Office Of ;:Vil'k ;-; « ft;j;
International Activilief
(2660) ^.^fX;^m
                               Ehforcemeint And ".V
                               CompliariQe- Assurance ,
                                   '     • ' "
EPA31P-R-97-008
September 1997
               Shipbuilding and
               Repair Industry

"!-«'SisS
  NOTEBOOKS
               EPA Office jOf Compliance Sector Notebook Project

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460
                                           f 8  /997
                                                                         THE ADMINISTRATOR
Message from the Administrator

Since EPA's founding over 25 years ago, our nation has made tremendous progress in protecting
public health and our environment while promoting economic prosperity. Businesses as large as
iron and steel plants and those as small as the dry cleaner on the corner have worked with EPA to
find ways to operate cleaner, cheaper and smarter.  As a result, we no longer have rivers catching
fire. Our skies are clearer. American environmental technology and expertise are in demand
around the world.

The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.

The Environmental Protection Agency has undertaken its Sector Notebook Project to compile,
for major industries, information about environmental problems and solutions, case studies and
tips about complying with regulations. We called on industry leaders, state regulators, and EPA
staff with many years of experience in these industries and with their unique environmental issues.
Together with an extensive series  covering other industries, the notebook you hold in your hand is
the result.

These notebooks will help business managers to understand better their regulatory requirements,
and learn more about how others in their industry have achieved regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.

I encourage you to use this notebook to  evaluate and improve the way that we together achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that — hi industry after industry, community after community —
environmental protection and economic prosperity  go'.
                                               Carol M. Browner,
            Rtcycltd/RtcyclaM* 'Printed with Vegetable Ol Based Inks on 100% Recycled Paper (40% Postconsumer)

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Shipbuilding and Repair Industry
Sector Notebook Project
                                                                EPA/310-R-97-008
             EPA Office of Compliance Sector Notebook Project:

      PROFILE OF THE SHIPBUILDING AND REPAIR INDUSTRY
                                 November 1997
                               Office of Compliance
                   Office of Enforcement and Compliance Assurance
                       U.S. Environmental Protection Agency
                           401 M St., SW (MC 2221-A)
                              Washington,  DC 20460
                            For sale by the U.S. Government Printing Office
                     Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
                                ISBN 0-16-049400-1

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Shipbuilding and Repair Industry
Sector Notebook Project
This report is one in a series of volumes published by the U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors.  The documents were developed under contract by Abt Associates
(Cambridge, MA), Science Applications International Corporation (McLean, VA), and Booz-
Allen & Hamilton, Inc. (McLean,  VA). This publication may be purchased from the
Superintendent of Documents, U.S. Government Printing Office. A listing of available Sector
Notebooks and document numbers is included at the end of this document.

All telephone orders should be directed to:

      Superintendent of Documents
      U.S. Government Printing Office
      Washington, DC 20402
      (202)512-1800
      FAX (202) 512-2250
      8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be directed to:

       U.S. Government Printing Office
       P.O. Box 371954
       Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and
academic libraries, Federal, State, and local governments, and the media from EPA's National
Center for Environmental Publications and Information at (800) 490-9198.  For further
information, and for answers to questions pertaining to these documents, please refer to the
contact names and numbers provided within this volume.
Electronic versions of all Sector Notebooks are available via Internet on the Enviro$en$e World
Wide Web. Downloading procedures are described in Appendix A of this document.
Cover photograph courtesy of Ingalls Shipbuilding Inc., Pascagoula, MS.
Sector Notebook Project
         November 1997

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 Shipbuilding and Repair Industry
                                                           Sector Notebook Project
                                 Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance.  Questions relating to
the Sector Notebook Project can be directed to:

Seth Heminway, Coordinator, Sector Notebook Project
US EPA Office of Compliance
401  M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017

Questions and comments regarding the individual documents can be directed to the appropriate
specialists listed below.
Document Number
EPA/310
EPA/310.
EPA/310.
EPA/310.
EPA/310-
EPA/310-
EPA/310.
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310.
EPA/310.

EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310.
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
•R-95-001.
-R-95-002.
•R-95-003.
•R-95-004.
•R-95-005.
•R-95-006.
•R-95-007.
-R-95-008.
•R-95-009.
-R-95-010.
-R-95-011.
-R-95-012.
-R-95-013.
-R-95-014.
-R-95-015.
-R-95-016.
-R-95-017.
-R-95-018.

-R-97-001.
-R-97-002.
-R-97-003.
-R-97-004.
-R-97-005.
-R-97-006.
-R-97-007.
-R-97-008.
-R-97-009.
-R-97-010.
            Industry

Dry Cleaning Industry
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.

Air Transportation Industry
Ground Transportation Industry
Water Transportation Industry
Metal Casting Industry
Pharmaceuticals Industry
Plastic Resin and Manmade Fiber hid.
Fossil Fuel Electric Power Generation Ind.
Shipbuilding and Repair Industry
Textile Industry
Sector Notebook Data Refresh, 1997
   Contact

Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Jane Engert
Anthony Raia
Jane Engert
Robert Lischinsky
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop

Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Anthony Raia
Belinda Breidenbach
Seth Heminway
Phone (202)

  564-7073
  564-7007
  564-7021
  564-7067
  564-7027
  564-7017
  564-7013
  564-5021
  564-6045
  564-5021
  564-2628
  564-7067
  564-7003
  564-7072
  564-7016
  564-7027
  564-7013
  564-7057

  564-7057
  564-7057
  564-7057
  564-5021
  564-7071
  564-7074
  564-7028
  564-6045
  564-7022
  564-7017
Sector Notebook Project
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                                                      November 1997

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                 SHIPBUILDING AND REPAIR INDUSTRY
                                   (SIC 3731)
                           TABLE OF CONTENTS


LIST OF FIGURES	vii

LIST OF TABLES 	vii

LIST OF ACRONYMS	 viii

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT  	1
      A.  Summary of the Sector Notebook Project	1
      B. Additional Information	2

II. INTRODUCTION TO THE SHIPBUILDING AND REPAIR INDUSTRY  	3
      A. Introduction, Background, and Scope of the Notebook  	3
      B. Characterization of the Shipbuilding and Repair Industry  	3
             1.  Product Characterization	3
             2.  Industry Size and Geographic Distribution	6
             3.  Economic Trends	9

III.  INDUSTRIAL PROCESS DESCRIPTION	13
      A. Industrial Processes in the Shipbuilding and Repair Industry	13
             1.  Shipyard Layout 	13
             2.  Docking and Launching Facilities	14
             3.  Ship Construction Processes  	16
             4.  Major Production Facilities  	18
             5.  Welding	19
             6.  Ship Repairing Processes	20
             7.  Support Shops and Services	21
             8.  Solvent Cleaning and Degreasing	23
             9.  Surface Preparation	24
             10. Painting Processes	28
      B. Raw Material Inputs and Pollutant Outputs	33
             1.  Surface Preparation	33
             2.  Painting	34
             3.  Metal Plating and Surface Finishing	35
             4.  Fiberglass Reinforced Construction	36
             5.  Machining and Metalworking  	36
             6.  Solvent Cleaning and Degreasing	37
      C. Management of Chemicals in Wastestream	40
Sector Notebook Project
       November 1997

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Shipbuilding and Repair Industry
                   Sector Notebook Project
IV. CHEMICAL RELEASE AND TRANSFER PROFILE  	43
      A. EPA Toxic Release Inventory for the Shipbuilding and Repair Industry  	47
      B. Summary of Selected Chemicals Released	52
      C. Other Data Sources  	57
      D. Comparison of Toxic Release Inventory Between Selected Industries	59

V. POLLUTION PREVENTION OPPORTUNITIES	63
      A. Surface Preparation  	64
      B. Painting and Coating  	65
             1. Application Equipment	65
             2, Alternative Coatings 	69
             3. Good Operating Practices 	70
      C. Metal Plating and Surface Finishing	 . 71
      D. Fiberglass Reinforced Construction  	72
      E, Solvent Cleaning and Degreasing	73
      F. Machining and Metalworking 	78

VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS	81
      A, General Description of Major Statutes  	81
      B. Industry Specific Requirements	93
      C. Pending and Proposed Regulatory Requirements  	97

VII.  COMPLIANCE AND  ENFORCEMENT HISTORY 	99
      A. Shipbuilding and Repair Industry Compliance History	103
      B. Comparison of Enforcement and Compliance Activity Between Selected Industries
              	105
      C. Review of Major Legal Actions	110
             1. Review of Major Cases	110
             2. Supplementary Environmental Projects (SEPs)	110

VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES  	Ill
      A. Sector-related Environmental Programs and Activities	Ill
      B. EPA Voluntary Programs  	114
      C. Trade Associations	120

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS	123

Appendix A: Instructions for downloading this notebook	A-l
Sector Notebook Project
VI
                           November 1997

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Shipbuilding and Repair Industry
                      Sector Notebook Project
                                LIST OF FIGURES

Figure 1: Profiles of Ship Types	5
Figure 2: Geographic Distribution of Shipyards	8
Figure 3: Example Shipyard Layout	15
Figure 4: General Ship Manufacturing Levels	17
Figure 5: Typical Pickling Tank Arrangement 	27
Figure 6: Summary of TRI Releases and Transfers by Industry	60


                                LIST OF TABLES

Table 1: Facility Size Distribution for the Shipbuilding and Repair Industry	7
Table 2: Top U.S. Companies with Shipbuilding and Repair Operations	9
Table 3: Material Inputs and Potential Pollutant Outputs for the
        Shipbuilding and Repair Industry	39
Table 4: Source Reduction and Recycling Activity for Shipyards	41
Table 5: 1995 TRI Releases for Shipbuilding and Repair Facilities	49
Table 6: 1995 TRI Transfers for Shipbuilding and Repair Facilities  	50
Table 7:Top 10 TRI Releasing Shipbuilding and Repair Facilities Reporting Only SIC 3731  ..51
Table 8: Top 10 TRI Releasing Facilities Reporting Only SIC 3731
         or SIC 3731 and Other  SIC codes	52
Table 9: Air Pollutant Releases (tons/year)	58
Table 10: Toxics Release Inventory Data for Selected Industries	61
Table 11: Five-Year Enforcement and Compliance Summary for the
         Shipbuilding and Repair Industry	103
Table 12: Five-Year Enforcement and Compliance Summary for Selected Industries	106
Table 13: One-Year Enforcement and Compliance Summary for Selected Industries	107
Table 14: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries  108
Table 15: One-Year Inspection and Enforcement Summary by Statute for Selected Industries  109
Table 16: Shipbuilding  and Repair Industry Participation in the 33/50 Program  	115
Sector Notebook Project
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November 1997

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Shipbuilding and Repair Industry
                    Sector Notebook Project
                            LIST OF ACRONYMS

AFS -       AIRS Facility Subsystem (CAA database)
AIRS -      Aerometric Information Retrieval System (CAA database)
BEFs -       Boilers and Industrial Furnaces (RCRA)
BOD -      Biochemical Oxygen Demand
CAA -      Clean Air Act
CAAA -     Clean Air Act Amendments of 1990
CERCLA -   Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS -  CERCLA Information System
CFCs -      Chlorofluorocarbons
CO -        Carbon Monoxide
COD -      Chemical Oxygen Demand
CSI -        Common Sense Initiative
CWA -      Clean Water Act
D&B -      Dun and Bradstreet Marketing Index
ELP -       Environmental Leadership Program
EPA -       United States Environmental Protection Agency
EPCRA -    Emergency Planning and Community Right-to-Know Act
FIFRA -     Federal Insecticide, Fungicide, and Rodenticide Act
FINDS -     Facility Indexing System
HAPs -      Hazardous Air Pollutants (CAA)
HSDB -     Hazardous Substances Data Bank
IDEA -      Integrated Data for Enforcement Analysis
LDR -       Land Disposal Restrictions (RCRA)
LEPCs -     Local Emergency Planning Committees
MACT -     Maximum Achievable Control Technology (CAA)
MCLGs -    Maximum Contaminant Level Goals
MCLs -     Maximum Contaminant Levels
MEK -      Methyl Ethyl Ketone
MSDSs -    Material Safety Data Sheets
NAAQS -   National Ambient Air Quality Standards (CAA)
NAFTA -    North American Free Trade Agreement
NCDB -     National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP -       National Oil and Hazardous Substances Pollution Contingency Plan
NEIC -      National Enforcement Investigation Center
NESHAP -   National Emission Standards for Hazardous Air Pollutants
NO2 -       Nitrogen Dioxide
NOV -      Notice of Violation
NOX -       Nitrogen Oxides
NPDES -    National Pollution Discharge Elimination System (CWA)
NPL -       National Priorities List
NRC -      National Response Center
Sector Notebook Project
via
                            November 1997

