Department of Health Services, Hazardous Waste Mat-
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Sowell, D. A. 1988. Hazardous waste minimization of abra-
sive blast media: addressing corrosion control and envi
ronmental risks. Journal of the Air Pollution Control
Association. 38(8): 1045. August 1988.
Stoddard, S. D., G. A. Davis, H. M. Freeman, and P. M.
Deibler. 1981. Alternatives to the land disposal of haz-
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Waste Assessment Group, Governor's Office of Appro-
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USEPA. 1979. Development document for proposed best
management practices for the shipbuilding and repair
industry: dry docks paint source category. EPA 440/1-
79/076b. U. S. Environmental Protection Agency. Efflu-
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1979.
USEPA. 1988. Waste minimization opportunity assessment
manual. EPA/600/2-88-025. Prepared by Jacobs Engi-
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Engineering Research Laboratory. Cincinnati.OH. April
1988.
USEPA. 199 la. Guides to pollution prevention: the
automotive repair industry. Prepared by Jacobs Engi-
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Cincinnati, OH. EPA/625/7-91/013.
USEPA 199 Ib. Guides to pollution prevention: the fiber
glass-reinforced and composite plastics industry. Pre-
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Environmetal Protection Agency, Office of Research
and Development. Cincinnati, OH. EPA/625/7-91/014.
18
-------
USEPA 199 Ic. Guides to pollution prevention: the automo
five refinishing industry. Prepared by Jacobs Engineer-
ing Group Inc. for the U.S. Environmental Protection
Agency, Office of Research and Development Cincin-
nati, OH. EPA/625/7-91/016.
Yaraschak, P. J. 1989. Hazardous waste minimization-
making it happen. AIChE National Conference. Wash
ington, D. C. December 4-5,1989.
Zagrobelny, T. J. 1987. Hazardous waste minimization by
the U. S. Navy. In: Proceedings of the National Confer-
ence on Hazardous Wastes and Hazardous Materials.
Washington, D. C. March 16-18,1987. p.335.
19
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-------
Section 4
Waste Minimization Assessment Worksheets
The worksheets provided in this section are intended to
assist marine maintenance and repair yards in systematically
evaluating waste generating processes and in identifying
waste minimization opportunities. These worksheets include
only the waste minimization assessment phase of the proce-
dure described in The Waste Minimization Opportunity As-
sessment Manual. A comprehensive waste minimization
assessment includes a planning and organizational step, an
Table 5. List of Wast Mimization Assessment Worksheets
assessment step that includes garnering background data and
information, a feasibility study on specific waste minimiza-
tion options, and an implementation phase. For a full descrip-
tion of waste minimization assessment procedures, refer to
the manual. Table 5 lists the worksheets included in this
section. After completing the worksheets, the assessment
team should evaluate the applicable waste minimization
options and develop an implementation plan.
No. Title
Descriptions
la. Waste Sources
Ib. Waste Sources
2a. Waste Minimization: Material Handling
2b. Waste Minimization: Material Handling
3. Option Generation: Material Handling
4a. Waste Minimization: Parts Cleaning
4b. Waste Minimization: Parts Cleaning
5. Option Generation: Parts Cleaning
6a. Waste Minimization: Waste Handling
6b. Waste Minimization: Waste Handling
7. Option Genration: Waste Handling
8a. Waste Minimization: Material Substitution
8b. Wste Minimization: Substitution
9. Option Generation: Material Substitution
10. Waste Minimization: Good Operating Practices
11. Option Generation: Good Operating Practices
Wastes generated from shop and parts clean-up.
Wastes generated by maintenance shops.
Questionnaire on material handling techniques.
Questionnaire on material handling.
Waste minimization options for material handling.
Questionnaire on procedures uscsd for parts cleaning.
Questionnaire on procedures us«:d for parts cleaning.
Waste minimization options for parts cleaning.
Questionnaire on waste handling operations.
Questionnaire on waste handling operations
Waste minimization options for waste hadling
Questionnaire for material substitution.
Questionnaire for material substitution.
Waste minimization options for material substitution.
Questionnaire on good operating practices
Waste minimization options that are good operating practices
21
-------
Firm
Site
Data
WORKSHEET
1a
Shop
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet of
Paae of
WASTE SOURCES
Clean-up
obgojatwaw matftrj^
^pllls Ik lofk*5 (lki||M
-------
Firm
Site
Date
WORKSHEET
1b
Waste Minimization Assessment
Prnj No
Prepared By
Checked By
Sheet c
r ••
f Paae of
WASTE SOURCES
Maintenance Shop Wastes
Motor oil
Oil filters
Gear and lube oils
Transmission fluid
Brake fluid
Radiator coolant
Gasoline
Brakes (asbestos)
Radiators (lead)
Batteries (lead & acid)
Junk parts
_ Abrasive paint stripping wastes
Organic chemical stripping wastes
Inorganic chemical stripping wastes
Paint overspray
Electroplating wastes
Fiberglass fabrication (solvent) wastes
Fiberglass fabrication (gelcoat) wastes
Fiberglass roving/chopping dusts
Significance at Plant
Low
Medium
High
23
-------
•irm.
Site .
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet of Page of
WORKSHEET
2a
WASTE MINIMIZATION:
Material Handling
A. DRUMS, CONTAINERS, AND PACKAGES
Are drums, packages and containers inspected for damage before being accepted? Q yes Q no
Are employees trained in ways to safely handle the types of drums and packages received? Q yes Q no
Are they properly trained in handling of spilled raw materials? Q yes Q no
Is there a formal personnel training program on raw material handling, spill prevention
proper storage techniques, and waste handling procedures?
Describe handling procedures for damaged items:.
Q yes Q no
How often is training given and by whom?_
Is obsolete raw material returned to the supplier?
Is inventory used in first-in first-out order?
Is the inventory system computerized?
Does the current inventory control system adequately prevent waste generation?
What information does the system track? —
Q yes
Q 'yes
Q yes
Q yes
Q no
Q no
Q no
Q no
Are stored items protected from damage, contamination, or exposure to rain,
snow, sun and heat?
Is the dispensing of raw materials supervised and controlled?
Are users required to return empty containers before being issued new supplies?
Do you maintain and enforce a clear policy of using raw materials only for their
intended use?
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
24
-------
Firm.
Site .
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked Ely
Sheet__of Page Of
WORKSHEET
2b
WASTE MINIMIZATION:
Material Handling
B. BULK LIQUIDS HANDLING
What safeguards are in place to prevent spills and avoid ground contamination during the filling of storage tanks?
High level shutdown/alarms Q
Flow totalizers with cutoff Q
Secondary containment Q
Other Q
Describe the system:.
Are air emissions from solvent storage tanks controlled by means of:
Conservation vents
Nitrogen blanketing
Absorber/Condenser
Other vapor loss control system
Q yes
Q yes
Q yes
Cl yes
Q no
Q no
Q no
Q no
Describe the system:.
Are all storage tanks routinely monitored for leaks? If yes, describe procedure and monitoring frequency for
above-ground/vaulted tanks: =
Underground tanks:-
How are the liquids in these tanks dispensed to the users? (i.e., in small containers or hard piped.).
What measures are employed to prevent the spillage of liquids being dispensed ?-
When a spill of liquid occurs in the facility, what cleanup methods are employed (e.g., wet or dry)? Also discuss the way
in which the resulting wastes are handled:
25
-------
Sita
Date
WORKSHEET
3
Waste Minimization Assessment
Proi No
Prepared By
Checked By
Sheet Page of
of
OPTION GENERATION:
Material Handling
Meeting Format (e.g., brainstorming, nominal group technic
Meeting Coordinator
Meeting Participants
ii m)
Suggested Waste Minimization Options
A. Qrums, Contalners,_andjaackaaes
Raw MateriaLlnspection
Proper Storage/Handling
ReturrtObsoIete Materiailo Suoolier
MinimizeJnventory
Compijleijze Inventory
Formal Training
Waste Segregation
B. Bulk Liquids Handlina
High 1 .evel Shutdown/Alarm
Flow Totalizers with Cutoff
Secondary Containment
Air Emission Control
Leak ^Monitoring
Currently
Done Y/N?
Rationale/Remarks on Option
26
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Firm
Site
Data
Waste Minimization Assessment
Proj. No.
WORKSHEET
WASTE MINIMSZATION:
43 Parts Cleaning
A. SOLVENTS
Do you use parts cleaning solvent for uses other than cleaning parts?
Have you established guidelines as to when parts should be cleaned with solvents?
Do you use solvent sinks instead of pails or dunk buckets?
Are solvent sinks and/or buckets located near service bays?
Prepared Bv
Checked Bv
Sheet of Page of
G yes G no
G yes Q no
G yes G no
G yes G no
Do you allow cleaned parts to drain inside the sink for a few minutes to minimize
dripping of residual solvent onto the shop floor?
Q yes G no
Are you careful when immersing and removing parts from the solvent bath so as
not to create splashes?
Do you keep all solvent sinks/buckets covered when not in use?
Do you lease your solvent sinks?
If yes, does your lease include solvent supply and spent solvent waste handling?
G yes G no
G yes G no
G yes G no
* Q yes G no
If you own your solvent sinks, does a registered waste hauler collect your dirty solvent
for recycling or treatment?
Do you own on-srte solvent recovery ei
If yes, how are the solvent residues ha
juipment such as a distillation unit?
nritaH?