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 Shipbuilding and Repair Industry
                     Sector Notebook Project
 NSPS -      New Source Performance Standards (CAA)
 OAR -       Office of Air and Radiation
 OECA -      Office of Enforcement and Compliance Assurance
 OPA-       Oil Pollution Act
 OPPTS -     Office of Prevention, Pesticides, and Toxic Substances
 OSHA -      Occupational Safety and Health Administration
 OSW-       Office of Solid Waste
 OSWER -    Office of Solid Waste and Emergency Response
 OW -        Office of Water
 P2 -         Pollution Prevention
 PCS -        Permit Compliance System (CWA Database)
 POTW -      Publicly Owned Treatments Works
 RCRA -      Resource Conservation and Recovery Act
 RCRIS -      RCRA Information System
 SARA -      Superfund Amendments and Reauthorization Act
 SDWA -      Safe Drinking Water Act
 SEPs -       Supplementary Environmental Projects
 SERCs -      State Emergency Response Commissions
 SIC -        Standard Industrial Classification
 SO2 -        Sulfur Dioxide
 SOX -        Sulfur Oxides
 TOC -        Total Organic Carbon
 TRI -        Toxic Release Inventory
 TRIS -       Toxic Release Inventory System
 TCRIS -      Toxic Chemical Release Inventory System
 TSCA -      Toxic Substances Control Act
 TSS-        Total Suspended Solids
 UIC  -        Underground Injection Control (SDWA)
 UST -        Underground Storage Tanks (RCRA)
 VOCs -       Volatile Organic Compounds
Sector Notebook Project
IX
November 1997

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Shipbuilding and Repair Industry
                     Sector Notebook Project
                      SHIPBUILDING AND REPAIR INDUSTRY
                                       (SIC 3731)

I.  INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

I.A. Summary of the Sector Notebook Project

                     Integrated environmental policies based upon comprehensive analysis of air,
                     water, and land pollution are a logical supplement to traditional single-media
                     approaches to environmental protection. Environmental regulatory agencies
                     are beginning to embrace comprehensive, multi-statute solutions to facility
                     permitting, enforcement and compliance assurance, education/ outreach,
                     research, and regulatory development issues.  The central concepts driving the
                     new policy direction are that pollutant releases to each environmental medium
                     (air, water, and land) affect each other, and that environmental strategies must
                     actively identify and address these inter-relationships by designing policies for
                     the "whole" facility.  One way to achieve a whole facility focus is to design
                     environmental  policies for  similar industrial facilities.   By  doing so,
                     environmental concerns that are common to the manufacturing of similar
                     products can be addressed in a comprehensive manner. Recognition of the
                     need to  develop the industrial "sector-based" approach within the EPA Office
                     of Compliance led to the creation of this document.

                     The Sector Notebook Project was originally initiated  by the Office of
                     Compliance within the Office of Enforcement and Compliance Assurance
                     (OECA) to provide  its staff and managers with summary information for
                     eighteen specific industrial sectors. As other EPA offices, states, the regulated
                     community, environmental groups, and the public became interested in this
                     project, the scope of the original project was expanded to its current form.
                     The ability to design comprehensive, common sense environmental protection
                     measures for specific industries is dependent on knowledge of several inter-
                     related topics.  For the purposes of this project, the key elements chosen for
                     inclusion are:  general industry information (economic and geographic); a
                     description of industrial processes; pollution outputs; pollution prevention
                     opportunities; Federal statutory  and  regulatory  framework;  compliance
                     history; and a description  of partnerships that have been formed between
                     regulatory agencies, the regulated community, and the public.

                     For any given industry, each topic listed above could alone be the subject of
                     a lengthy volume.  However, in order to produce a manageable document, this
                     project focuses  on providing summary information for each topic.  This
                     format provides the reader with a synopsis of each issue, and references where
                     more in-depth information  is available.  Text within each  profile  was
                     researched from a variety of sources, and was usually condensed from more
                     detailed sources pertaining to specific topics.  This approach allows for a wide
                     coverage of activities that can be further explored based upon the citations
Sector Notebook Project
1
November 1997

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Shipbuilding and Repair Industry
Sector Notebook Project
                    and references listed at the end of this profile. As a check on the information
                    included, each notebook went through an external review process.  The Office
                    of Compliance appreciates the efforts of all those that participated in this
                    process and enabled us to develop more complete, accurate and up-to-date
                    summaries. Many of those who reviewed this notebook are listed as contacts
                    in Section IX and may be sources of additional information.  The individuals
                    and groups on this list do not necessarily concur with all statements within this
                    notebook.

I.B.  Additional Information
Providing Comments
                    OECA's Office of Compliance plans to periodically review and update the
                    notebooks and will make these updates available both in hard copy and
                    electronically. If you have any comments on the existing notebook, or if you
                    would like to provide additional information, please send a hard copy and
                    computer disk to the EPA Office of Compliance, Sector Notebook Project,
                    401 M St., SW (2223-A), Washington, DC 20460.  Comments can also be
                    uploaded to the Enviro$en$e World Wide Web for general access to all users
                    of the system. Follow instructions in Appendix A for accessing this system.
                    Once you have logged in, procedures for uploading text are available from the
                    on-line Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
                    The scope of the industry sector described in this notebook approximates the
                    national occurrence of facility types within the sector.  In many instances,
                    industries within specific geographic regions or states may have unique
                    characteristics that are not fully captured in these profiles.  The Office of
                    Compliance encourages  state and local environmental  agencies and other
                    groups to supplement or re-package the information included in this notebook
                    to include more specific  industrial and regulatory information that may be
                    available. Additionally,  interested  states  may want to  supplement  the
                    "Summary of Applicable Federal Statutes and Regulations" section with state
                    and local requirements.  Compliance or technical assistance providers may
                    also want to develop the "Pollution Prevention" section in more detail.  Please
                    contact the appropriate specialist listed on the opening page of this notebook
                    if your office is interested in assisting us in the further development of the
                    information or policies addressed within this volume. If you are interested in
                    assisting in the development of new notebooks for sectors not covered in the
                    original eighteen, please contact the Office of Compliance at 202-564-2395.
Sector Notebook Project
         November 1997

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Shipbuilding and Repair Industry	Introduction

H. INTRODUCTION TO THE SHIPBUILDING AND REPAIR INDUSTRY

                    This  section provides background  information on the size, geographic
                    distribution, employment, production, sales, and economic condition of the
                    ship building and repair industry. Facilities described within this document are
                    described in terms of their Standard Industrial Classification (SIC) codes.

n.A.  Introduction, Background, and Scope of the Notebook

                    The shipbuilding and repair industry builds and repairs ships, barges, and other
                    large vessels, whether self-propelled or towed by other craft.  The industry
                    also includes the conversion and alteration of ships and the manufacture of
                    offshore oil and gas well drilling and production platforms. The shipbuilding
                    and repair industry described in this notebook is categorized by the Office of
                    Management and Budget (OMB) under the Standard Industrial Classification
                    (SIC) code 3731. This notebook does not cover the related sector SIC 3732
                    Boat Building and  Repairing.  The boat building and repair industry is
                    engaged in  the manufacturing and  repairing of smaller non-ocean going
                    vessels primarily used for recreation, fishing, and personnel transport.  OMB
                    is in the process of changing the SIC code system to a system based on similar
                    production processes  called the North American Industrial Classification
                    System (NAICS). (In the NAIC system, shipbuilding and repair facilities are
                    all classified as NAIC 336611.)

II.B.  Characterization of the Shipbuilding and Repair Industry

                    Shipyards, or facilities that build and/or repair ships, operate on a job basis.
                    With the exception of about nine U.S. Navy owned shipyards (which are not
                    included in SIC 3731), the U.S. shipbuilding and repair industry is privately
                    owned.  Unlike most other industries, each year only a small  number of
                    valuable orders are received that often take years to fill. Orders for ships and
                    ship repairs are primarily placed by companies or the federal government.
                    Companies that place orders often include commercial shipping companies,
                    passenger and cruise companies, ferry companies, petrochemical companies,
                    commercial fishing  companies, and towing and tugboat companies.   The
                    principal federal government agencies placing shipbuilding and repair orders
                    include the Naval Sea Systems Command, the Military Sealift Command, the
                    Army Corps of Engineers, the U.S. Coast Guard, the National Oceanic and
                    Atmospheric Administration, the National Science Foundation,  and the
                    Maritime Administration.

       EL.B.1. Product Characterization

                    Shipyards are often categorized into a few basic subdivisions either by type of
                    operations (shipbuilding or  ship repairing), by type  of ship  (commercial or
                    military), and shipbuilding  or repairing capacity (first-tier or second-tier).

Sector Notebook Project                     3                             November 1997

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Shipbuilding and Repair Industry
   Introduction
                     Ships themselves are often classified by their basic dimensions, weight
                     (displacement), load-carrying capacity (deadweight), or their intended service.
                     In the U.S., there are considerable differences between shipyard operations
                     when constructing ships for commercial purposes and when constructing ships
                     for the military.

       Commercial Ships

                     An important difference between commercial ships and military ships is that
                     the  commercial ship market is much more cost competitive.   Unlike the
                     military  market, the commercial  ship   market must  also  compete
                     internationally.  The cost of building and maintaining a ship must be low
                     enough such that the owners can make a  reasonable profit.   This has a
                     significant impact on the manner in which commercial ships are built and
                     repaired. The intense global competition in this industry is the main reason
                     that  since World War II,  U.S. shipyards  have produced  relatively few
                     commercial ships.  In this regard,  since 1981 the U.S. shipyards received less
                     than one percent of all commercial orders for large ocean going vessels in the
                     world, and no commercial orders for large ocean going cause ships (ASA,
                     1997).

                     Commercial ships can be subdivided into a number of classes based on their
                     intended use. Commercial ship classes include dry cargo ships, tankers, bulk
                     carriers, passenger ships, fishing vessels, industrial vessels, and others (Storch
                     et al., 1995). Dry cargo ships include break bulk, container, and roll-on/roll-
                     off types. Profiles of a  number of ship types are shown in Figure  1.
       Military Ships
                     Military ship orders have been the mainstay of the industry for many years.
                     The military ship market differs from the commercial market in that the major
                     market drivers are agency budgets as set by government policy.

                     The military ship market can be divided into combatant ships and ships that
                     are ordered by the government, but are built and maintained to commercial
                     standards rather than military standards. (Storch et al., 1995)   Combatant
                     ships are primarily ordered by the U.S. Navy and include surface combatants,
                     submarines, aircraft carriers,  and auxiliaries.  Government  owned non-
                     combatant ships are mainly purchased  by the  Maritime Administration's
                     National Defense Reserve Fleet  (NDRF) and the Navy's Military Sealift
                     Command (MSC). Other government agencies that purchase non-combatant
                     ships are the Army Corp of Engineers, National Oceanic and  Atmospheric
                     Administration, and the National Science Foundation.   Such ships often
                     include cargo ships, transport ships, roll on/roll off ships, crane ships, tankers,
                     patrol ships, and ice breakers.
Sector Notebook Project
November 1997

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 Shipbuilding and Repair Industry
                                          Introduction
                           Figure 1: Profiles of Ship Types
1
r FT"
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J "v.
Hri
i,

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SPACE


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' H W

TANK NO. 5


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TANK NO. 4



TANK NO. 3


TANK NO. 2


TANK NO. 1

M
L
D.T.
NO. 1
a
s.wA
BALLIN-
	 1-
                                        TANKER
N0 e ! HOLD | HOLD ! HOLD | Hnl n I Mr> ,
N0-6 I N0.5 I N0.4I N0.3 I HOLD I NO'2
                                                                   HOLD
                                                                   NO. 1
                                                                  BALLAST
                                                                        BALL
                                                                            -
                                          BALLAST

                                     BULK CARRIER
                                FISHING VESSEL
                 HANGER
                                                          MAGAZINE
                                                          SONAR
                                  COMBATANT (SURFACE)
    Source: Adapted from Ship Production, Storch, et. al., 1995.
Sector Notebook Project
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Shipbuilding and Repair Industry
  Introduction
       Ship Repairing
                     Ship repair operations include repainting, overhauls, ship conversions, and
                     alterations. Almost all shipyards that construct new ships also do major ship
                     repairs. In addition, about 200 shipyards concentrate solely on ship repairing
                     and do not have the necessary facilities to construct ships (Storch et. al.,
                     1995).  Only about 31 shipyards have "major dry-docking facilities" capable
                     of removing ships over 122 meters in length from the water (MARAD, 1995).
                     Dry-docking facilities,  or "full service" repair yards,  allow repairs and
                     maintenance below a ship's water line.  The remaining repair yards can either
                     dry-dock vessels under  122 meters  or have  no dry-docking  facilities.
                     Shipyards with no dry-docking facilities, called topside yards, perform above-
                     water ship and barge repairs. Such facilities generally employ fewer than 100
                     people and are often capable of transporting workers and materials to the ship
                     (Storch etal., 1995).

       First and Second-Tier Shipyards

                     U.S. shipyards are also classified by MARAD as either first-tier shipyards or
                     second-tier  shipyards.   First-tier  shipyards make up  the  "U.S.  major
                     shipbuilding base" (MSB).  As defined by MARAD and the Department of
                     Transportation  in "Report on  Survey  of U.S.  Shipbuilding and Repair
                     Facilities," 1995, the MSB is comprised of privately owned shipyards that are
                     open and have at least one shipbuilding position capable of accommodating
                     a vessel of  122  meters (383 feet) or more.  With few exceptions, these
                     shipyards are also major repair facilities  with drydocking capabilities (U.S.
                     Industrial Outlook, 1994). In 1996 there were 16 of these major shipbuilding
                     facilities in the U.S.

                     Second-tier shipyards are comprised of the  many  small and medium-size
                     shipyards that construct and repair smaller  vessels (under 122 meters) such as
                     military and non-military patrol boats, fire and rescue vessels, casino boats,
                     water taxis, tug and towboats, off-shore crew and supply boats, ferries, fishing
                     boats, and shallow draft barges (MARAD, 1996). A-number of second-tier
                     shipyards are also able to make topside repairs to ships over 122 meters in
                     length.

       II.B.2.  Industry Size and Geographic Distribution

                     According to the 1992 Census of Manufacturers data (the most recent Census
                     data available), there were approximately 598 shipbuilding and repairing yards
                     under SIC code 3731.   The payroll for  this year totaled $3.6 billion for a
                     workforce of 118,000 employees, and  value of shipments totaled $10.6
                     billion.  Based on the Census of Manufacturers data, the industry is very labor
                     intensive.    The value  of shipments per employee  (a measure of labor
                     intensiveness) is $90,000, which is  about one  third that of the  steel
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Shipbuilding and Repair Industry
  Introduction
                    manufacturing industry ($245,000 per employee) and only five percent that
                    of the petroleum refining industry ($1.8 million per employee).

                    According to the Census of Manufacturers, most shipyards are small. About
                    72 percent of the shipyards employ fewer than 50 people in 1992 (see Table
                    1). It is the relatively few (but large) shipyards, however, that account for the
                    majority of the industry's employment and sales. Less than five percent of the
                    shipyards account for almost 80 percent of the industry's employment and
                    sales.
Table 1: Facility Size Distribution for the Shipbuilding and Repair Industry
Employees
per Facility
1-9
10-49
50-249
250-499
500-2499
2500 or more
Total
Facilities
Number of
Facilities
230
203
113
25
21
6
598
Percentage of
Facilities
38%
34%
19%
4%
4%
1%
100%
Employees
Number of
Employees
900
4,600
12,900
8,200
17,100
74,600
118,300
Percentage of
Employees
1%
4%
11%
7%
14%
63%
100%
Source: U.S. Department of Commerce, Census of Manufacturers, 1992.
       Geographic Distribution
                    The geographic  distribution of the shipbuilding  and repair  industry is
                    concentrated  on the coasts.   Other important areas are  the  southern
                    Mississippi River and Great Lakes regions.  According to the 1992 U.S.
                    Census of Manufacturers, there are shipyards in 24 states.  The top states in
                    order are: Florida, California, Louisiana, Texas, Washington, and Virginia.
                    Together, these states account for about 56 percent of U.S. shipyards.  Figure
                    2 shows the U.S. distribution of facilities based on data from the Census of
                    Manufacturers.
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Shipbuilding and Repair Industry
  Introduction
                  Figure 2: Geographic Distribution of Shipyards
  Source; U.S. Census of Manufacturers, 1992.
                    Dun & Bradstreet'sMillion Dollar Directory, compiles financial data on U.S.
                    companies including those  operating within the shipbuilding and repair
                    industry. Dun & Bradstreet ranks U.S. companies, whether they are a parent
                    company, subsidiary or division, by sales volume within their assigned 4-digit
                    SIC code.  Readers should note that:  (1) companies are assigned a. 4-digit
                    SIC that resembles their principal industry most closely; and (2) sales figures
                    include total company sales, including subsidiaries and operations (possibly
                    not related to  shipbuilding  and repair).  Additional  sources  of company
                    specific financial information include Standard & Poor's Stock Report
                    Services, Ward's Business Directory of U.S. Private and Public Companies.,
                    Moody's Manuals, and annual reports.
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  Introduction
Table 2: Top U.S. Companies with Shipbuilding and Repair Operations
Rank3
1
2
3
4
5
6
7
8
9
10
Company*
Newport News Shipbuilding and Dry Dock Co.
Newport News, VA
Ingalls Shipbuilding Inc. - Pascagoula, MS
General Dynamics Corp. (Electric Boat) - Groton, CT
Bath Iron Works Corp. - Bath, ME
Avondale Industries Inc., Shipyards Division
New Orleans, LA
National Steel and Shipbuilding Co. (NASSCO)
San Diego, CA
Trinity Marine Group - Gulfport, MS
Norfolk Shipbuilding and Drydock Corp. - Norfolk, VA
American Commercial Marine Service Co. -
Jeffersonville, IN
Atlantic Marine - Jacksonville, FL
1996 Sales
(millions of dollars)
1,756
1,125
980
850
576
500
400
212
166
121
Note: aNot all sales can be attributed to the companies' shipbuilding and repair operations.
b Companies shown listed .SIC 373 1 .
Source: Dunn & Bradstreet's Million Dollar Directory - 1996.
       II.B.3. Economic Trends
       General Economic Health
                     In general, the U.S. shipbuilding and repair industry is in a depressed state.
                     At its height in the mid-1970s, the industry held a significant portion of the
                     international commercial market while maintaining its ability to supply all
                     military orders.  Since then, new ship construction, the number of shipbuilding
                     and repair yards, and overall industry employment have decreased sharply.
                     The decline has been especially severe in the construction of commercial
                     vessels at first tier shipyards which fell from about 77 ships (1,000 gross tons
                     or more) per year in the mid-1970s to only about eight ships total through the
                     late 1980s and early  1990s.  In the  1980s, the industry's loss of the
                     commercial market share was somewhat offset by a substantial increase in
                     military ship orders. Following the naval expansion, however, the industry
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Shipbuilding and Repair Industry
                                 Introduction
                     entered the 1990s with a much smaller military market and a negligible share
                     of the commercial market.

                     The second tier shipyards and the ship repairing segment of the industry has
                     also suffered in recent decades; however, its decline has not been as drastic.
                     The second tier shipyards, comprised of small and medium size facilities, were
                     able to keep much of their mainly commercial market share. These shipyards
                     build vessels used on the inland and coastal waterways which by law must be
                     built in the U.S.

                     The U.S.  shipbuilding and repairing industry's loss of the commercial
                     shipbuilding market has been attributed to a number of factors. First, a world
                     wide shipbuilding boom in the  1970s created a large quantity  of surplus
                     tonnage which  suppressed demand for years.  Another significant factor
                     reducing  U.S.  shipbuilding  and  repair  industry's ability to  compete
                     internationally are the substantial subsidies that many nations provide to their
                     domestic shipbuilding and repair industries.  Also, until 1980, over 40 percent
                     of U.S.-built merchant ships received Construction Differential Subsidies
                     (CDS) based on the difference between foreign and domestic shipbuilding
                     costs. The program was eliminated in 1981, further reducing the industry's
                     competitiveness.

                     Another trend in the industry has been a movement toward consolidation. In
                     recent years many shipyards have been closed or purchased by larger ship
                     building and repair companies.

       Government Influences

                     The U.S. shipbuilding and repair industry is highly dependent on the Federal
                     Government, its primary market, for its continued existence. Direct purchases
                     of military ships and military ship  repair services by the Federal Government
                     account for  about  80  percent  of the  industry's sales  (Census of
                     Manufacturers, 1992). In addition, the industry receives a small amount of
                     support  through a  few federal tax incentives and financing  assistance
                     programs.

                     MARAD provides assistance to U.S. ship owners through the Federal Ship
                     Mortgage Insurance (Title XI) and Capital Construction Fund programs.
                     Under Title XI,  the Federal Government guarantees repayment  of private
                     sector mortgage obligations for operators that purchase  ships from U.S.
                     shipyards.  Although the Capital  Construction Fund has not been funded in
                     recent years, in  the past it has allowed operators to establish tax-deferred
                     funds for procuring new or reconstructed vessels from U.S. shipyards (U.S.
                     Industrial Outlook, 1994). Another program, MARITECH, is jointly funded
                     by the Federal  Government  and industry  and is administered by  the
                     Department of Defense's Advanced Research Projects Agency (ARPA), in
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 Shipbuilding and Repair Industry
                                  Introduction
                     collaboration with MARAD. MARITECH provides matching Government
                     funds to  encourage the shipbuilding industry to  direct  and lead in  the
                     development and application of advanced  technology  to improve its
                     competitiveness and to preserve its industrial base. (For more information on
                     MARITECH, see Section VIII.A.)

                     Such outside support is not unique to the U.S.  Worldwide,  many nations
                     provide substantial subsidies to their shipbuilding and repair industries.  The
                     governments of most trading nations support their domestic industries because
                     they believe that it is in their best  interest  economically and militarily.
                     Maintaining a shipbuilding industrial base helps to .safeguard a nation's control
                     over getting its products to foreign markets, and ensures that it will have the
                     means to replace its merchant or naval fleets in a time of national emergency.
                     As  a result of these external influences, the industry does not behave
                     according to the simple  economic supply and  demand model. Rather,  the
                     policies of national governments in conjunction with economic forces dictate
                     economic activity in this  sector.

                     Like many other nations, the U.S. has a policy of maintaining a shipbuilding
                     and repair industrial base that can be expanded in time of war (Storch, et al.,
                     1995). National policy, therefore, will continue to be the primary factor
                     influencing the industry's economic trends in the U.S.

       Domestic Market

                     The military still is, and will continue to be, the primary source of work for  the
                     industry.  However,  the Navy's new ship procurement has  sharply declined
                     since the accelerated Navy ship construction in the 1980s.   This work is
                     expected to continue to decline at least through the remainder  of the 1990s.
                     Some industry analysts predict that a number of the first tier shipyards, which
                     fill most of the military orders, will close in coming years.

                     While military shipbuilding is on the decline, the forecast for the commercial
                     sector is more promising.  Domestic demand for commercial  shipbuilding and
                     repair has increased dramatically in recent years and is expected to continue
                     to increase throughout the 1990s.  There have  been significant increases in
                     barge construction in recent years. In  1996,  1,070 hopper  barges were
                     delivered by U.S. shipyards, more than double the number delivered in 1995.
                     This number is expected to grow to over 1,500 in 1997.  Demand is also
                     expected  to be particularly high for tankers; especially for  new double-hull
                     tankers in response to the 1990 Oil Pollution Act requirements.
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Shipbuilding and Renair Industry
                                Introduction
       International Market
                    Currently, the U.S. holds less than one half of one percent of the world market
                    share of commercial shipbuilding and repair. South Korea and Japan currently
                    dominate the world market.  Each holds about  30 percent of the gross
                    tonnage of merchant ships on order. Germany, Poland, Italy, and China each
                    hold between four and five percent of the commercial market. However, a
                    number of major commercial ship orders were received by first and second tier
                    shipyards in 1995 and 1996. The chief driving forces for this increase in U.S.
                    commercial ship production  is a general increase in worldwide demand
                    stemming from an aging merchant fleet and an improving global economy.
                    The elevated demand is expected to continue over the next three to five years.