G yes G no
G yes G no
What other methods are you using to r<
aduce solvent use/waste?
B. AQUEOUS CLEANERS
Do you use dry pre-cleaning methods such as baking and/or wire brushing to reduce
loading on the aqueous cleaner?
Have you switched from caustic-based
G yes G no
cleaning solutions to detergent-based cleaners? G yes Q no
Do you use drip trays on hot tanks to minimize the amount of cleaner dripped on the floor? Q yes Q no
27
-------
Firm-
Site.
Date.
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet of ^Page of
WORKSHEET
4b
WASTE MINIMIZATION:
Parts Cleaning
B. AQUEOUS CLEANERS (continued)
Are the hot tanks/jet spray washers located near the service bays?
Do you pre-rinse dirty engine parts in a tank of dirty cleaning solution so as to reduce
loading on the clean tank?
Do you routinely monitor solution composition and make adjustment accordingly?
Do you routinely remove sludge and solids from the tank?
Are slodge and solids screened out before they reach the waste sump?
Do you use demineralized water for your cleaning bath make-up ?
Have you installed still rinses or converted free running rinses to still rinses? Spent rinse
water can be used as make-up to your cleaner bath if you use demineralized water.)
Is your cleaning tank agitated?
If yes, do you use mechanical agitation instead of air agitation?
Do you lease your hot tank(s)/jet spray washer(s)?
Do you own your hot tanks/jet spray washer(s)?
Do you own on-site aqueous waste treatment equipment?
Does a hazardous waste hauler collect aqueous waste for recycling or treatment?
If not, how is your waste handled and disposed of? _
Q yes G no
Q yes
G yes
G yes
G yes
G yes
G yes
G yes
Q "yes
G yes
G yes
G yes
G yes
Q no
Q no
Q no
Q no
G no
G no-
Q no
Q no
G no
G no
G no
Q no
28
-------
Firm
fiite
Dato
WORKSHEET
5
Waste Minimization Assessment
Proj. No.
Prepared E3v
Checked By
Sheet «f Page nf
OPTION GENERATION:
Parts Cleaning
Meeting Format (e.g., brainstorming, nominal group techn
Meeting Coordinator
Meeting Participants
Icue)
Suggested Waste Minimization Options
A. Solvents
Proper solvent use
Established guidelines
Use solvent sinks
Careful drainage
Cover tanks
Lease equipment/service
Recycle solvent
8. Aqueous Cleaners
Dry pre-cleaning
Use detergents
Drip trays
Pre-rinse parts
Monitor solution
Remove sludge and solids
Employ still rinse
Use demineralized water
Use mechanical agitation
Lease equipment
Currently
Done Y/N?
Rationale/Remarks on Option
29
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Firm Waste Minimization Assessment F
Site C
rtala Pro]- No. 5
WORKSHEET WASTE MINIMIZATION:
03 Waste Handling
A. ENGINE, LUBRICATING AND COOLING FLUIDS
Do you test fluid quality, including engine, lubricating and cooling fluids, to determin
they should be changed?
When fluids must be drained either to requalify in the case of turbine oils or service
they stored in a clean container so they may be used to refill the turbine or recycle t
Have you had experience using any longer lasting synthetic motor, lubricating and <
fluids?
If yes, please explain:
Do you currently employ rigid inventory controls to minimize fluid use?
Do you have a waste turbine oil and /or coolant management program in place?
Ifyas plaasa discuss:
Are all waste fluids kept segregated?
If no, have you notified your waste hauler or recycler?
Have you ever had a load of waste fluid rejected by a hauler or recycler because o
cross contamination?
Please describe how you store and dispose of waste fluids (motor and lube oils, gr
B. PAINT APPLICATION
Do you generate large quantities of waste paint or thinner?
Do you currently employ rigid inventory controls to minimize material use?
"repared By
Checked By
Sheet of Pace of
.
e when
Q yes Q no
a part, are
he oil? Q yes Q no
:ooling
Q yes . Q no
Q yes Q no
Q yes Q no
Q yes Q no
Q yes Q no
f
Q yes Q no
eases,
Q yes Q no
Q yes Q no
30
-------
Firm Waste Minimization Assessment F
Site C
Date Proi- No- £
WORKSHEET
£. WASTE MINIMIZATION:
OD Waste Handling
B. PAINT APPLICATION (continued)
Discuss how implementing more rigid controls could be accomplished in your shop:
'repared 13v
Checked Elv
Jheet of Paqe of
Are paints mixed according to need? Is the volume of paint mixed based on the surface
area to be painted? G yes G no
Does the design of your mixing equipment prevent you from mixing smaller batches of paint? G yes G no
If specialized mixing equipment procedures were available for mixing smaller batches of paint:,
would you use them? G yes G no
Have you tried high efficiency spray application equipment in your shop? G yes G no
Did it reduce the amount of paint sprayed? G yes G no
Did it affect finish quality? G yes G no
Descibe how you minimize overspray waste.
C. OTHER WASTES
Does a battery collector remove your used batteries?
, .s
Do you take used batteries to a storage or recycling facility?
Does a recycler or equipment leasing service collect your spent antifreeze?
Do you use a collection/recycling system to service air conditioning units?
Do you sell or give worn parts to a re-manufacturer?
Do you have any suggestions for reducing other wastes?
G yes G no
G yes G no
G yes G no
G yes G no
G yes G no
31
-------
Firm
CttA
WORKSHEET
7
Waste Minimization Assessment
Prnj Wn
Prepared By
Checked By
Sheet of Page of
OPTION GENERATION:
Waste Handling
Meeting Format (e.g., bralnstormlng, nominal group technl
Meeting Coordinator
Moving Participants
que)
Suggested Waste Minimization Options
A. Waste Oils and Coolants
Test fluid quality
Store fluids for reuse
Use longer lasting fluids
Keep wastes segregated
Send torecyder
B. Paint Applications
Use rigid inventory controls
Mix smaller batches of paint
Use high-efficiency sprayer
Minimize overspray
C. Other Wastes
Drain filters and dispose properly
Recycle batteries
Collect asbestos dust
Collect/recycle refrigerant
Sell or give parts to re-manufacturer
Currently
Done Y/N?
Rationale/Remarks on Option
32
-------
Firm Waste Minimization Assessment f
Site <;
Date Proi. No. .«
WORKSHEET WASTE MINIMIZATION:
O 3 Material Substitution
A. ABRASIVE BLASTING
Is the blasting media used in the shop considered hazardous (e.g., lead shot)?
If so, can other lesser/non-hazardous materials be substituted?(e.g. plastic media)
Describe results of any substitution attempts:
'repared By
Checked Bv
Sheet of Paqe of
Q yes G no
Q yes G no
Are dust suppression/collection systems employed during abrasive blasting?
Is this dust collected and recycled or reused?
Would the installation of a dust collection system allow for reuse?
Explain how blasting dusts are handled and the potential for reuse:
Q yes G no
G yes Q no
Q yes G no
B. CHEMICAL STRIPPING
Are any chemical stripping agents used in tr
-------
Firm
Site
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet of Page of.
WORKSHEET
8b
WASTE MINIMIZATION:
Material Substitution
C. PAINTING OPERATIONS
Have attempts been made to maximize water-based paints (e.g., for interior painting
application)?
Have you tried substituting water-based for solvent-based paints?
Have attempts been made to substitute paints with lower VOC emissions?
Are non-toxic paints available in the market?
Can you use non-toxic paints where anti-fouling paints are not required?
Describe the results of attempts to substitute paints: , ,
Q yes
Q yes
Q yes
Q yes
a yes
3 no
3 no
Q no
a no
Q no
34
-------
Firm Waste Minimization Assessment
Sito
Date Proj. No.
Prepared By
Checked Ru
Sheet of page r,f
WORKSHEET ^_
Q OPTION GENERATION:
S/ Material Substitution
Meeting Format (e.g., bralnstormlng, nominal group technique)
Meeting Coordinator
Meeting Participants
Suggested Waste Minimization Options
A. Paint Removal
Blasting media substitution
Substitute blasting for chemical stripping
Less hazardous strippers
B. Painting Operation
Use low VOC paints
Use less toxic paints
Maximize use of water-based paints
Currently
Done Y/N?
Rationale/Remarks on Option
35
-------
Rrrn.
Site.
Date.
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet of Page of.
WORKSHEET
10
WASTE MINIMIZATION:
Good Operating Practices
A. GOOD OPERATING PRACTICES
Are plant material balances routinely performed?
Are they performed for each material of concern (e.g. solvent) separately?
Are records kept of Individual wastes with their sources of origin and eventual disposal?
Are the operators provided with detailed operating manuals or instruction sets?
Are all operator Job functions well defined?
Are regularly scheduled training programs offered to operators?
Are there employee Incentive programs related to waste minimization?
Does the plant have an established waste minimization program in place?
If yes, Is a specific person assigned to oversee the success of the program?
Discuss goals of the program and results: ___
Q yes
Q yes
Q yes
Q yes
G yes
D yes
Q yes
Q yes
Q yes
a
a
a
a
a
a
a
'a
a
no
no
no
no
no
no
no
no
no
Has a waste minimization assessment been performed at this plant in the past? If yes, discuss:
B. HOUSEKEEPING
Are dirty parts removed and placed on a drip pan instead of directly on the shop floor?
Are all work areas kept clean and neat?
Do your workers wipe up small spills of fluid as soon as they occur?