                    Through the OECD in December 1994, an agreement was reached by the
                    Commission of the European Communities, and the Governments  of Finland,
                    Japan, South Korea,  Norway, Sweden and the United States to establish more
                    normal competitive conditions in the shipbuilding industry.  The agreement is
                    expected to remove government support and unfair pricing practices in the
                    industry. If and when this agreement is implemented, it is expected to have
                    a positive  impact on the world market by  discouraging "ship dumping"
                    practices that are believed to have been damaging shipbuilders.  It is hoped
                    that the agreement will also bring to light the actual economic advantage and
                    competitiveness of the various countries and individual ship builders. In
                    addition, the shipowners will no longer be able to buy ships at subsidized or
                    dumped prices reducing the likelihood of speculative buying.

                    Recognizing the unique need for the Administration,  Congress and the
                    shipbuilding industry to work together in order for the  U.S.  to become
                    competitive once again in the international shipbuilding market, President
                    Clinton submitted a Report to Congress entitled "Strengthening America's
                    Shipyards: A Plan for Competing in the International Market."  In that report,
                    the President outlined a number of steps to be taken "to ensure a successful
                    transition to a competitive industry in a truly competitive marketplace."  The
                    Administration's five step plan included:

                    •     Ensuring Fair International Competition
                           Improving Competitiveness
                           Eliminating  Unnecessary Government Regulation
                           Financing Ship Sales Through Title XI Loan Guarantees, and
                           Assisting International Marketing.
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 Shipbuilding and Repair Industry
                 Industrial Process Description
     INDUSTRIAL PROCESS DESCRIPTION

                     This section describes the major industrial processes within the shipbuilding
                     and repair industry, including the materials and equipment used and the
                     processes employed. The section is designed for those interested in gaining
                     a general understanding of the industry, and for those interested in the inter-
                     relationship between the industrial process and the topics  described in
                     subsequent sections of this profile ~ pollutant outputs, pollution  prevention
                     opportunities, and Federal regulations. This section does not  attempt to
                     replicate published engineering information that is available for this industry.
                     Refer to Section IX for  a list of resource materials  and contacts that are
                     available.

                     This section specifically contains a description of commonly used production
                     processes, associated raw materials, the by-products produced or released,
                     and the materials either  recycled or transferred off-site.  This discussion,
                     coupled with  schematic  drawings of the identified  processes,  provide a
                     concise description of where wastes may be produced in the process. This
                     section also describes the potential fate (via air, water,  and soil pathways) of
                     these waste products.

IILA. Industrial Processes in the Shipbuilding and Repair Industry

                     The shipbuilding and repair  industry  has  characteristics of  both  a
                     manufacturing industry and the construction industry. The industry uses and
                     produces  a wide variety  of manufactured components in addition to basic
                     construction materials. As with the construction industry, shipbuilding and
                     repair requires many workers with many different  skills all working in  an
                     established organization structure.

                     New ship  construction and ship repairing have many industrial processes in
                     common.  They both apply of essentially the same manufacturing practices,
                     processes,  facilities, and support  shops.   Both  ship repair  and new
                     construction work require highly skilled labor because many of the operations
                     (especially in ship repair) have limited potential for automation. Both require
                     excellent planning, engineering, and interdepartmental communications.  New
                     ship construction,  however,  generally requires  a  greater amount  of
                     organization because of the  size of the workforce, size of the workload,
                     number of parts, and the complexity of the communications (e.g., production
                     plans and schedules) surrounding the shipbuilding work-flow (NSRP, 1993).

       III.A.I. Shipyard Layout

                     Shipbuilding and repair facilities are generally made up of several specific
                     facilities laid out to facilitate the flow of materials  and assemblies.   Most
                     shipyards were built prior to the Second World War.  Changes in shipyard
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               Industrial Process Description
                     layout were made piecemeal, responding to advances in technology, demands
                     for different types of ships, and availability of land and waterfront.  As a
                     result, there is no typical shipyard layout.  There are, however, a number of
                     specific facilities that are common to most large shipyards.  These facilities
                     include: drydocks,  shipbuilding  positions,  piers and berthing  positions,
                     workshops (e.g.,  machine,  electrical, pipe,  assembly,  paint  and  blast,
                     carpenter, and sheet metal shops), work  areas (steel storage, platen lines, and
                     construction areas), warehouses, and offices. A shipyard layout containing
                     many of these facilities is shown in Figure 3.

       EQ.A.2.  Docking and Launching Facilities

                     There are few shipyards that have the capability to construct or repair vessels
                     under cover; in most cases shipbuilding and repair are done largely out of
                     doors. Much of this work is done over, in, under, or around water,  which can
                     inadvertently receive a portion of shipyard pollutant outputs.  The  docking
                     facilities, or the mechanisms used to remove ships from the water for repair
                     or to   construct  and  launch  ships,  can  affect  waste generation and
                     management.

                     Ships can be either wet-docked or drydocked. A wet-dock or berth is a pier
                     or a wet slip position that a ship can dock next to and tie up. A ship that has
                     its entire hull exposed to the atmosphere is said to be drydocked.  A number
                     of different drydocking and launching facilities exist including building ways,
                     floating drydocks, graving docks, and marine railways.
       Building Ways
                     Building ways are used only for building ships and releasing them into the
                     adjacent waters. New ships are constructed and launched from one of two
                     main types of building ways: longitudinal end launch ways and side launch
                     ways (NSRP, 1993).
       Floating Drydocks
                     Floating drydocks are floating vessels secured to land that have the ability to
                     be lowered under the water's surface in order to raise ships above the water
                     surface. Floating drydocks are generally used for ship repair, but in some
                     cases ship construction is performed.   When the drydock is submerged by
                     filling ballast tanks with water, ships are positioned over bilge and keel blocks
                     located on the deck of the drydock.  The ship's position over the drydock is
                     maintained while the ballast tanks are pumped out, which raises the dock and
                     the ship above the water surface (NSRP, 1993).
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 Shipbuilding and Repair Industry
                Industrial Process Description
                        Figure 3: Example Shipyard Layout
    Source: Maritime Administration, Report on Survey of U.S. Shipbuilding and Repair Facilities, 1995.
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       Graving Docks
                     Graving docks are man-made rectangular bays where water can be let in and
                     pumped out. Ships are floated into the dock area when the dock is full of
                     water. Water-tight gates are closed behind the ship and the water is pumped
                     from inside the dock area to the outside adjacent waters. Large pumping
                     systems are typically used to remove all but a few inches of the water.
                     Graving docks usually have a  sloping dock floor which directs the water to
                     channels leading to smaller pumps which empty the final few inches of water
                     as well as any rain or water runoff which enters the dock (NSRP, 1993).
       Marine Railways
                     Marine railways have the ability to retrieve and launch ships. They are similar
                     to end-launch building ways, but usually much smaller.  Marine railways
                     essentially consist of a rail-car platform and a set of railroad tracks.  The rails
                     are secured to an inclined cement slab that runs the full length of the way and
                     into the water to a depth necessary for docking ships.   Motor and pulley
                     systems are located at the head of marine railways to pull the rail-car platform
                     and ship from the water (NSRP, 1993).
       III.A.3.  Ship Construction Processes
                     Most new ship construction projects are carried out using zone-oriented
                     methods, such as the hull block construction method (HBCM). In HBCM, the
                     ship structure is physically divided into a number of blocks. The definition of
                     hull blocks has an enormous impact on the efficiency of the ship construction.
                     Therefore, blocks  are  carefully designed to minimize work  and to avoid
                     scheduling problems. Blocks are constructed and pieced together in five
                     general manufacturing levels. Figure 4 summarizes the various manufacturing
                     levels.

                     The  first level involves the purchasing and handling of raw  materials and
                     fabricating these materials into the most basic parts.  The primary raw
                     materials include steel plates, bars, and structural members.  Parts fabrication
                     or pre-assembling operations  often  involve  cutting,  shaping,  bending,
                     machining, blasting, and painting of these materials.  Fabricated parts include
                     steel plates and steel members used as structural parts, machined parts, piping,
                     ventilation ducts, electrical components (motors, lights, transformers, gauges,
                     etc.), and a wide variety of other miscellaneous parts.  Parts fabrication is
                     carried out throughout the shipyard in a number of different shops and work
                     areas depending on the specific raw materials being handled (see Section
                     III.A.7 for a description of typical operations conducted in shipyard shops).

                     Level 2 of new ship construction involves the joining of different fabricated
                     parts from Level 1  into assembled parts.  In the third level of manufacturing
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                 Industrial Process Description
                      the fabricated and/or assembled parts  are fitted together into a sub-block
                      assembly which are in turn fitted together in Level 4 to form blocks.  Blocks
                      are three dimensional sections of the ship and are the largest sections of the
                      ship to be assembled away from the erection site. Blocks are designed to be
                      stable configurations that do not require temporary support or reinforcement.
                      Often, at least one side of a block forms  part of the outside hull of the ship.
                      Blocks are built and transported through the shipyard and welded together at
                      a building position where the ship is erected.  The size of the blocks that a
                      shipyard can  build is dependent on the shipyard capacity  to assemble,
                      transport, and lift the blocks  and units onto the ship under construction.  In
                      Level 5  the ship is erected from the blocks (Storch, 1995).
                              Figure 4: General Ship Manufacturing Levels
                       LEVEL # 1
                                   PURCHASING AND PHE-ASSEMBLY
               A) PURCHASING OF RAW MATERIALS, •) TRANSFORM-
               IMG THE MATERIALS INTO PARTS. (U., PLATE STEEL
               INTO SHAPES AND HK INTO PIPE SPOOLS)
                      LEVEL #s 2 & 3
                                   SUB-ASSEMBLY
               JOINING THOSE PARTS PRODUCED AT LEVEL *1 INTO
               LARGER SUB-ASSEMBLIES.
                       LEVEL # 4
                                   ASSEMBLY AND OUTFITTING
               JOINING PARTS AND SUB-ASSEMBLIES TOGETHER TO
               FORM LARGE SECTION OF THE SHIP CALLED HULL
               BLOCKS.
                                   SYSTEM COMPLETION AND TEST AND TRIAL
                                                               INSTALLATION OF THE HULL BLOCK ONTO THE SHIP
                                                               UNDER CONSTRUCTION, THUS THE SHIP IN BHNa
                                                               ERECTED.
                SYSTEMS ON THE SHIP (!•«•. ELECTRICAL, HEATING
                AND VENTILATION, PLUMBING, ETC.) ARE CONNECT-
                ED TOGETHER, TESTED, AND TESTED BEFORE DELIV-
                ERY TO THE CUSTOMER.
                       Source: Adapted from NSRP, Introduction to Production Processes and Facilities in the
                       Steel Shipbuilding and Repair Industry, 1993.
                       Another important aspect of ship construction is outfitting.  Outfitting, which
                       involves the fabrication and installation of all the parts of a ship that are not
                       structural in nature, is carried out concurrently with the hull construction.
                       Outfit is comprised of the ship's plumbing, derricks, masts, engines, pumps,
                       ventilation ducts, electrical cable, stairs, doors, ladders, and other equipment.
                       The basic raw materials include pipes, sheet metal, electrical components, and
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Shipbuilding and Repair Industry
                Industrial Process Description
                     machinery.   A zone-oriented method is typically used to assemble the parts
                     that form major machinery spaces onboard the ship including engine rooms,
                     pump rooms,  and auxiliary machinery spaces.  Parts or fittings can  be
                     assembled onboard the ship during hull erection, on the blocks or subblocks,
                     or independent of the hull structure in units of similar parts (NSRP, 1993).