Do you have an award program for workers who keep their work areas clean
(I.e.: prevent leaks and spills)?
Do you use a laundry service to clean your rags and uniforms?
Do you use a biodegradable detergent for cleaning shop floors?
Have you tried using a steam cleaner In place of chemical cleaners?
Do you discharge area washdown wastewater to a POTW or industrial sewer,
Instead of to the storm drain?
If no, how Is this waste handled?
Q yes Q no
a yes Q no
Q yes a no
Q yes a no
Q yes Q no
Q yes Q no
Q yes Q no
a yes Q no
36
-------
Firm Waste Minimization Assessment
Site
Date Proj.No.
Prpnsrwl Ru
Checked By
Sheet of Page of
WORKSHEET ^ „
1-f OPTION GENERATION:
B I Good Operating Practices
Meeting Format (e.g., brainstorm ing, nominal group techn
Meeting Coordinator
ique)
Meeting Participants
Suggested Waste Minimization Options
Perform Material Balances
Keep Records of Waste Sources & Disposition
Waste/Materials Documentation
Provide operaing Manuals/Instructions
Employee Training
Increased Supervision
Provide Employee Incentives
Increase Plant Sanitation
Establish Waste Minimization Policy
Set Goals for Source Reduction
Conrinrt Annual Assa.Qamants
Use Drip Pans
Wipe up Spills (Cotton Rags, Paper To we I IK)
Keep Bays Clean
Award Program
Use Laundry Service
Use Biodegradible Detergents
. Use Steam Cleaners
Discharqe to POTW/lndustrlal Sewer
Currently
Done Y/N?
Rationale/Remarks on Option
37
-------
Appendix A
Marine Maintenance and Repair
Yards Assessments
Case Studies of Yards A, B, and C
Case Studies of Marine Maintenance and
Repair Facilities
In 1987 the California Department of Health Services
commissioned a wasteminimization study (Calif. DHS1987)
of three marineyards. The objectives of the waste minimiza-
tion assessments were to:
• Gather site-specific information concerning the
generation, handling, storage, treatment, and dis-
posal of hazardous waste;
• Evaluate existing waste reduction practices;
• Develop recommendations for waste reduction
through source control, treatment, and recycling
techniques; and
• Assess costs/benefits of existing and
recommended waste reduction techniques.
Initially, several marine maintenance and repair yards
were contacted to solicit voluntary participation in the audit
study. Plant selection emphasized small businesses which
generally lack the financial and/or internal technical re-
sources to perform a wastereduc tion assessment. A relatively
large yard was also selected for study because it offered the
opportunity to evaluate a wide variety of maintenance and
repair services, as well as a number of in-place waste reduc-
tion measures. Three yards were assessed.
This Appendix presents summary results of the assess-
ments of the yards here identified as A, B, and C and the
potentially useful waste minimization options identified
through the assessments. Also included are the practices
already in use at the yards that have successfully reduced
waste generation from past levels. During each of the marine
maintenance and repair yard assessments, the assessment
team observed the operations; inspected waste management
facilities; interviewed the yard manager, environmen|al com-
pliance personnel, and operations supervisors; and reviewed
and copied records pertinent to waste generation and man-
agement.
The original assessments may be obtained from:
Mr. Benjamin Fries
California Department of Health Services
Alternative Technology Division
Toxic Substances Control Program
714/744 P Street
Sacramento, CA 94234-7320
(916) 324-1807
In addition, the results of the waste assessments were
used to prepare waste minimization assessment worksheets
to be completed by other marineyards in self- assessment.
Examples of completed worksheets follow the assessment
for Company C.
Summary of Waste Minimization Assessment
for Company A
Introduction
Company A is a small-sized business in the marineyard
maintenance and repair industry employing six to 12 full-
time workers. Approximately 15 ships per year are serviced
on one marine rail way dry dock and a nearby pier. The largest
service contracts are supply boats reaching a length of 185
feet, however, the average vessel serviced is approximately
125 feet in length. Maintenance work is limited to sandblast-
ing, painting, welding, and shaft and propeller repairs; engine
repair work is performed by subcontractors. The yard's pier
and marine railway serve as a general ship servicing area,
while the remainder of the yard contains two large structures
used for equipment storage, a plastics shop, a machine shop,
two paint storage vaults, and a number of smaller shops. The
machine shop has been used intermittently for several years.
The company does not have a formal waste minimization
program.
Raw Materials Usage
Raw materials used in this yard include epoxy and vinyl
primers, antifouling paints, and thinners used for painting
and parts cleaning. Paint coatings are applied with airless
spray guns. Small amounts of muriatic acid are stored in the
machine shop and are used for cleaning. Boat hulls are
38
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routinely washed down with chlorine bleach. Minor volumes
of lubricating and cutting oils are used in the machine shop
and other workshops.
Waste Generation
Waste generation rates at this small yard are relatively
low. Exact volumes of individual waste streams could not be
determined due to the lack of adequate inventory control. For
most painting jobs, paints, thinners and other hazardous
materials are ordered by the client with delivery directly to
the shipyard. After project completion, excess paint supplies
are normally returned to the owner of the vessel.
Thinners kept at the yard are reused until spent. Open
cans containing waste thinner were observed during inspec-
tion of the paint storage vaults. When the thinner becomes too
contaminated to be used for brush and parts cleaning, it is
stored in a 1,400-gallon aboveground tank. This tank is on
paved ground immediately east of the main equipment stor-
age area. Waste oils generated on site are deposited here as
well. The tank is old and was observed to be open to the
atmosphere. Several times per year, the liquid waste mixture
is pumped out by a waste hauler/recycler. Waste sludge
accumulates at the bottom of the tank. Surface spills around
the tank are usually adsorbed with beach sand.
Sandblasting takes place immediately above the marine
railway dock, which is in direct contact with the water in the
harbor. Ships are positioned onto the submerged end of the
dock and are winched onto the railways and into the yard.
Washed beach sand is used as the sandblasting medium.
Resulting fines, consisting of sand and paint, accumulate at
the bottom of the railway. Every 6 months, approximately 20
cubic yards of sand are dug out by hand. Ocean tidal action
washes part of the waste material fines into the harbor.
Recommendations
Suggestedrecommendationsfor waste reduction atCom-
pany A are outlined below.
Housekeeping
1. Segregation of Wastes. Wastes generated from simi-
lar unit processes should be segregated (e.g., paint thinners,
waste solvents, waste kerosene, bilge wastes, etc.). Segrega-
tion of waste types facilitates reclamation. A separate con-
tainer should be maintained for each waste type. Only waste
oils should be stored in the 1,400-gallon aboveground tank.
A separate 55-gallon drum should be used for the storage of
all thinner wastes.
2. Use of Lids on Drums. Tight-fitting lids should be
used on all waste storage containers to prevent evaporation
loss of volatile substances such as paint thinner. Funnels and
pumps should be used to transfer wastes from small to large
containers to prevent spillage.
3. Spill Containment. Areas used for the storage of
hazardous materials and wastes (particularly the 1,400- gal-
lon storage tank) should be bermed to contain any spills that
may occur.
4. Inventory Control. More stringent inventory control
practices should be maintained. Inventory should be kept to
a minimum. Paints maintained in storage should be used
before fresh or unopened paints to minimize the possibility
that they will solidify and require disposal in the future. If
paints in storage cannot be used for final coats, perhaps they
may be used as undercoats.
5. Use ofTarps. Tarps should be used during sandblast-
ing operations to prevent the off-site; migration of grit, which,
unless controlled with tarps, could v/ash away with the tide to
contaminate sediment Sandblast grit should then be re-
moved on a periodic basis, preferably at the end of each
blasting operation.
6. Manifests. Copies of manifests from the past disposal
of hazardous waste could not be produced during the assess-
ment. The importance of a proper waste tracking system
cannot be overemphasized. Moreover, it is the responsibility
of the yard owner or operator to provide proper documenta-
tion regarding the types and volumes of hazardous wastes
generated, and the disposal or reclamation practices utilized
for those wastes.
Off-Site Reclamation
1. Solvent Reclamation Services. There are several ser-
vices available which offer full service, from the purchase of
paints and thinners to the disposal of waste materials. For
convenience, a service such as this may be feasible for both
the purchase and disposal of waste materials.
2. Paint Gun Cleaning. At least one solvent recycling
company provides a self-contained paint gun cleaning unit
that reuses thinner for the cleaning of paint application guns
and other painting equipment. Periodically, the unit is ser-
viced by the company, and spent thinners are replaced with
new material. Wastes are then hauled away by the company.
This service minimizes the possibility for solvents to be
managed improperly, extends the useful life of the solvent,
and ensures that wastes are reclaimed. Some recycling ser-
vices also provide parts washers for operations in which
recycled solvents are used for degnsasing.
3. Waste Exchanges. Waste exchanges may be outlets
for selling surplus or leftover paint.
On-Site Reclamation
1. Collection of Thinner Wastes. As discussed above,
thinners and solvents should be collected in a single con-
tainer. Under quiescent conditions within the drum, the
sludge settles on the bottom, leaving the reusable solvent at
39
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the surface. The solvent can then be decanted from the drum
and reused for cleaning equipment or for other uses where a
high-quality material is notneeded. This process can be used
to extend the life of thinner and reduce the quantity of
hazardous waste generated by the facility.
2. Distillation of Spent Solvents. On-site distillation can
be used to recover spent solvents. There are several commer-
cial distillation units that are available for commercial appli-
cation.