       III.A.4. Major Production Facilities

                     Most shipbuilding yards have in common the following major facilities, work
                     areas, or specialized equipment.
       Prime Line
       Panel Lines
       Platen Lines
                     The prime line is a large machine that blasts and primes (paints) ra.w steel
                     sheets, preparing them for production.  Steel sheets, parts, and shapes enter
                     one end of the prime line, go through a blasting section,  then through a
                     priming section. The primer is referred to as construction primer, and is used
                     to prevent corrosion during the production process.  Section III. A. 9 discusses
                     surface preparation and coating operations in more detail (NSRP, 1993).
                     Panel lines typically consist of motor driven conveyors and rollers used to
                     move large steel plates together for joining. The use of panel lines introduced
                     manufacturing production line techniques into the steel shipbuilding industry.
                     Joining of plates involves the welding of the seams either on one side or two
                     sides. Two sided welding requires the panel line to be capable of turning the
                     steel plates over after one-side is welded.  Vertical stifFeners are also welded
                     on the panel line often using automated welding machines.  After welding,
                     excess steel is cut off using gas cutting equipment. Panel assemblies are
                     typically moved through the line with the  aid of magnetic cranes (NSRP,
                     1993).
                     The platen lines (or platens) are the area in the shipyard where blocks are
                     assembled. Therefore, platens form assembly lines where the steel structures
                     of construction blocks are fabricated. Sub-assemblies from the panel line and
                     plate shop are brought together at the platen and assembled into blocks.  The
                     platen mainly provides locations for sub-assembly construction, block layout,
                     tack-welding, and final weld out. The platen lines are serviced by welding and
                     steel cutting equipment and cranes for materials movement (NSRP, 1993).
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       Rolls
       Pin Jigs
                     Rolls are large facilities that bend and shape steel plates into curved surface
                     plates for the curved portion of the hull. Rolls consist of large cylindrical steel
                     shafts and a motor drive.  Rolls vary greatly in size and technology from
                     shipyard to shipyard. Some of the newer rolls are computer controlled, while
                     the older machines are manually operated (NSRP, 1993).
                     Pin jigs are platen lines used to assemble the curved blocks that form the
                     outside of the hull's curved surface. The pin jig is simply a series of vertical
                     screw jacks that support curved blocks during construction.  A pin jig is set
                     up specifically for the curved block under construction.  The jig heights are
                     determined from the ship's engineering drawings and plans (NSRP, 1993).
       Rotary Tables
                     Rotary tables are facilities that hull blocks are set into and which mechanically
                     rotate the block. The ability to easily rotate an entire block in a single location
                     reduces the number of time-consuming crane lifts that would otherwise be
                     needed.  Rotary tables also exploit the increased efficiencies experienced when
                     workers are able to weld on a vertical line (down hand).  Down hand welding
                     provides a higher quality weld with higher efficiency rates. Turn tables are
                     also used for outfitting materials on the block because of easier access to
                     outfitting locations (NSRP, 1993).
       Materials Handling
                     Materials handling  is  an  important aspect  of efficient  shipbuilding.
                     Considerable coordination is needed between materials delivery and the
                     production schedule. Materials need to be delivered to the proper location in
                     the shipyard at the proper time to be installed on the construction block.
                     Typical materials handling equipment includes conveyors, cranes, industrial
                     vehicles (e.g.,  forklifts,  flatbeds,  carts, special  lift vehicles,  etc.),  and
                     containers (NSRP, 1993).
       m.A.5.  Welding
                     The structural framework of most ships is constructed of various grades of
                     mild and high strength steel.  Aluminum and other nonferrous materials are
                     used for some  superstructures  (deck-houses)  and other areas requiring
                     specific corrosion resistance and structural  requirements.  However, other
                     common materials such as stainless steel, galvanized steel, and copper nickel
                     alloys, are used in far less quantities than steel (ILO, 1996).
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                     The primary raw material for ship construction is steel plate.  Steel plates are
                     typically cut to the desired size by automatic burners before being welded
                     together to form the structural components of the vessel.

                     Shipyard welding processes are performed at nearly every location in the
                     shipyard.  The  process involves joining metals by bringing the adjoining
                     surfaces to extremely high temperatures to be fused together with a molten
                     filler material.  An electric arc or gas flame are used to heat the edges of the
                     joint, permitting them to fuse with molten weld fill metal in the form of an
                     electrode, wire, or rod. There are many different welding techniques used by
                     the industry. Most welding techniques can be classified as either electric arc
                     or gas welding, with electric arc being the most common (ELO, 1996).

                     An important factor impacting the strength of welds is arc shielding, isolating
                     the molten metal weld pool from the atmosphere.  At the extremely high
                     temperatures used in welding, the molten metal reacts rapidly with oxygen and
                     nitrogen in the atmosphere which decreases the weld strength.  To protect
                     against this weld impurity and ensure  weld quality, shielding from the
                     atmosphere is required. In most welding processes, shielding is accomplished
                     by  addition of a flux, a gas,  or a combination of the two.  Where a flux
                     material is used, gases generated by vaporization and chemical reaction at the
                     electrode tip result in a combination of flux and gas shielding that protect the
                     weld from the atmosphere.  The various types of electric arc welding (shielded
                     metal arc, submerged arc,  gas metal arc, gas tungsten arc, flux core airc, and
                     plasma-arc) all use different methods to accomplish arc shielding (TLO, 1996).

       I1I.A.6.  Ship Repairing Processes

                     Ship repair generally includes all ship conversions, overhauls, maintenance
                     programs, major damage repairs, and minor equipment repairs.  Although
                     specific repair methods vary from job to job, many of the operations are
                     identical to new  ship construction operations.  Repair operations, however,
                     are typically on a smaller scale and are performed at a faster pace. Jobs can
                     last anywhere from one day to over a year.  Repair jobs often have severe time
                     constraints requiring work to be completed as quickly as possible in order to
                     get the ships back in service. In many cases, piping, ventilation, electrical, and
                     other machinery are prefabricated prior to the ship's arrival. Often, repair jobs
                     are an emergency situation with very little warning, which makes ship repair
                     a fast moving and unpredictable environment. Typical maintenance and repair
                     operations include:

                     •       Blasting and repainting the ship's hull, freeboard, superstructure, and
                            interior tanks and work areas

                     •       Major rebuilding and installation of machinery such as diesel engines,
                            turbines,  generators, pump stations,  etc.
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                     •      Systems overhauls, maintenance, and installation (e.g., piping system
                            flushing, testing, and installation)

                     •      System replacement  and new  installation of  systems such  as
                            navigational  systems,  combat  systems,  communication systems,
                            updated piping systems, etc.

                     •      Propeller and rudder repairs, modification, and alignment

                     •      Creation of new machinery spaces through cut outs of the existing
                            steel structure and  the addition of hew walls, stiffeners, vertical,
                            webbing, etc.

                     In addition, some larger shipyards are capable of large repair and conversion
                     projects that could include: converting supply ships to hospital ships,  cutting
                     a ship in half and installing a new section to lengthen the  ship,'replacing
                     segments  of a ship that has  run aground, completing rip-out, structural
                     reconfiguration and outfitting of combat systems, major remodeling of ships'
                     interiors or exteriors (NSRP, 1993).

       IH.A.7.  Support Shops and Services

                     Shipyards typically have a number of support shops that  either process
                     specific raw materials (e.g., pipes, electric, sheet metal, machinery, plates,
                     paint,  etc.) or provide specialty services (e.g., carpentry, maintenance,
                     materials transporting, warehousing, etc.).  In many ways,  support shops are
                     small manufacturers producing goods to support  the  production effort
                     (NSRP, 1993).  Common shipbuilding  and repair yard support  shops and
                     services are described below.
       Pipe Shop
                     The pipe shop is responsible for manufacturing and assembling piping systems.
                     Piping systems are the largest outfitting task in shipbuilding.  Small pipe
                     sections known  as  "pipe spools" are assembled  in  the  pipe shop and
                     transported to the stages of construction (i.e., assembly, on-block, on-unit,
                     and on-board).  Pipe spools are shaped and manufactured per engineering
                     design, are scheduled for construction, and sent to the various stages for
                     installation. Many pipe shops will tag the spools to identify the location for
                     installation on the block and ship. A typical ship may have anywhere from
                     10,000 to 25,000 pipe spools.   Some of the processes in the pipe shop
                     include: pipe welding, pipe bending,  flux removal,  grit-blast, pickling,
                     painting, galvanizing, and pressure testing.  Some of the equipment used by
                     the pipe shop  are as follows: pipe welders, lathes, pipe cutting saws, shears,
                     grinders,   chippers,   hole  cutters,  pipe benders,  pickling  tanks,  and
                     transportation equipment (NSRP, 1993).
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       Machine Shop
                     The machine shop serves the entire shipyard's machining needs though the
                     exact functions  of the  shipyard  machine  shops  vary throughout  the
                     shipbuilding industry.  Shipyard machine shops perform functions ranging
                     from rebuilding pumps to turning 25 foot long propeller drive shafts on lathes.
                     Equipment in the machine shop consists of: end mills, lathes, drill presses,
                     milling machines, band saws, large presses, work tables, and cleaning tanks
                     (NSRP, 1993).
       Sheet Metal Shop
                     The sheet metal shop is generally responsible for fabricating and installing
                     ventilation ducting and vent spools. Using engineering drawings and special
                     sheet metal tools this shop produces ventilation systems for new construction,
                     as well as repair work. The shop cuts, shapes, bends, welds, stamps, paints,
                     and performs a variety of manufacturing operations for ship ventilation
                     systems. Many sheet metal shops are also responsible for assembling large
                     ducting fans and heating  and air conditioning components.  Sheet metal
                     workers perform  the  installation of the  ducting  in  various stages  of
                     construction such as on-block, on-unit, onboard (NSRP, 1993).
       Electrical Shop
                     Electrical shops in the shipyard perform a variety of functions throughout the
                     industry.  In many cases, the electrical shop installs, rebuilds, builds, and tests
                     electrical components (e.g., motors, lights, transformers, gauges, etc.). The
                     electrical shop electricians also install the electrical equipment on the ship
                     either on-block  or  onboard.   On-block is where the electrical  parts are
                     installed and  onboard is where  cables are routed  throughout the ship
                     connecting the electrical systems  together. Electric  shops generally have
                     plating tanks, dip  tanks for lacquer coatings,  electrical testing equipment, and
                     other specialized equipment (NSRP, 1993).
       Foundry/Blacksmith Shop
                     The blacksmith shop is an older term used for the shipyard shop that performs
                     forging or castings.  Forging and casting at shipyards are somewhat rare.
                     Over the years, forging  and casting functions  have  been  shifted  to
                     subcontractors off-site.  The subcontractors are usually foundries whose
                     primary function is forging and casting. Shipyards that have blacksmith shops
                     maintain large furnaces and other foundry equipment (NSRP, 1993).
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        Plate Shop
                     The plate shop is a generic term used for the area and process in the shipyard
                     that provides steel parts cutting, bending, and sub-assembly.  The plate shop
                     uses information from engineering drawings to produce plate shapes. The
                     shapes are cut and formed as needed. Most plate shops have manual and
                     computer controlled machinery.  The types of machinery commonly found in
                     the plate shop are cutting machines, steel bending machines and plate bending
                     rolls, shearing machines,  presses, hole punching equipment, and furnaces for
                     heat treatment. The plate shop sends the parts and sub-assemblies that they
                     manufacture to the stages of construction, or the platen area for installation
                     (NSRP,  1993).

       Production Services

                     Services provided by this  department include:  carpentry, scaffolding erection,
                     crane operations, rigging, facility and equipment maintenance,  and other
                     production support activities. The production services may be grouped into
                     one department  or divided into unique shops for each service provided
                     (NSRP, 1993).

       m.A.8.  Solvent Cleaning and Degreasing

                     Solvent cleaning and degreasing are common in the shipbuilding  and repair
                     industry (although many facilities  are replacing solvent cleaning and
                     degreasing with  aqueous and alkaline cleaning and degreasing). Solvent
                     cleaning and degreasing are typically accomplished by either cold cleaning or
                     vapor degreasing. Cold cleaning refers to operations in which the solvent is
                     used at room  temperature. The surfaces or parts are soaked in a tank of
                     solvent,  or  sprayed,  brushed,  wiped, or flushed  with  solvent.   Diphase
                     cleaning  is sometimes used to  combine a water rinse before and after the
                     solvent cleaning  into a  single step.   In diphase cleaning, water insoluble
                     halogenated solvents and water are placed in a single tank where they separate
                     with the  solvent  on the bottom. Parts are lowered through the water bath
                     before reaching the solvent and then are rinsed through the water level as they
                     are removed from the tank.

                     In vapor degreasing, parts and surfaces are cleaned with a hot solvent vapor.
                     Solvent in a specially designed tank is boiled creating a solvent vapor in the
                     upper portion of the tank.  The parts are held in the vapor zone where solvent
                     vapor condenses on the surface removing dirt and oil as it drips back into the
                     liquid solvent. In this way, only clean solvent vapors come in contact with the
                     part. A  condensing coils at the top  of the tank reduces the amounts of
                     solvents escaping to the atmosphere (NSRP,  1993).
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       HI.A.9. Surface Preparation
                     To a large extent, the effectiveness of the surface coating relies on the quality
                     of surface preparation.  All paints will fail eventually, but the majority of
                     premature failures are due to loss of adhesion caused by improper surface
                     preparation.  Surface preparation is also typically one of the most significant
                     sources of shipyard wastes and pollutant outputs.  Section III.B.l discusses
                     waste generation and pollution outputs from these operations.

                     Surface preparation techniques are used to remove surface contaminants such
                     as mill scale, rust, dirt, dust, salts, old paint, grease, and flux.  Contaminants
                     that remain on the surface are the primary causes of premature failure of
                     coating systems.  Depending on the surface location,  contaminants, and
                     materials, a number of different surface preparation techniques are used in the
                     shipbuilding and repair industry:
                            Solvent, Detergent, and Steam Cleaning
                            Blasting
                            Hand Tool Preparation
                            Wet Abrasive Blasting and Hydroblasting
                            Chemical Preparation
       Solvent, Detergent, and Steam Cleaning
        Blasting
                     The process of removing grease, oil and other contaminants with the aid of
                     solvents, emulsions, detergents, and other cleaning compounds is frequently
                     used for surface preparation in the shipbuilding industry. Solvent cleaning
                     involves wiping, scrubbing, immersion in solvent, spraying, vapor degreasing,
                     and emulsion cleaning the surface with rags or brushes until the surface is
                     cleaned. The final wipe down must be performed with a clean rag or brush,
                     and solvent. Inorganic compounds such as chlorides, sulfates, weld flux, rust
                     and mill scale cannot be removed with organic solvents.

                     In many cases steam cleaning is a better alternative to solvent wipe down.
                     Steam cleaning or high pressure washing is used to remove dirt and grime that
                     is present on top of existing paint and bare steel.  Many hot steam, cleaners
                     with detergents will remove most petroleum products and sometimes, old
                     chipping paint.  After steam cleaning the part should be rinsed with fresh
                     water and allowed to dry. Often the surface is ready to prime, although many
                     surfaces will require further preparation before painting.
                      Abrasive blasting is the most common method for paint removal and surface
                      preparation.  Copper slag, coal slag, steel grit, and steel shot are common
                      blasting abrasives.  Copper and steel grit consist of small angular particles,
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                     while steel shot is made up of small round balls. Copper slag can generally be
                     used only once or twice before it becomes too small to be effective.  Steel grit
                     and shot can typically be used between 50 and 5,000 times before becoming
                     ineffective.  Metallic grit and shot are available in varying ranges of hardness
                     and size.

                     Centrifugal blasting machines, also called roto-blasting or automatic blasting,
                     are one of the more popular methods of blasting steel surfaces.  In centrifugal
                     blasting, metallic shot or grit is propelled to the surface to be prepared by a
                     spinning wheel.  Centrifugal blasting machines tend to be large and not easily
                     mobilized.  Therefore, they are not applicable to all shipyard blasting needs.
                     Parts to be prepared must be brought to the machine and passed through on
                     a conveyor or rotary table. On flat surfaces, centrifugal blasting machines can
                     produce uniform blasting results at high production rates.  More time is
                     required to prepare surfaces that are hard to reach. The process allows easy
                     recovery of  abrasive materials for reuse and recycling which can result in
                     significant savings in materials and disposal costs. Large centrifugal blasting
                     machines are often found in the prime line for preparing raw steel sheets
                     before priming.  Other centrifugal blasting machines are smaller and can be
                     used to prepare small parts,  pipe  spools,  and steel subassemblies prior to
                     painting.

                     Air nozzle blasting (or dry abrasive blasting) is one of the most common types
                     of blasting in the shipbuilding and repair industry.  In air  nozzle blasting,
                     abrasive is conveyed to the  surface to be prepared in a medium of high
                     pressure air (approximately 100 pounds per square inch) through a nozzle at
                     velocities approaching 450 feet per second.  Abrasives are copper slag, coal
                     slag  and other metallic grit. Typically copper slag is used on the west coast
                     and  coal slag is used on the east  coast. Traditionally sand was used, but
                     metallic grit has replaced it due to the adverse health  and environmental
                     effects of silica dust associated with sand.  Air nozzle blasting is  generally
                     carried  out manually by shipyard workers  either within a building or in the
                     open air, depending on the application.  If the application allows, blast booths
                     can be used for containing abrasives.

       Hand Tool Preparation

                     Hand tools such as grinders, wire brushes, sanders, chipping hammers, needle
                     guns, rotary peening tools, and other impact tools are commonly used in the
                     shipyard for surface preparation. The hand tools are ideal for small jobs, hard
                     to reach areas, and areas where blasting grit would be too difficult to contain.
                     Cleaning surfaces with hand tools seems comparatively slow although, when
                     removing heavy paint formulations and heavy rust, they are effective and
                     economical. Impact tools like chipping and needle guns are best for removing
                     heavy deposits of brittle substances (e.g., rust and old paint). Hand tools are
                     generally less effective when  removing tight surface mill scale or surface
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                     rusting, because they can damage the metal surface. Surface preparation hand
                     tools are generally pneumatic instead of electric because they are lighter, easy
                     to handle, do not overheat, and there is no risk of electric shock.

       Wet Abrasive Blasting and Hydroblasting

                     Wet abrasive blasting and hydroblasting are generally performed on ships
                     being repaired in a floating drydock, graving dock, or other building or repair
                     position.  Wet abrasive blasting involves blasting with a mixture of water, air
                     and solid abrasives.  Wet abrasive blasting does not occur throughout the
                     shipyard like dry abrasive blasting because of the problem of water blast
                     containment.  In part  due  to lack of customer acceptance, wet abrasive
                     blasting is not common in the shipbuilding and repair industry at this time.
                     Instead, hydroblasting is a widely used wet blasting technique which uses only
                     high pressure water to remove chipping paint, marine growth, mud, and salt
                     water from the ship's hull. A small amount of rust inhibitor may be used in
                     the water to prevent flash rusting.  Hydro basting is often followed  by air
                     nozzle blasting for final surface preparation.

       Chemical Preparation

                     Chemical surface preparations consist of paint removers, alkaline cleaning
                     solutions, chlorinated solvents, and pickling. Alkaline cleaning solutions come
                     in a variety of forms and are used in a variety of manners. Alkaline cleaners
                     can be brushed on, sprayed on, and applied in a dip tank.  Alkaline dip tanks
                     of caustic soda solution are frequently used for cleaning parts and preparing
                     them for painting.  After the surface is cleaned, it is thoroughly rinsed before
                     a coating system is applied. Many solvents and alkaline cleaners cannot be
                     used for nonferrous materials, such as bronze, aluminum, and galvanized steel
                     which are frequently found on ships.

                     Pickling is a process of chemical abrasion/etching which prepares surfaces for
                     good paint adhesion.  The pickling process is used in shipyards  mainly for
                     preparing pipe systems  and small parts for paint. However, the process and
                     qualities will vary from shipyard to shipyard.  The process involves a system
                     of dip tanks. Figure 5  displays how the tanks can be arranged. In pickling
                     steel parts and piping systems, Tank #1 is used to remove any oil, grease, flux,
                     and other contaminants on the surface being pickled. The content in tank #1
                     are generally  a 5-8%  caustic soda and  water  mixture maintained at
                     temperatures of between  180°-200°F. The part is then immersed into tank
                     #2, which is the caustic soda rinse tank (pH 8-13).  Next, the steel is dipped
                     into tank #3B, which  is  a  6-10% sulfuric acid/water mixture maintained
                     between  140°-160°F. Tank #4 is the acid rinse tank that is maintained at a
                     pH of 5-7. Finally the steel pipe or part is immersed in a rust preventative 5%
                     phosphoric mixture in tank #5.  The part is allowed to fully dry prior to paint
                     application.
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                  Figure 5: Typical Pickling Tank Arrangement
                        Steel Parts
                       Caustic Tank
                            #1
                       Rinse Water
                         '  #2
      Copper and
     Copper-Nickel
      Alloy Parts
                       Sulfuric Acid
                           #3B
      Nitric Acid
         #3A
                                     Rinse Water
                                         #4
                          Rust
                       Preventative
                           #5
                            i
                        Steel Parts
      Copper and
     Copper-Nickel
      Alloy Parts
                     Some ships have large piping systems that are predominantly copper-nickel
                     alloy or copper. Pickling of copper is generally only a two-step process. The
                     first step is to  dip the pipe into  tank  #3 A, a 3-6% nitric acid  solution
                     maintained at 140°-160°F.  The nitric acid removes any flux and greases that
                     are present on the surface and prepares the surface for paint.  Next, the pipe
                     is dipped into the acid rinse tank  (#4),  after which it is  considered to be
                     treated.  Once the part is dry, the final coating can be applied.
       Metal Plating and Surface Treatment
                    Metal plating and surface treatment are used in shipyards to alter the surface
                    properties of the metal in order to increase corrosion or abrasion resistance,
                    and to  improve electrical conductivity (Kura, 1996).  Metal plating and
                    surface treatment includes chemical and  electrochemical  conversion, case
                    hardening, metallic coating,  and electroplating.  Thorough descriptions of
                    these processes and their associated wastes are contained in the Fabricated
                    Metal Products Industry Sector Notebook.
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       m.A.10. Painting Processes
                     Proper surface coating system application is essential in the shipbuilding and
                     repair industry.  The corrosion and deterioration associated with the marine
                     environment has detrimental effects on ships and shipboard components.
                     Maintaining ships' structural integrity and the proper functioning of their
                     components are the main purposes of shipboard coating systems.

                     Painting is performed at almost every location within shipyards. This is due
                     to the wide variety of work performed throughout shipyards.  The nature of
                     shipbuilding and repair requires  several types of paints to  be used for a
                     variety of applications. Paint types range from water-based coatings to high
                     performance epoxy coatings.  The type  of paint needed  for a certain
                     application depends on the environment that the coating will be exposed. In
                     general there are six areas where shipboard paint requirements exist:
                            Underwater (Hull Bottom)
                            Waterline
                            Topside Superstructures
                            Internal Spaces and Tanks
                            Weather Decks
                            Loose Equipment
                     Because paint systems are often specified by the customer or are supplied by
                     the ship owner, shipyards often may not be able to choose or recommend a
                     particular system. Navy ships may require a specific type of paint for every
                     application through a military specification (Mil-spec). Many factors are
                     considered when choosing a particular application. Among the factors are
                     environmental  conditions, severity of environmental exposure, drying and
                     curing times, application equipment and procedures, etc.
       Paint Coating Systems
                     Paints are made up of three main ingredients: pigment, binder, and a solvent
                     vehicle. Pigments are small particles that generally determine the color as well
                     as many other properties associated with the coating. Examples of pigments
                     include: zinc oxide, talc, carbon, coal tar, lead, mica, aluminum, and zinc dust.
                     The binder can be  thought of as the glue that holds the paint pigments
                     together. Many paints are referred to by their binder type (e.g., epoxy, alkyd,
                     urethane, vinyl, phenolic, etc.).   The binder is also very important for
                     determining a coating's performance characteristics (e.g., flexibility, chemical
                     resistance, durability, finish,  etc.). The solvent is added to thin the paints so
                     that it will flow to the surface and then dry.  The solvent portion of the paint
                     evaporates  when the paint  dries.  Some typical solvents include acetone,
                     mineral spirits, xylene, methyl ethyl ketone, and water.
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                     Anticorrosive and antifouling paints are typically used on ship's hulls and are
                     the main two types of paint used in the shipbuilding industry. Antifouling
                     paints are used to prevent the growth of marine organisms on the hull of
                     vessels.  Copper-based and  tributyl-tin-based paints are widely used as
                     antifouling paints.  These paints release small quantities of toxics which
                     discourage marine life from growing on the hull.  Anticorrosive paints are
                     either vinyl, lacquer, urethane, or newer epoxy-based coating systems (ILO,
                     1996).

                     The first coating system applied to raw steel sheets and parts is generally pre-
                     construction primer.  This pre-construction primer is sometimes referred to
                     as shop primer. This coat of primer is important for maintaining the condition
                     of the part throughout the construction process. Pre-construction priming is
                     performed on steel plates, shapes, sections of piping, and ventilation ducting.
                     Most pre-construction primers are zinc-rich with organic or inorganic binders.
                     Zinc silicates are predominant among the inorganic zinc primers.  Zinc coating
                     systems protect coatings in much the same manner as galvanizing. If zinc is
                     coated on steel, oxygen will react with the zinc to form zinc oxide, which
                     forms a tight layer that does not allow water or air to come into contact with
                     the steel (ILO, 1996).