3. On-Site Separation of Bilge Wastes. On-site treatment
of bilge wastes will reduce the volume of wastes hauled from
the yard. Oil can be separated from waste water using an oil/
water separator. The water can then be sewered and the
concentrated oil disposed of through a reclamation facility.
Product Substitution
1. Substitutionfor Solvent-Based Paints. At the present
time, there are paintmanufacturers which offerawater-based
paint as a substitute for solvent-based paints. Water-based
paints are less volatile and the equipment used to apply the
paints can be cleaned using water instead of solvents. The
rinsategenerated from cleaning is generally sewerable. Hence,
it is advantageous to maximize the use of water-based paints
as an alternate to solvent-based paints.
2. Hand Scraping. Wherever practical, hull surfaces
should be prepared for painting by hand scraping rather than
by sandblasting. The higher labor cost of hand scraping may
be offset by the savings in waste management costs. Air-
powered mechanical vibrating scrapers may be a viable
alternative.
Summary of Waste Minimization Assessment
for Company B
Introduction
Company B is a medium-sized operation in the
marineyard maintenance and repair industry. Depending on
business, the yard employs 25 to 100 workers. Approxi-
mately 80 percent of all projects are derived from a master
ship repair contract with the United States Navy, which
requires in part the removal and disposal of all hazardous
wastes on board all vessels. Over 10 naval vessels per year are
serviced either at the boat shop or the nearby naval shipyard.
Only ships up to 200 feet in length are serviced at the boat
shop. The shipyard is bound under contract to utilize paints
which meet Navy requirements. In addition, paints are typi-
cally ordered directly by the owner of the ship for delivery at
the shipyard.
Two large and one smaller marine railway dry docks and
a 1,000-ton floating dry dock are used for ship maintenance
and repair. In addition, three piers are used for boat storage
and servicing. The remainder of the yard consists of a
machine shop, welding shop, pipe fitter's shop, carpenter's
shop, sheds for painting and equipment storage, and several
administrative offices.
Raw Materials Usage
Raw materials used at this yard include epoxy thinners,
epoxy and vinyl paints, several solvents, and a variety of oils.
The epoxy thinners and paints are utilized in painting. The
paints are applied with airless spray guns. Paint usage is
approximately 2,000 gallons per year. Since the bulk of the
paints and thinners is supplied by the boat owners, some
paints are stored in a metal shed. Excess paints are either
returned to the ship owners or stored and used for touch-up
jobs.
Cleaning solvents, such as kerosene and paint thinner,
are utilized in the machine and pipe fitter's shop for parts
cleaning at a rate of approximately 55 gallons per month.
Waste solvents are stored in 55-gallon drums. Cutting, lubri-
cating, and hydraulic oils are each used in the various shops
at rates of approximately 5 gallons per year.
Waste Materials
The majority of hazardous liquid wastes is generated in
conjunction with ship cleaning and painting operations. Ap-
proximately 15,000 gallons of contaminated water are annu-
ally removed from ship bilges, double bottoms, and tank
bottoms. This wastewater contains varying amounts of oils,
greases, solvents, and sludges. These liquids are pumped
directly from the vessels into a waste hauler's tank truck.
Asbestos-containing materials (ACMs) are removed from
those sections of Navy ships that are serviced. Abatement
procedures adhere to strict government standards. Approxi-
mately 20 pounds of ACM are generated monthly. ACMs are
double bagged and stored in an on-site container provided by
a certified abatement contractor.
Another waste stream is generated in the machine/pipe
fitting shop. A 250-gallon sump serves as a catch basin for
waste oils and solvents and steam cleaning wastes. In addi-
tion, a 200-gallon per day holding tank is located on paved
ground between the shop area and the piers. This aboveground
tank is often used to store contaminated water and waste
solvents. Contents of the sump and day holding tank are
pumped out by a waste hauler after the bilge wastes have been
removed from a vessel anchored at the pier. While the
hazardous waste manifest provided by the disposal contrac-
tor specifies the total amount of waste removed, it does not
quantify the volumes of waste obtained from the sump or the
day holding tank.
Paint wastes are generated at a rate of about 50 gallons
per month and consist of waste thinners, spent solvents, and
paint pigments. A 55-gallon drum located near the paint shop
serves as a waste storage container. Empty paint cans are left
exposed to the atmosphere for a minimum of 24 hours before
they are crushed and disposed of as rubbish.
Exterior hull cleaning operations are performed on the
marine railways. Barnacles and algae are hand-scraped fol-
lowed by a sand or water blast. Some of the sandblasting
wastes get swept into the harbor during washdowns.
40
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Recommendations
Suggestedrecommendations for waste reduction atCom-
pany B are outlined below.
Housekeeping
1. Segregation of Wastes. Wastes generated from similar
unit processes should be segregated (e.g., paint thinners,
waste solvents, waste kerosene, bilge wastes, etc.). Segrega-
tion of waste types facilitates reclamation. A separate con-
tainer should be maintained for each waste type.
2. Inventory Control. More stringent inventory control
practices should be maintained. Paints maintained in storage
should be used before newer paints to minimize the possibil-
ity that they will solidify and require disposal in the future. If
stored paints cannot be used for final coats, they can possibly
be used as undercoats. *
3. Thinner Waste Collection and Reuse. Spent thinners
used for cleaning of painting equipment should be collected
in a single 55-gallon container. The thinner will separate,
with the paint sludge settling on the bottom. The clear thinner
on the top can then be decanted and reused.
4. Use ofTarps. Tarps should be used during sandblast-
ing operations to prevent the off-site migration of grit. Sand-
blast grit should then be removed on a periodic basis, prefer-
ably at the end of each blasting.
Off-Site Reclamation '
1. Solvent Reclamation Service. Currently, there are
several services available that provide paints and thinners
and also provide a solvent reclamation service.
, 2. Paint Gun Cleaning. At least one recycler provides a
self-contained paint gun cleaning unit which reuses thinner.
Periodically, the unit is serviced by the company, and spent
thinners are replaced with new material; wastes are then
hauled away by the company. Some vendors also provide
parts washers for operations in which solvents are used for
degreasing.
3., Waste Exchange. Waste exchanges may be an outlet
for selling surplus or leftover paint.
Oii-Site Reclamation
1, Collection of Thinner and Solvent Wastes.' As dis-
cussed aTbove, thinners and solvents should be collected in a
single drum and allowed to separate under quiescent condi-
tions. The clear thinner can then be reused for cleaning
operations.
2. Distillation of Spent Solvents. On-site distillation can
be used to recover spent solvents. There are several commer-
cial distillation units which are available for commercial
application.
3. On-Site Separation of Bilge Wastes. On-site treatment
of bilge wastes will reduce the volume of wastes hauled from
the yard. Oil can be separated from waste using an oil/water
separator. The water can then be sewered and the concen-
trated oil disposed of by a reclamation facility. '
4. Recover and Reuse Blasting Medium. Blasting me-
dium should be recovered and reused. A cyclonic separator
can be used to separate paint chips from blasting grit
Summary of Waste Minimization Assessment
for Company C .
Introduction •
Company C is representative of a small- to medium-
sized marine shipyard. It services recreational boats, and
performs all boat-related maintenance work such as painting,
sandblasting, fiberglassing, and engine, shaft, and rudder
repair. Approximately 500 boats and yachts up to 52 feet in
length are serviced at this yard annually. The yard has an
administrative office building that also houses a retail store
for boat parts and accessories. Attached to this building are a
machine shop and an engine repair shop. Near this structure
is a wooden shack used for the storage of 55-gallon drums of
polyester resin, lacquer thinner, acetone, and waste solvent).
Another storage shed is located near the pier and houses 55-
gallon drums of lubricating and hydraulic oil. At the pier, a
travel lift, which is anchored, is us3d to hoist the boats onto
the yard where most of the maintenance work is performed.
Raw Materials Usage
Many different raw materials are used at this yard. Paints
and lacquer thinners are utilized for painting operations.
Approximately 3 gallons of copper-based antifouling paint
are used per day, and thinners are used at a rate of about 5
gallons per month. Leftover paint is stored and applied on
touch-up jobs. Polyester resin utilized for fiberglass boat
repair is consumed at a rate of approximately 200 gallons per
year, and acetone and lacquer thinner at rates of 50 and 450
gallons per year, respectively. Acetone is used to wipe down
boat surfaces and remove moisture before paint application.
Lacquer thinner is typically utilized for the removal of
overspray and wax from painted surfaces.
In the machine and engine repair shops, a closed system
cleaning solvent bath has been installed and is used for
degreasing machine and engine parts. A recycling service
picks up 30 gallons of spent solvent each month. Hydraulic
and lubricating oils are consumed at rates of 50 and 100
gallons per year, respectively.
Waste Materials
Several hazardous waste streams are generated at this
yard. Solvent and thinner wastes are produced at a rate of
approximately 80 gallons per year. Much of the acetone and
lacquer thinner is lost due to evaporation during boat surface
preparation. The remainder is stonsd in a 55-gallon waste
41
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solvent drum, which is picked up by a hazardous waste
contractor every 6 months.
A second solvent waste stream is generated in the ma-
chine and engine repair shop. The shop is equipped with a
solvent bath utilized for parts and tool cleaning. A waste
solvent recycling service picks up about 20 gallons of spent
solvent per month and replaces it with fresh solvent This
parts cleaning method minimizes solvent loss due to spillage
and evaporation.
Waste oils are generated at approximately 20 gallons per
month as a result of engine maintenance operations. The
waste oil is stored in drums and is taken to a local service
station once monthly, old boat batteries are sold to a battery
shop for recycling. Empty paint cans are stored on site, until
the residual paint has dried, and are then discarded as rubbish.
Recommendations
Sugges tedrecommendations for waste reduction atCom-
pany C are outlined below.
Housekeeping
The housekeeping practices at this yard are, for the most
part, excellent There are, however, several hazardous waste
management practices that can be implemented to improve
those practices.
1. Manifests. Copies of manifests from the past
disposal of hazardous waste could not be produced during
the assessments. The importance of a proper waste
tracking system cannot be overemphasized.
2. Inventory Control. Although it appears that inventory
is tightly controlled at this facility, additional practices may
be implemented to minimize the volume of hazardous waste
generated. The quantity of paint required to complete a job is
often less than the volume of paintpurchased. Paint that is left
over is stored in the original sealed containers and used for
touch-up as needed in future jobs.
It is possible that a paint which is left unused over a
period of time will eventually dry. Since many of these paints
are metal-based, they should be disposed of as a hazardous
waste. Waste (or spent) paints should therefore be collected
and saved for disposal as a hazardous waste. It is recom-
mended that spent paints be collected in a single drum for
reclamation or disposal. In order to minimize the volume of
hazardous waste generated, spent paints can be used for base
coats or in other applications where appearance is not impor-
tant
On-Site Reclamation
1. Separation of Solvent/Thinner Wastes. At present,
thinners and solvents used to clean paint application equip-
ment are collected and stored in a 55-gallon drum. Periodi-
cally, this drum is hauled off site by a registered hazardous
waste hauler.
Under the quiescent conditions within the drum,
separation occurs with the sludge settling to the bottom
and reusable solvent at the surface, which can be decanted
from the drum and reused for cleaning equipment This
process can be used to extend the life of thinner and reduce
the quantity of hazardous waste generated by the facility.
2 . Distillation. Distillation can be used to treat solvent
and thinner wastes. Distillation units that can be used to
reclaim spent solvents are commercially available. A high-
quality thinner or solvent that can be reused is recovered from
the unit The remaining sludge is then managed as a hazard-
ous waste. The economics of on-site distillation and recovery
of solvent or thinner may be comparable to the costs associ-
ated with the purchase of new thinner and the disposal of
spent materials.
Off-Site Reclamation
1. Paint Gun Cleaning Services. At least one recycler
offers a paint gun cleaning service similar in principle to the
parts washing service. A self-contained paint gun cleaner is
provided to the customer. Periodically, thinner within the
cleaner is removed and replaced with clean material. This
service minimizes the possibility for solvents to be managed
improperly, extends the useful life of the solvent, and ensures
that wastes are reclaimed.
2. Solvent Reclamation Services. There are several
companies that offer full service from the purchase of paints
and thinners to the disposal of waste materials. For conve-
nience, a service such as this may be feasible for both the
purchase and disposal of waste materials.
Product Substitution
1. Substitute Water-Based Paints. There are paint manu-
facturers which offer water-based paint as a substitute for
solvent-based paints. Water-based paints are less volatile and
the equipment used to apply the paints can be cleaned using
water instead of solvents. The rinsate generated from clean-
ing is generally sewerable. Hence, it is advantageous to
maximize the use of water-based paints as an alternate to
solvent-based paints.
42
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pirm Waste Minimization Assessment
Site
Date Proi. No.
WORKSHEET
-|g WASTE SOURCES
ShopClean-Up
Obsolete raw materials
Spills & leaks (llaulds)
Spills (powders)
Dirty rags
Used sawdust
Area wash water
Clarlfler sludges
Container disposal (metal)
Container disposal (paper/plastic)
Pipeline/tank drainaae
Evaporative losses
Other
Parts Cleaning
Spent solvent cleaner
Spent carburetor cleaner
Spent brake cleaner
Evaporative losses
Leaks and spills (solvents)
Spent alkaline cleaner
Leaks and spills (alkali)
Rinse water discharge
Sludges
Filter waste
Prepared Bj
Checked By
Sheet , Q
f. Page of
Significance at Plant
Low
X
X
X
X
X
X
X
y
Medium
X
X
x
X
X
x
y
y
X
x
X
V
High
43
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Firm
Sito
WORKSHEET
1b
Mafntenar
Waste Minimization Assessment
(
Prnj Nn <
'repared By
Checked By
Sheet of
Paae of
WASTE SOURCES
ice Shoo Wastes
Motor oil
Oil filters
Gear and lube oils
Transmission fluid
-Brake-fkrid- Vot- applicable
Radiator coolant
Gasoline
- Brakes .'asbestosV-- M>^ 6/pl>ct*l>le>
Radiators (lead)
Batteries (lead & acid)
Junk parts
Abrasive paint stripping wastes
Organic chemical stripping wastes
Inorganic chemical strlpplna wastes
Paint oversprav
Electroplating wastes
Fiberglass fabrication (solvent) wastes
Fiberglass fabrication (gelcoat) wastes
Fiberglass roving/chopping dusts
Enwf +hinn
-------
pjrm Waste Minimization Assessment p
Site C
Pate ^OJ- N°- S
o WASTE MINIMIZATION:
•^3 Material Handling
repared By
hacked By
heet of Page of
A. DRUMS, CONTAINERS, AND PACKAGES
Are drums, packages and containers inspected for damage before being accepted? Ja yes Q no
Are employees trained in ways to safely handle the types of drums and packages received? M yes Q no
Are they properly trained in handling of spilled raw materials? j^ yes Q no
Is there a formal personnel training program on raw material handling, spill prevention
proper storage techniques, and waste handling procedures? Q yes X no
Describe handling procedures for damaged items: 1? veaefor"
How often is training given and by whom? ?Jeu> t)>rff /S "fr
-------
Firm.
Site .
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet of Page of.
WORKSHEET
2b
WASTE MINIMIZATION:
Material Handling
B. BULK LIQUIDS HANDUNG
What safeguards are in place to prevent spills and avoid ground contamination during the filling of storage tanks?
High level shutdown/alarms Q
Flow totalizers with cutoff Q
Secondary containment X
Other Q
Describe the system:.
Are air emissions from solvent storage tanks controlled by means of:
Conservation vents
Nitrogen blanketing
Absorber/Condenser
Other vapor loss control .system
Q yes
Q yes
Q yes
Q yes
A no
X no
X no
flu no
Describe the system:-
Are all storage tanks routinely monitored for leaks? If yes, describe procedure and monitoring frequency for
above-ground/vaultedtanks:
Underground tanks:
How are the liquids in these tanks dispensed to the users? (i.e., in small containers or hard piped.) h
What measures are employed to prevent the spillage of liquids being dispensed?-
When a spill of liquid occurs in the facility, what cleanup methods are employed (e.g., wet or dry)? Also discuss the way
in which the resulting wastes are handled: ^°^«* ** *** */j ^J *#«** ** "
Sr&-. —
46
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Firm Waste Minimization Assessment
Site
Dat« Prnj. No.
WORKSHEET OPTION GENERATldN
3 Material Handling
Prepared By
Checked By
Sheet Of Page of
iS '
Meeting Format (e.g., bralnstorming, nominal group technique)
Meeting Coordinator
Meeting Participants
Suggested Waste Minimization Options
A. Drums, Containers, and Packages
Raw Material Inspection
Proper Storage/Handling
Return Obsolete Material to Supplier
Minimize Inventory
Computerize Inventory
Formal Training
Waste Segregation
B. Bulk Liquids Handling
High Level Shutdown/Alarm
Flow Totalizers with Cutoff
Secondary Containment
Air Emission Control
Leak Monitoring
Currently
Done Y/N?
V
y
Y
y
A/
/s/
y
A;
A/
A)
^
/
Rationale/Remarks on Option
S»m& Soppltdrs uoaV- Accffl'
Ord*r ftith as neffdeJl
J>»ae /irV/ru/A/
?!&» ^ /rt^// mere kfrrtS
47
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Firm.
Site .
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet of Page of_
WORKSHEET
4a
WASTE MINIMIZATION:
Parts Cleaning
A. SOLVENTS
Do you use parts cleaning solvent for uses other than cleaning parts?
Have you established guidelines as to when parts should be cleaned with solvents?
Do you use solvent sinks instead of pails or dunk buckets?
Are solvent sinks and/or buckets located near service bays?
Do you allow cleaned parts to drain inside the sink for a few minutes to minimize
dripping of residual solvent onto the shop floor?
Are you careful when immersing and removing parts from the solvent bath so as
not to create splashes?
Do you keep all solvent sinks/buckets covered when not in use?
Do you tease your solvent sinks?
If yes, does your lease include solvent supply and spent solvent waste handling?
If you own your solvent sinks, does a registered waste hauler collect your dirty solvent
for recycling or treatment?
Do you own on-site solvent recovery equipment such as a distillation unit?
If yes, how are the solvent residues handled?
What other methods are you using to reduce solvent use/waste?
B.
AQUEOUS CLEANERS
Do you use dry pre-cteaning methods such as baking and/or wire brushing to reduce
loading on the aqueous cleaner?
Have you switched from caustic-based cleaning solutions to detergent-based cleaners?
Do you use drip trays on hot tanks to minimize the amount of cleaner dripped on the floor?