       Paint Application Equipment

                     There are many types of paint application equipment used in the shipbuilding
                     industry. Two main methods used are compressed air and airless sprayers.
                     Compressed air sprayers are being phased out in the industry because of the
                     low transfer ability of the system. Air assisted paint systems spray both air
                     and paint, which causes some paint to atomize and dry quickly prior to
                     reaching the intended surface.  The transfer efficiency of air assisted spray
                     systems can vary from 65% to 80%.  This low transfer efficiency is due mainly
                     to overspray,  drift, and the air sprayer's inefficiencies (ILO, 1996).

                     The most widely used form of paint application in the shipbuilding industry is
                     the airless sprayer. The airless sprayer is a system that simply compresses
                     paint in a hydraulic line and has a spray nozzle at the end.  Airless sprayers use
                     hydrostatic pressure instead of air to convey the paint. They are much cleaner
                     to operate and have fewer leaking problems because the system requires less
                     pressure.  Airless sprayers can have up to 90% transfer efficiency.  A new
                     technology that can be added to the airless sprayer is called High Volume
                     Low Pressure (HVLP).  HVLP offers an even higher transfer efficiency, in
                     certain conditions (ILO, 1996).

                     Thermal spray is the application of aluminum or zinc coatings to steel for long
                     term corrosion protection.  Thermal spray can  also be referred to as metal
                     spray or flame spray.   Thermal  spray is  significantly  different  than
                     conventional coating practices due to its specialized equipment and relatively
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                     slow production rates.  The initial cost of thermal spray is  usually high
                     compared to painting, although when the  life-cycle is taken into account,
                     thermal spray becomes more economically  attractive. Many shipyards have
                     their own thermal spray machines and other shipyards will subcontract their
                     thermal coating work. Thermal spray can occur in a shop or onboard the ship.
                     There are two basic types of thermal coating machines: combustion wire and
                     arc spray. The combustion wire type consists of combustible gasses and flame
                     system with a wire feed controller. The combustible gasses melt the material
                     to be sprayed onto the parts.  The electric  arc spray machine instead uses a
                     power supply arc to melt the flame sprayed material (ILO, 1996).

       Painting Practices and Methods

                     Painting  is performed in nearly every area in the shipyard from the initial
                     priming of the steel to the final paint detailing of the ship.  Methods for
                     painting vary greatly from process to process. Mixing of paint  is performed
                     both manually and mechanically and should be done in  an area  contained by
                     berms, tarps, secondary containment pallets.  Outdoor as  well as indoor
                     painting occurs in the shipyard.  Shrouding fences, made of steel, plastic, or
                     fabric, are frequently used to help  contain paint overspray by  blocking the
                     wind and catching paint particles (NSRP, 1996)v

                     Hull painting occurs on both repair ships and new construction ships.  Hull
                     surface preparation and painting on repair ships is normally performed when
                     the ship is fblly drydocked (i.e., graving-dock or floating drydock). For new
                     construction, the hull is prepared and painted at a building position using one
                     of the techniques discussed  in the previous sections. Paint systems are
                     sprayed onto the hull using airless sprayers and high reach equipment such as
                     man-lifts, scissor lifts, or portable scaffolding (ILO, 1996).

                     The superstructure of the ship consists of the exposed decks,  deck houses,
                     and  structures above the  main deck.   In  many cases, scaffolding is used
                     onboard the ship to reach  antennas, houses, and other superstructures.
                     Shrouding is usually put into place if it is likely that paint or blast material will
                     fall into adjacent waters. On repair ships, the ship's superstructure is painted
                     mostly while berthed. The painters access  the superstructures  with existing
                     scaffolding, ladders, and various lifting equipment that  was used during
                     surface preparation. The shrouding system (if applicable) that  was used for
                     blast containment will stay in place to help contain any paint overspray (ILO,
                     1996).

                     Tanks and  compartments  onboard ships must  be coated and  re-coated to
                     maintain the longevity of the ship. Re-coating of repair ship tanks requires.a
                     large amount of surface preparation prior  to painting.  The majority of the
                     tanks are at the bottom of the ship (e.g., ballast tanks, bilges, fuel, etc.).  The
                     tanks are prepared for paint by using solvents and detergents to  remove
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                     grease and oil build-up. The associated waste-water developed during tank
                     cleaning must be properly treated and disposed of. After the tanks are dried,
                     they are blasted with a mineral slag.  Once the surface is blasted and the grit
                     is removed, painting can begin. Adequate ventilation and respirators are a
                     strict requirement for all tank and compartment surface preparation and
                     painting (ELO, 1996).

                     Painting is also carried out after the assembly of hull blocks. Once the blocks
                     leave the assembly area, they are frequently transported to a blast area where
                     the entire block is prepared for paint.  At this point, the block is usually
                     blasted back down to bare metal (i.e., the construction primer is removed).
                     However,  many shipyards  are  now  moving towards implementing  a
                     preconstruction primer that does not need to be removed. The most frequent
                     method for block surface preparation is air  nozzle blasting.  The paint system
                     is applied by  painters generally using airless spray equipment on access
                     platforms.  Once the block's coating system has been applied, the block is
                     transported to the on-block stage where outfitting materials are installed (TLO
                     1996).

                     Many parts need to have a coating system applied prior to installation. For
                     example, piping spools, vent ducting, foundations, and doors are painted
                     before they are installed on-block.  Some small parts painting occurs in the
                     various shops while others are painted in a  standard location operated by the
                     paint department (ILO, 1996). Indoor painting of this type usually occurs in
                     a spray booth.  Spray booths capture overspray, control the introduction of
                     contaminants to the workplace environment,  and reduce the likelihood of
                     explosions and fires.  Paint booths are categorized by the method used for
                     collecting the overspray (EPA, 1995).

                     The two primary types of paint booths are dry filter and water wash booths.
                     Dry filter booths use filter media (usually paper or cloth filters) to screen out
                     the paint solids by pulling prefiltered air through the booth, past the spraying
                     operation, and through the filter media.  Water wash booths use a "water
                     curtain" to capture paint overspray by pulling air containing entrained paint
                     overspray through a circulated water stream which "scrubs" the overspray
                     from the air.  Water is periodically added to the paint booth reservoir to
                     compensate for evaporative losses, and chemicals are periodically added to
                     improve paint sludge formation.  The sump is periodically discharged, usually
                     during general system cleaning or maintenance (EPA, 1995).

       IH.A.11. Fiberglass Reinforced Construction Operations

                     Many of the medium and small shipyards manufacture and repair fiberglass
                     ships and boats or construct fiberglass parts for steel ships. The process
                     involves combining polymerizing resin with fiberglass reinforcing material.
                     The resin is polymerized with a catalyst or curing agent.  Once cured, the hard

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Shipbuilding and Repair Industry
                Industrial Process Description
                     resin cannot be softened or reshaped and is stronger than composite plastics
                     without the reinforcing. Fiberglass material consists of a woven mat of glass-
                     like fibers. The fiberglass content of the reinforced product ranges from 25 to
                     60 percent.

                     A number of different processes are used, but the mold-based process is the
                     most common for this industry. Mold-based fiberglass reinforced construction
                     typically involves either the hand application or spray application of fiberglass
                     reinforcing. In the hand application method,  the reinforcing material is
                     manually applied to a mold wetted with catalyzed resin mix or gelcoat and
                     then sprayed or brushed with more resin or gelcoat. In the sprayup method,
                     catalyzed resin and fiberglass reinforcement are mechanically sprayed onto the
                     mold surface.

                     Molds are used to give structure and support to the shape of the structure
                     being built. Most molds are made of wood with a plastic finish. Typical resins
                     used  include: polyesters, epoxies, polyamides, and phenolics.  The type of
                     resin to  be used in a particular process depends on the specific properties
                     required for the end product. The resin is supplied in liquid form and may
                     contain a solvent. Resin preparation involves mixing with solvents, catalysts,
                     pigments,  and other  additives. Solvents are typically acetone, methanol,
                     methyl ethyl ketone, and styrene. Catalysts are typically amines, anydrides,
                     aldehyde condensation products, and Lewis acid products. Gelcoat is a
                     pigmented  polyester  resin  or a polyester resin-based  paint  containing
                     approximately 35 percent styrene that is applied to the mold or surface with
                     an air atomizer or airless spray gun.  A catalyst is injected into the resin in a
                     separate line or by hand mixing in order to thermoset the polyester resin.
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Shipbuilding and Repair Industry                           Industrial Process Description

m.B.  Raw Material Inputs and Pollutant Outputs

                     Raw material inputs to the shipbuilding and repair industry are primarily steel
                     and other metals, paints and solvents, blasting abrasives,  and machine and
                     cutting oils.  In addition, a wide variety of chemicals are used for surface
                     preparation and finishing such as  solvent degreasers,  acid  and alkaline
                     cleaners, and cyanide and metal bearing plating solutions.  Pollutants and
                     wastes generated typically include VOCs, particulates, waste solvents, oils and
                     resins, metal bearing sludges and wastewater, waste paint, waste paint chips,
                     and spent abrasives.  The major shipyard activities that generate wastes and
                     pollutant outputs are discussed below and are summarized in Table 3.

       m.B.1. Surface Preparation

                     The materials used and wastes generated during surface preparation depend
                     on the specific methods used. The surface  preparation method is chosen
                     based on the  condition of the  metal surface (e.g., coated with paint, rust,
                     scale, dirt, grease, etc.), the type of coating to be applied, the size, shape, and
                     location  of the surface, and the type of metal.   Material inputs used  for
                     preparing surfaces include: abrasive materials such as steel shot or grit, garnet,
                     and copper or coal slag; and cleaning water, detergents, and chemical paint
                     strippers (e.g., methylene chloride-based solutions, caustic solutions, and
                     solvents).  In the case of hydroblasting, only  water and  occasionally rust
                     inhibitor are required (NSRP, 1996).
       Air Emissions
                     Air emissions  from  surface  preparation  operations  include  particulate
                     emissions of blasting abrasives, and paint chips. Particulates emissions can
                     also contain toxic metals which are a concern both in the immediate area
                     surrounding the work and if they are blown off-site or into surrounding
                     surface waters.  Particulate emissions are typically controlled by preparing
                     surfaces  indoors when  possible or by surrounding the work area with
                     shrouding fences made of steel, plastic, or fabric.  Other air emissions that
                     could potentially arise during surface preparation operations are VOCs and
                     hazardous air pollutants (HAPs) arising from the use of solvent cleaners, paint
                     strippers, and degreasers.

       Residual Wastes

                     The primary residual waste generated is a mixture of paint chips and used
                     abrasives. Paint chips containing lead or antifouling agents may be hazardous,
                     but often in practice the concentration of toxic compounds is reduced due to
                     the presence of considerable amounts of spent blasting medium.  The resulting
                     mixed waste may be nonhazardous (Kura, 1996).  Waste sludge containing
                     paint chips and surface contaminants may also be generated in the case of

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Shipbuilding and Repair Industry	Industrial Process Description

                     hydroblasting or wet abrasive blasting. Blasting abrasives and paint chips that
                     collect in tank vessels, ship decks, or drydocks should be thoroughly cleaned
                     up and collected after work is completed or before the drydock is flooded or
                     submerged. Particular attention should be paid to the cleanup of paint chips
                     containing the antifouling tributyl-tin (TBT) compounds which have been
                     shown to be highly toxic to oysters and other marine life (Levy, 1996).
       Waste\vater
                     Significant quantities of wastewater can be generated when cleaning ship
                     cargo tanks, ballast tanks, and bilges prior to surface preparation and painting.
                     Such wastewater is often contaminated with cleaning solvents, and oil and fuel
                     from bilges and cargo tanks. Wastewater contaminated with paint chips and
                     surface  contaminants  is generated when hydroblasting and wet abrasive
                     blasting methods are used (EPA, 1991).
       III.B.2. Painting
                     Material inputs for painting are primarily paints and solvents. Solvents are
                     used in the paints to carry the pigment and binder to the surface, and for
                     cleaning the painting equipment. VOCs and HAPs from painting solvents are
                     one of the most important sources of pollutant outputs for the industry.
                     Paints also may contain toxic pigments such as chromium, titanium dioxide,
                     lead, copper, and tributyl-tin compounds. Water is also used for equipment
                     cleaning when water-based paints are used.
       Air Emissions
                     Painting can produce significant emissions of VOCs and HAPs when the
                     solvents in the paint volatilize as the paint dries. Other sources of VOCs and
                     HAPs may arise when solvents are used to clean painting equipment such as
                     spray guns, brushes, containers, and rags.  Sprayed paint that does not reach
                     the  surface being coated, or overspray,  is another source of painting air
                     emissions.  The solvents in the overspray rapidly volatilize and the remaining
                     dry paint particles can drift off-site or into nearby surface waters.