Q yes
Q yes
M yes
TS_! yes
]Sf yes
yes
yes
yes
yes
33. no
^f no
Q no
Q no
Q no
Q no
a no
Q no
Q no
Q yes Q no
Q yes J& no
Q yes }3 no
H yes Q no
Q yes JE( no
48
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Firm-
Site _
Date-
Waste Minimization Assessment
Proj. No.
Prepared E3y .
Checked Ely ,
Sheet of __ Page of.
WORKSHEET
4b
WASTE MINIMIZATION:
Parts Cleaning
B. AQUEOUS CLEANERS (continued)
Are the hot tanks/jet spray washers located near the service bays? ]£( yes Q no
Do you pre-rinse dirty engine parts in a tank of dirty cleaning solution so as to reduce
loading on the clean tank? Q yes j!l no
Do you routinely monitor solution composition and make adjustment accordingly? fit yes Q no
Do you routinely remove sludge and solids from the tank? TsC yes Q no
Are sludge and solids screened out before they reach the waste sump? Q yes ^ no
Do you use demineralized water for your cleaning bath make-up ? Q yes Sf no
Have you installed still rinses or converted free running rinses to still rinses? Spent rinse
water can be used as make-up to your cleaner bath if you use demineralized water.) Q yes £3 no
Is your cleaning tank agitated? 13 yes Q no
If yes, do you use mechanical agitation instead of air agitation? Q yes 121 no
Do you leas® your hot tank(s)/jet spray washer(s)? T2f yes G no
Do you own your hot tanks/jet spray washer(s)? Q yes jSf no
Do you own on-site aqueous waste treatment equipment? J2. yes Q no
Does a hazardous waste hauler collect aqueous waste for recycling or treatment? ^ yes Q no
If not, how is your waste handled and disposed of?
49
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_. Waste Minimization Assessment
eiff,
nntn Proi, Mn
Prepared By
Checked By
Sheet of Page of
WORKSHEET OPTION GENERATION:
Q Parts Cleaning
Mooting Format (e.g., bralnstormlng, nominal group technl
Mooting Coordinator
due) vfttifiSTOrmin^
Mating Participants
Suggested Waste Minimization Options
A. Solvents
Proper solvent use
Established guidelines
Use solvent sinks
Careful drainage
Cover tanks
Lease equipment/service
Recycle solvent
B. Aqueous Cleaners
Dry pre-cleaning
Use detergents
Drip trays
Pre-rinse parts
Monitor solution
Remove sludge and solids
Employ still rinse
Use demineralized water
Use mechanical agitation
Lease equipment
Currently
Done Y/N?
Y
A/
Y
y
Y
Y
y
M
y
A)
*J
y
y
A/
N
Kl
AJ
Rationale/Remarks on Option
Kft/nen rhvfj urtfe up these.
fJteJ -to set*i*J u^ef leers
Pane. l>y c.*»fr**t&~
HeeJ ife .
Alr&Jit 0WI "US
50
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Firm
Site
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked EJy
Sheet of Page __ of
WORKSHEET
6a
WASTE MINIMIZATION:
Waste Handling
A. ENGINE, LUBRICATING AND COOLING FLUIDS
Do you test fluid quality, including engine, lubricating and cooling fluids, to determine when
they should be changed?
Q yes
When fluids must be drained either to requalify in the case of turbine oils or service a part, are
they stored in a clean container so they may be used to refill the turbine or recycle the oil? Q yes
Have you had experience using any longer lasting synthetic motor, lubricating and cooling
fluids? Q.yes
If yes, please explain: _____
Do you currently employ rigid inventory controls to minimize fluid use?
Do you have a waste turbine oil and /or coolant management program in place?
Q yes
Q yes
If yes, please discuss:
no
no
no
no
no
Are all waste fluids kept segregated?
If no, have you notified your waste hauler or recycler?
Have you ever had a load of waste fluid rejected by a hauler or recycler because of
cross contamination?
Q yes J^T no
]Sf yes Q no
Q yes JSf
no
Please describe how you store and dispose of waste fluids (motor and lube oils, greases,
transmission fluids and spent anti freezes). All *>n$te$ arc. ^ ttfy &. ce^mmt f-*«k +«J ht,u/t
-------
Firm
Site
Date
Waste Minimization Assessment
Praj. No.
Prepared By
Checked By
Sheet of Page of.
WORKSHEET
6b
WASTE MINIMIZATION:
Waste Handling
B. PAINT APPLICATION (continued)
Discuss how implementing more rigid controls could be accomplished in your shop: M>f
Are paints mixed according to need? Is the volume of paint mixed based on the surface
area to be painted?
yes Q no
Does the design of your mixing equipment prevent you from mixing smaller batches of paint? Q yes
If specialized mixing equipment procedures were available for mixing smaller batches of paint,
would you use them?
Have you tried high efficiency spray application equipment in your shop?
Did it reduce the amount of paint sprayed?
Did it affect finish quality?
Descibe how you minimize overspray waste..
Q yes
Q yes
Q yes
Q yes
t)ou> 6 i>S&
no
no
Q no
Q no
C. OTHER WASTES
Does a battery collector remove your used batteries?
Do you take used batteries to a storage or recycling facility?
Does a recycler or equipment leasing service collect your spent antifreeze?
Do you use a collection/recycling system to service air conditioning units?
Do you sell or give worn parts to a re-manufacturer?
Do you have any suggestions for reducing other wastes?
S yes
Q yes
Q yes
Q yes
Q yes
Q no
H no
.& no
ft no
fa no
52
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Firm
Site
WORKSHEET
7
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet Of Paqe of
OPTION GENERATION:
Waste Handling
Meeting Format (e.g., bralnstorming, nominal group techn
Meeting Coordinator
Meeting Participants
Ique) Mr&. infhrrr*)
Suggested Waste Minimization Options
A. Waste Oils and Coolants
Test fluid quality
Store fluids for reuse
Use longer lasting fluids
Keep wastes segregated
Send to recycter
B. Paint Applications
Use rigid inventory controls
Mix smaller batches of paint
Use high-efficiency sprayer
Minimize overspray
C. Other Wastes
Drain filters and dispose property
Recycle batteries
Collect asbestos dust
Collect/recycle refrigerant
Sell or give parts to re-manufacturer
Currently
Done Y/N?
*J
N!
A/
M
*f
N/
rJ
fJ
V
V
.Y
Y
tf
w
Rationale/Remarks on Option
&vlj cJ[J &s « sewce.
A/of e*ovfli hjutbfi/
dt>f firmer $p£CihfS }~ltJta$
Skotflc* Itok IATV /M
-------
Firm Waste Minimization Assessment F
Sita C
Date Pro). No. S
WORKSHEET WASTE MINIMIZATION:
O3 Material Substitution
A. ABRASIVE BLASTING
Is the blasting media used in the shop considered hazardous (e.g., lead shot)?
If so, can other lesser/non-hazardous materials be substituted?(e.g. plastic media)
Describe results of any substitution attempts:
'repared By
Checked By
Jheet of Page of
Q yes J2^ no
Q yes Q no
Are dust suppression/collection systems employed during abrasive blasting?
!s this dust collected and recycled or reused?
Would the installation of a dust collection system allow for reuse?
Explain how blasting dusts are handled and the potential for reuse: CollechJ &*
flaf &c,5 no
Q yes IzC no
Q yes JSQ no
J Uu/fel e#. fattse. fS
B. CHEMICAL STRIPPING
Are any chemical stripping agents used in the shops considered hazardous
(e.g. chlorinated solvents)?
If so, can other non-hazardous materials substitute for the hazardous materials?
Describe results of any substitutution attempts: &*? not fes-faa oHterS
$( yes Q no
Q yes Q no
Can plastic media blasting or water-jet stripping be used as a substitute stripping operation? ]2i yes Q no
Has chemical stripping using a smaller volume of stripper been attempted to reduce
overall spent stripping solutions? Q yes 3. no
Describe the results of attempts to use smaller volumes of stripping agent:
54
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Firm
Site
Date
Waste Minimization Assassmant
Proj. No.
Prepared By
Checked By
Sheet of Page of
WORKSHEET
8b
WASTE MINIMIZATION:
Material Substitution
C. PAINTING OPERATIONS
Have attempts been made to maximize water-based paints (e.g., for interior painting
application)?
Have you tried substituting water-based for solvent-based paints?
Have attempts been made to substitute paints with lower VOC emissions? $
Are non-toxic paints available in the market? ft
Can you use non-toxic paints where anti-fouling paints are not required? $3
Describe the results of attempts to substitute paints: Hast h-lk ft each cvsfamcs- ttvotn
M( yes
Q yes
E& yes
£& yes
yes
Q no
pi no
G no
Q no
Q no
•fie, type. /
55
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_. Waste Minimization Assessment
CJfr.
n-ifi* Pro! No,
PraparaH Ry
r.hacktvi By
Shsflt . of „ , , Pag*^ ftf
WORKSHEET OPTION GENERATION:
9 Material Substitution
Meeting Format (e.g., bralnstormlng, nominal group techn
Mating Coordinator
Ique)
Moating Participants
Suggested Waste Minimization Options
A. Paint Removal
Blasting media substitution
Substitute blasting for chemical stripping
Less hazardous strippers
B. Painting Operation
Use low VOC paints
Use less toxic paints
Maximize use of water-based paints
Currently
Done Y/N?
M
Y
Y
y
V
V
Rationale/Remarks on Option
S*«e) is cke.tif>
tfst ntSS ttke* pr6.ckctj
•
56
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pirm Waste Minimization Assessment
Site
Date Prni Wo
WORKSHEET WASTE MINIMIZATION:
"1 0 Good Operating Practices
Pfopqiwl Py ,
Checked By
Sheet of Page of
A. GOOD OPERATING PRACTICES
Are plant material balances routinely performed? Q yes X no
Are they performed for each material of concern (e.g. solvent) separately? a ves -^C no
Are records kept of individual wastes with their sources of origin and eventual disposal? ^ ves >^C no
Are the operators provided with detailed operating manuals or Instruction sets? J* ves a no
Are all operator job functions well defined? & yes Q no
Are regularly scheduled training programs offered to operators? a yes X no
Are there employee Incentive programs related to waste minimization? At Ves Q no
Does the plant have an established waste minimization program in place? <§ Ves a no
If yes, is a specific person assigned to oversee the success of the program? X ves Q no
Discuss goals of the program and results: JuS't" 5"ha»H'€
-------
... Waste Minimization Assessment
Sitn
Date Proj No
Prepared By
Checked By
Sheet of Page of
WORKSHEET OPTION 6|NERATION:
1 1 Good Operating Practices
Meeting Format (e.g., bralnstormlng, nominal group technl
Meeting Coordinator
mm) Ava«'*vs-h>rroiAci
I ' "^ Q
Meeting Participants
Suggested Waste Minimization Options
A. General
Perform Material Balances
Keep Records of Waste Sources & Disposition
Waste/Materials Documentation
Provide Operating Manuals/Instructions
Employee Training
Increased Supervision
Provide Employee Incentives
Increase Plant Sanitation
Establish Waste Minimization Policy
Set Goals for Source Reduction
Set Goals for Recycling
Conduct Annual Assessments
Use Drip Plans
Wipe up Spills (cotton rags, paper towels)
Keep Bays Clean
Award Program
Use Laundry Service
Use Biodegradable deteraents
Use Steam Cleaners
DIscharae to POTW/lndustrlal Sewer
Currently
Done Y/N?
ti
hi
r
Y
Y
H
r
Y
^
N
|4
Y
r
r
N
r
Y
A/
/
Rationale/Remarks on Option
Wani&H'S on\<-i
•J
Mot ngti/a^-ly ^ch«J^«dI
jjave r\ot mcr^ased
W ill CansiJer Jetlih^ ^als
u •» '» "
Co^/»«i«*"^ "t/\»S
/^«^r all AvTeAS Jo ~hiw Y\o»A
Varies Awong 5^o.^>S
"fT»»*s ^hi K*lp Viou$e^fl?pinQ
vj 1 SJ
58
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Appendix B
Where to Get Help
Further Information on Pollution Prevention
Additional information on source reduction, reuse and
recycling approaches to pollution prevention is available in
EPA reports listed in this section, and through state programs
and regional EPA offices (listed below) that offer technical
and/or financial assistance in the areas of pollution preven-
tion and treatment.
Waste exchanges have been established in some areas of
the U.S. to put waste generators in contact with potential
users of the waste. Twenty-four exchanges operating in the
U.S. and Canada are listed.
U.S. EPA Reports on Waste Minimization
Waste Minimization Opportunity Assessment Manual. EPA/
625/7-88/003.***
Waste Minimization Audit Report: Case Studies of Corrosive
and Heavy Metal Waste Minimization Audit at a Specialty
Steel Manufacturing Complex. Executive Summary. NTIS
No. PB88 -107180*
Waste MinimizationAuditReport: Case Studies of Minimiza-
tion of Solvent Waste for Parts Cleaning and from Electronic
Capacitor Manufacturing Operation. Executive Summary.
NTIS No. PB87 - 227013*
WasteMinimizationAuditReport:CaseStudiesofMinimiza-
tion of Cyanide Wastes from Electroplating Operations.
Executive Summary. EPA No. PB87 -229662.*
Report to Congress: Waste Minimization, Vols. I and II. EPA/
530-SW-86-033and-034Washington,D.C.:U.S.EPA,1986.**
Waste Minimization - Issues and Options, Vols. I-III EPA/
530-SW-86-041 through -043. Washington, D.C.:
U.S.EPA.1986.**
* Executive Summary available from EPA, CERI, Publications
Unit, 26 West Martin Luther King Drive, Cincinnati, OH,
45268; full report available from the National Technical Infor-
mation Service (NTIS), U.S. Department of Commerce,
Springield, VA 22161.
** Available from the National Technical Information Service as
a five volume set, NTIS NO. PB-87-114-328.
*** Available from EPA, CERI, Publications Unit, 26 West Martin
Luther King Drive, Cincinnati, OH 45268, (513) 569-7562.
The Guides to Pollution Prevention manuals*** de-
scribe waste minimization options for specific industries.
This is a continuing series which currently includes the
following titles:
Guides to Pollution Prevention Paint Manufacturing Indus-
try. EPA/625/7-90/005.
Guides to Pollution Prevention The Pesticide Formulating
Industry. EPA/625/7-90/004.
Guides to Pollution Prevention The Commercial Printing
Industry. EPA/625/7-90/008.
Guides to Pollution Prevention The FabricatedMetal Indus-
try. EPA/625/7-90/006.
Guides to Pollution Prevention For Selected Hospital Waste
Streams. EPA/625/7-90/009.
Guides to Pollution Prevention Research and Educational
Institutions. EPA/625/7-90/010.
Guides to Pollution Prevention The Printed Circuit Board
Manufacturing Industry. EPA/625/7-90/007.
Guides to Pollution Prevention The Pharmaceutical Indus-
try. EPA/625/7-91/017.
Guides to Pollution Prevention The Photoprocessing Indus-
try. EPA/625/7-91/012.
Guides to Pollution Prevention The Fiberglass Reinforced
and Composite Plastic Industry. EPA/625/7-91/014.
Guides to Pollution Prevention The. Automotive Repair In-
dustry. EPA/625/7-91/013.
Guides to Pollution Prevention The Automotive Refinishing
Industry. EPA/625/7-91/016.
U.S. EPA Pollution Prevention Info;rmation Clearing House
(PPIC): Electronic Information Exchange System (EIES) -
User Guide, Version 1.1. EPA/600/9-89/086
59
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Waste Reduction Technical/ Financial
Assistance Programs
The EPA Pollution Prevention Information Clearing-
house (PPIC) was established to encourage waste reduction
through technology transfer, education, and public aware-
ness. PPIC collects and disseminates technical and other
information about pollution prevention through a telephone
hotline and an electronic information exchange network.
Indexed bibliographies and abstracts of reports, publications,
and case studies about pollution prevention are available.
PPIC also lists a calendar of pertinent conferences and
seminars; information aboutactivities abroad and a directory
of waste exchanges. Its Pollution Prevention Information
Exchange System (PIES) can be accessed electronically 24
hours a day without fees.
For more information contact:
PIES Technical Assistance
Science Applications International Corp.
8400 Westpark Drive
McLean, VA 22102
(703) 821-4800
or
U.S. Environmental Protection Agency
401 M Street S.W.
Washington, D. C. 20460
Myles E. Morse
Office of Environmental Engineering
and Technology Demonstration
(202)475-7161
Priscilla Flattery
Pollution Prevention Office
(202) 245-3557
The EPA's Office of Solid Waste and Emergency Re-
sponse has a telephone call-in service to answer questions
regarding RCRA and Superfund (CERCLA). The telephone
numbers are:
(800) 242-9346 (outside the District of Columbia)
(202) 382-3000 (in the District of Columbia)
The following programs offer technical and/or financial
assistance for waste minimization and treatment.
Alabama
Hazardous Material Management and Resources Recovery
Program
University of Alabama
P.O. Box 6373
Tuscaloosa, AL 35487-6373
(205) 348-8401
Alaska
Alaska Health Project
Waste Reduction Assistance Program
431 West Seventh Avenue, Suite 101
Anchorage, AK 99501
(907) 276-2864
Arkansas
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501) 371-1370
California
Alternative Technology Division
Toxic Substances Control Program
California State Department of Health Services
714/744 P Street
Sacramento, CA 94234-7320
(916) 324-1807
Connecticut
Connecticut Hazardous Waste Management Service
Suite 360
900 Asylum Avenue
Hartford, CT 06105
(203) 244-2007
Florida
Waste Reduction Assistance Program
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904)488-0300
Georgia
Hazardous Waste Technical Assistance Program
Georgia Institute of Technology
Georgia Technical Research Institute
Environmental Health and Safety Division
O'Keefe Building, Room 027
Atlanta, GA 30332
(404) 894-3806
Environmental Protection Division
Georgia Department of Natural Resources
Floyd Towers East, Suite 1154
205 Butler Street
Atlanta, GA 30334
(404)656-2833
Guam
Solid and Hazardous Waste Management Program
Guam Environmental Protection Agency
IT & E Harmon Plaza, Complex Unit D-107
130 Rojos Street
Harmon. Guam 96911
(671) 646-8863
60
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Illinois
Hazardous Waste Research and Information Center
Illinois Department of Energy and Natural Resources
One East Hazelwood Drive
Champaign, IL 61820
(217) 333-8940
Illinois Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Alumni Building, Room 102
Illinois Institute of Technology
3200 South Federal Street
Chicago, IL 60616
(313)567-3535
Indiana
Environmental Management and Education Program
Young Graduate House, Room 120
Purdue University
West Lafayette, IN 47907
(317) 494-5036
Indiana Department of Environmental Management
Office of Technical Assistance P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317) 232-8172
Iowa
Center for Industrial Research and Service
205 Engineering Annex
Iowa State University Ames, IA 50011
(515) 294-3420
Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
Des Moines, IA 50319-0034
(515) 281-8690
Kansas
Bureau of Waste Management
Department of Health and Environment
Forbesfield, Building 730
Topeka, KS 66620
(913) 269-1607
Kentucky
Division of Waste Management
Natural Resources and Environmental Protection
Cabinet
18 Reilly Road
Frankfort, KY 40601
(502) 564-6716
Louisiana
Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 44307
Baton Rouge, LA 70804
(504) 342-1354
Maryland
Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200 A
Annapolis, MD 21401
(301)974-3432
Maryland Environmental Service
2020 Industrial Drive
Annapolis, MD 21401
(301)269-3291
(800) 492-9188 (in Maryland)
Massachusetts
Office of Technical Assistance
Executive Office of Environmental Affairs
100 Cambridge Street, Room 1094
Boston, MA 02202
(617) 727-3260
Source Reduction Program
Massachusetts Department of Environmental Protection
1 Winter Street
Boston, MA 02108
(617) 292-5982
Michigan
Resource Recovery Section
Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
(517) 373-0540
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612) 296-6300
Minnesota Technical Assistance Program
1313 5th Street S.E., Suite 207
Minneapolis, MN 55414
(612) 627-4555 (800)
247-0015 (in Minnesota)
Missouri
State Environmental Improvement and
Energy Resources Agency
P.O. Box 744
Jefferson City, MO 65102
(314)751-4919
New Hampshire
New Hampshire Department of Environmental Services
Waste Management Division
6 Hazen Drive
Concord, New Hampshire 03301-6509
(603) 271-2901
61
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New Jersey
New Jersey Hazardous Waste Facilities Siting Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609) 292-1459
(609) 292-1026
Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
(609) 292-8341
Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
(609) 984-6070
New York
New York State Environmental Facilities Corporation
50 Wolf Road
Albany, NY 12205
(518) 457-3273
North Carolina
Pollution Prevention Pays Program
Department of Natural Resources
and Community Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611
(919) 733-7015
Governor's Waste Management Board
325 North Salisbury Street
Raleigh, NC 27611
(919) 733-9020
Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Raleigh, NC 27602
(919) 733-2178
Ohio
Division of Solid and Hazardous Waste Management
Ohio Environmental Protection Agency
P.O. Box 1049
1800 WaterMark Drive
Columbus, OH 43266-1049
(614)481-7200
Oklahoma
Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK 73152
(405) 271-7353
Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204
(503) 229-5913
Pennsylvania
Pennsylvania Technical Assistance Program
501F. Orvis Keller Building
University Park, PA 16802
(814) 865-0427
Center of Hazardous Material Research
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
Bureau of Waste Management
Pennsylvania Department of Environmental Resources
P.O. Box 2063
Fulton Building
3rd and Locust Streets
Harrisburg, PA 17120
(717) 787-6239
Rhode Island
Office of Environmental Coordination
Department of Environmental Management
83 Park Street
Providence, RI 02903
(401) 277-3434
(800) 253-2674 (in Rhode Island)
Center for Environmental Studies
Brown University
P.O. Box 1943
135 Angell Street
Providence, RI 02912
(401) 863-3449
Tennessee
Center for Industrial Services
102 Alumni Hall
University of Tennessee
Knoxville.TN 37996
(615) 974-2456
Virginia
Office of Policy and Planning
Virginia Department of Waste Management
11th Floor, Monroe Building
101 North 14th Street
Richmond, VA 23219
(804) 22572667
Washington
Hazardous Waste Section
Mail Stop PV-11
Washington Department of Ecology
Olympia, WA 98504-8711
(206) 459-6322
62
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Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, WI53707
(608) 267-3763
Wyoming
Solid Waste Management Program
Wyoming Department of Environmental Quality
Herschler Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7752
Waste Exchanges
Alberta Waste Materials Exchange
Mr. William C. Kay Alberta Research Council
Post Office Box 8330
Postal Station F
Edmonton, Alberta CANADA T6H 5X2
(403) 450-5408
British Columbia Waste Exchange
Ms. Judy Toth
2150 Maple Street
Vancouver, B.C. CANADA V6J 3T3
(604) 731-7222
California Waste Exchange
Mr. Robert McCormick
Department of Health Services
Toxic Substances Control Program
Alternative Technology Division
Post Office Box 942732
Sacramento, CA 94234-7320
(916)324-1807
Canadian Chemical Exchange*
Mr. Philippe LaRoche
P.O. Box 1135
Ste-Adele, Quebec
CANADA JORILO
(514)229-6511
Canadian Waste Materials Exchange
ORTECH International
Dr. Robert Laughlin
2395 Speakman Drive
Mississauga, Ontario
CANADA L5KIB3
c(416) 822-4111 (Ext. 265)
FAX: (416) 823-1446
Enstar Corporation*
Mr. J.T. Engster
P.O. Box 189
Latham, NY 12110
(518) 785-0470
Great Lakes Regional Waste Exchange
400 Ann Street N.W., Suite 204
Grand Rapids, MI 49504
(616) 363-3262
Indiana Waste Exchange
Dr. Lynn A. Corson
Purdue University School of Civil Engineering
Civil Engineering Building
West Lafayette, IN 47907
(317) 494-5036
Industrial Materials Exchange
Mr. Jerry Henderson
172 20th Avenue
Seattle, WA 98122
(206) 296-4633
FAX: (206) 296-0188
Industrial Materials Exchange Service
Ms. Diane Shockey
Post Office Box 19276
Springfield, IL 62794-9276
(217) 782-0450
FAX: (217) 524-4193
Industrial Waste Information Exchange
Mr. William E. Payne
New Jersey Chamber of Commerce
5 Commerce Street
Newark, NJ 07102
(201) 623-7070
Manitoba Waste Exchange
Mr. James Ferguson
c/o Biomass Energy Institute, Inc.
1329 Niakwa Road
Winnipeg, Manitoba
CANADA R2J 3T4
(204)257-3891
Montana Industrial Waste Exchange
Mr. Don Ingles
Montana Chamber of Commerce
P.O. Box 1730
Helena, MT 59624
(406) 442-2405
New Hampshire Waste Exchange
Mr. Gary J. Olson
c/oNHRRA
P.O. Box 721
Concord, NH 03301
(603) 224-6996 ;
Northeast Industrial Waste Exchange, Inc.
Mr. Lewis Cutler
90 Presidential Plaza, Suite 122
Syracuse, NY 13202
(315)422-6572
FAX: (315) 422-9051
For-Profit Waste Information Exchange
63
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Ontario Waste Exchange
ORTECH International
Ms. Linda Varangu
2395 Speakman Drive
Mississauga, Ontario
CANADA L5K IBS
(416) 822-4111 (Ext. 512)
FAX: (416) 823-1446
Pacific Materials Exchange
Mr. Bob Smee
South 3707 Godfrey Blvd.
Spokane, WA 99204
(509) 623-4244
Peel Regional Waste Exchange
Mr. Glen Milbury
Regional Municipality of Peel
10 Peel Center Drive
Brampton, Ontario
CANADA L6T4B9
(416) 791-9400
RENEW
Ms. Hope Castillo
Texas Water Commission
Post Office Box 13087
Austin, TX 78711-3087
(512)463-7773
FAX: (512) 463-8317
San Francisco Waste Exchange
Ms. Portia Sinnott
2524Benvenue#35
Berkeley, CA 94704
(415) 548-6659
Southeast Waste Exchange
Ms. Maxie L. May
Urban Institute
UNCC Station
Charlotte, NC 28223
(704) 547-2307
Southern Waste Information Exchange
Mr. Eugene B. Jones
Post Office Box 960
Tallahassee, FL 32302
(800) 441-SWDC (7949)
(904) 644-5516
FAX: (904) 574-6704
Tennessee Waste Exchange
Ms. Patli Christian
226 Capital Blvd., Suite 800
Nashville, TN 37202
(615)256-5141
FAX: (615) 256-6726
Wastelink, Division of Tencon, Inc.
Ms. Mary E. Malotke
140 Wooster Pike
Milford,OH45150
(513)248-0012
FAX: (513) 248-1094
U.S. EPA Regional Offices
Region 1 (VT, NH, ME, MA, CT, RI)
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3715
Region 2 (NY, NJ)
26 Federal Plaza
New York, NY 10278
(212) 264-2525
Region 3 (PA, DE, MD, WV, VA)
841 Chestnut Street
Philadelphia, PA 19107
(215)597-9800
Region 4 (KY, TN, NC, SC, GA, FL, AL, MS)
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727
Region 5 (WI, MN, MI, IL, IN, OH)
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000
Region 6 (NM, OK, AR, LA, TX)
1445 Ross Avenue
Dallas, TX 75202
(214) 655-6444
Region 7 (NE, KS, MO, IA)
756 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2800
Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2405
(303) 293-1603
Region 9 (CA, NV, AZ, HI) 75
Hawthorne Street
San Francisco, CA 94105
(415)744-1305
Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-5810
64
•&U.S. GOVERNMENT PRINTING OFFICE: 1994 - 550-001/80348
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