       Residual Wastes

                     Solid wastes associated with painting are believed to be the largest category
                     of hazardous waste  produced in shipyards (Kura,  1996). Typical wastes
                     associated with painting include leftover paint, waste paint containers, spent
                     equipment, rags and other materials contaminated with paint, spent solvents,
                     still bottoms from recycled cleaning solvents, and sludges from the sumps of
                     water wash paint spray booths. Wastes associated with  antifouling bottom
                     paints are sometimes collected separately from the typically less toxic topside
                     and interior paints. Antifouling paints contain toxic metal or organometallic

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Shipbuilding and Repair Industry
                Industrial Process Description
                    biocides such as cuprous oxide, lead oxide, and tributyl-tin compounds.
                    (Kura, 1996)
       Wastewater
                    Wastewater contaminated with paints and solvents may be generated during
                    equipment cleaning operations; however, water is typically only  used in
                    cleaning water-based paints.  Wastewater is  also generated when water
                    curtains (water wash spray booths) are used during painting. Wastewater
                    from painting water curtains commonly contains organic pollutants as well as
                    certain metals.  The wastewater can be treated at the source using filtration,
                    activated carbon adsorption, or centrifugation and then reused instead of
                    being discharged (EPA, 1995).

       m.B.3. Metal Plating and Surface Finishing

                    Material inputs for metal plating and finishing include the solutions of plating
                    metals such as chromium, aluminum, brass, bronze, cadmium, copper, iron,
                    lead, nickel, zinc, gold, platinum, and silver. In addition, cyanide solutions,
                    solvents, rinse water, and rust inhibitors  are  used. Many  of the wastes
                    generated from metal plating and surface finishing operations are considered
                    hazardous resulting from their toxicity.  Thorough descriptions of these
                    processes and their associated wastes are contained in the Fabricated Metal
                    Products Industry Sector Notebook.
       Air Emissions
                    Air emissions arise from metal mists, fumes, and gas bubbles from the surface
                    of the liquid baths and the volatilization of solvents used to clean surfaces
                    prior to plating or surface finishing.
       Residual Wastes
       Wastewater
                     Solid wastes include wastewater treatment sludges, still bottoms, spent metal
                     plating solutions, spent cyanide solutions, and residues from tank cleaning.
                     Often, the solid waste generated contains significant concentrations of toxic
                     metals, cyanides, acids, and alkalies.
                    Wastewaters  are primarily rinse waters, quench  water, and waste tank
                    cleaning water contaminated with metals, cyanides, acids, alkalies, organics,
                    and solvents.  Wastewaters are typically either sent off-site for treatment or
                    disposal or are treated onsite by neutralization and conventional hydroxide
                    precipitation prior to discharging either to a POTW or surface waters under
                    an NPDES permit.
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                Industrial Process Description
       IIJ.B.4. Fiberglass Reinforced Construction

                     Material inputs for fiberglassing operations  include fiberglass,  mold  or
                     reinforcing materials (wood and plastic), resins, solvents, and curing catalysts.
                     Unsaturated polyester resins, such as orthophthalic polyester, isophthalic
                     polyester, and bisphenol polyester are the most commonly used resins. Other
                     resins include epoxies, polyamides and phenolic compounds. Resins typically
                     are not hazardous;  however, the solvent in which the resin is dissolved may
                     be hazardous. In addition, some catalysts may be hazardous. Catalysts include
                     amines  (e.g.,  diethylenetriamine and triethylenetetramone),  anhydrides,
                     aldehyde condensation products, and Lewis acid catalysts.

                     Typical hazardous wastes include containers contaminated with residual
                     chemicals, wash-down wastewater, spent cleaning solvents from equipment
                     cleanup, scrap solvated resin left over in mix tanks, diluted resin  and partially
                     cured resin. For  a detailed description  of fiberglassing operations and
                     associated  wastes, refer to EPA's Pollution Prevention  Guide for the
                     Fiberglass-Reinforced and Composite Plastics Industry, October 1991.
       Air Emissions
                     Organic vapors consisting of VOCs are emitted from fresh resin surfaces
                     during the fabrication process and from the use of solvents for cleanup. The
                     polyester resins used in gelcoating operations have a styrene content of
                     approximately 35 percent. Emissions of styrene and other solvent VOCs
                     during spraying, mixing, brushing, and curing can be significant. In addition,
                     emissions of solvent vapors arise when acetone and methylene chloride are
                     used to clean fiber glassing equipment (Kura, 1996).
       Residual Wastes
                     Residual wastes generated from fiberglass operations include, gelcoat and
                     resin overspray, unused resins that have exceeded their shelf life, fiberglass
                     boxes, gelcoat drums, waste solvents, and cleanup rags (Kura, 1996).
       HI.B.5. Machining and Metalworking
                     Machining and metal working operations such as cutting, pressing, boring,
                     milling, and grinding, typically involve the use of a high speed cutting tool.
                     Friction at the cutting edge of the blade creates heat that could permanently
                     deform the metal being machined or the cutting tool.  Coolants,  such as
                     cutting oils and lube oils are, therefore, supplied to the leading edge of the
                     tool to remove excessive heat (Kura, 1996). Solvents are frequently used to
                     clean parts and tools prior to and after machining.
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Industrial Process Description
       Air Emissions
                     Fugitive air emissions arise from the use of solvents  for cleaning and
                     degreasing.
       Residual Wastes
       Wastewater
                     Waste cutting oils, lube oils, and degreasing solvents are the major residual
                     wastes generated. Metal shavings and chips are also generated.  Typically
                     these are separated from coolants, if necessary, and recycled along with scrap
                     metal (Kura, 1996).
                     Wastewaters containing cleaning solvents and emulsified lubricants, coolants,
                     and cutting oils may produced if parts are cleaned or rinsed with water. In
                     addition, some modern lubricating oils and grease are being formulated with
                     limited or no mineral oil content.  These lubricants are known as high water
                     content fluids.  When spent they can result in wastewater comprised of a
                     maximum of 15 percent mineral oil emulsified in water (Water Environment
                     Federation, 1994).

       m.B.6. Solvent Cleaning and Degreasing

                     The type of solvent used in parts and surface cleaning and degreasing depends
                     on the type of contaminants  to be removed, degree of cleaning needed,
                     properties of the surfaces to be cleaned,  and properties of the various solvents
                     (stability,  toxicity,  flammability, and  cost).    Both  halogenated  and
                     nonhalogenated solvents are used and mixtures of different solvents are
                     common.  Typical cleaning and degreasing solvents include mineral spirits,
                     aromatic hydrocarbons (e.g., xylenes, toluene, etc.), aliphatic hydrocarbons,
                     ketones, esters, alcohols, glycol ethers,  phenols, turpentine, and various
                     halogenated  solvents   (e.g.,  trichloroethylene,   1,1,1-trichloroethane,
                     perchloroethylene, etc.).
       Air Emissions
                     Solvent vapors comprised of VOCs and HAPs are a significant pollutant
                     output of cleaning and degreasing operations.  Fugitive emissions arise from
                     vapor degreasers, solvent tanks and containers, solvent stills, solvent soaked
                     rags, and residual solvents on parts and surfaces.

       Residual Wastes

                     Residual wastes may include contaminated or spent solvents, solvents that
                     have become contaminated  or  deteriorated  due to improper storage or

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Shipbuilding and Repair Industry
                Industrial Process Description
                     handling, solvent residues and sludges from tank bottoms and still bottoms,
                     solvent contaminated rags and filter cartridges, and solvent contaminated soil
                     from solvent spills.
       Wastewater
                     Wastewater containing solvents are generated when cleaning or rinsing parts
                     or surfaces,  and when cleaning equipment, tanks, and process lines with
                     water. Wastewater contaminated with solvents is also generated when water
                     from diphase parts cleaning operations is replaced.
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 Shipbuilding and Repair Industry
                Industrial Process Description
Table 3: Material Inputs and Potential Pollutant Outputs
for the Shipbuilding and Repair Industry
Industrial
Process
Surface
Preparation
Metal Plating
and Surface
Finishing
Painting
Fiberglass
Reinforced
Construction
Machining
and Metal
Working
Material
Inputs
Abrasives (steel
shot, lead shot, steel
grit, garnet, copper
slag, and coal slag),
detergents, solvent
paint strippers and
cleaners, and caustic
solutions.
Plating metals,
cyanide solutions,
cleaning solvents,
rinse water, acid and
caustic solutions and
rust inhibitors.
Paints, solvents, and
water.
Fiberglass, resin,
solvents, curing
catalysts, and wood
and plastic
reinforcing
materials.
Cutting oils, lube
oils, and solvents.
Air Emissions
Particulates (metal,
paint, and abrasives)
and VOCs from
solvent cleaners and
paint strippers.
Metal mists and
fumes, and VOCs
from solvents.
VOCs from paint
solvents and
equipment cleaning
solvents, and
overspray.
VOC emissions
released during
construction
operations and curing
(e.g., styrene) and
during cleaning with
solvents (e.g., acetone
and methylene
chloride).
VOC emissions from
the use of cleaning
and degreasing
solvents.
Wastewater
Wastewater
contaminated with
paint chips, cleaning
and paint stripping
solvents, surface
contaminants, and
oil residues from
bilges and cargo
tanks.
Rinse and quench
water contaminated
with metals,
cyanides, acids,
alkalies, organics,
and solvents.
Waste equipment
cleaning water and
water wash spray
paint booth sump
water contaminated
with paints and
solvents.
Little or no
Wastewater
generated.
Wastewater
containing solvents,
emulsified
lubricating and
cutting oils and
coolants.
Residual
Wastes
Paint chips
(potentially
containing metals,
tributyl-tin), spent
abrasives, surface
contaminants, and
cargo tank residues.
Sludge from
Wastewater
treatment, spent
plating solutions and
cyanide solutions,
bath cleaning
residues.
Leftover paint and
solvents, waste paint
and solvent
containers, spent
paint booth filters,
and spent
equipment.
Waste fiberglass,
gelcoat, resin,
unused resin that has
exceeded its shelf
life, spent solvents,
and used containers.
Waste cutting oils,
lube oils, and metal
chips and shavings.
Sources: Kura, Bhaskar, Typical Waste Streams in a Shipbuilding Facility, and U.S. EPA, Office of Research and
Development, Guides to Pollution Prevention, The Marine Maintenance and Repair Industry
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Shipbuilding and Repair Industry
               Industrial Process Description
III.C.  Management of Chemicals in Wastestream
                    The Pollution Prevention Act of 1990 (PPA) requires facilities to report
                    information about the management  of Toxics  Release Inventory  (TRI)
                    chemicals in waste and efforts made to eliminate or reduce those quantities.
                    These data have been collected annually in Section 8 of the TRI reporting
                    Form R beginning with the 1991 reporting year.  The data summarized below
                    cover the years 1993-1996 and is meant to provide a basic understanding of
                    the quantities of waste handled by the industry, the methods typically used to
                    manage  this waste, and  recent  trends in these methods.   TRf  waste
                    management data can be used to assess trends in source reduction within
                    individual industries and  facilities, and for specific TRI chemicals. This
                    information could then be used as a tool in identifying opportunities for
                    pollution prevention compliance assistance activities.

                    While the quantities reported for 1994 and 1995 are estimates of quantities
                    already managed, the quantities listed by facilities for 1996 and 1997 are
                    projections only. The PPA requires these projections to encourage facilities
                    to consider future waste generation and source reduction of those quantities
                    as  well  as movement up the  waste  management hierarchy.   Future-year
                    estimates are not commitments that facilities reporting under TRI are required
                    to meet.

                    Table 4  shows that the TRI reporting shipyards  managed about six million
                    pounds of production related wastes (total quantity of TRI chemicals in the
                    waste from routine production operations in column B) in 1995. From the
                    yearly data presented in column B, the total quantities of production related
                    TRI wastes increased between 1994 and 1995.  This is likely in part because
                    the number of chemicals on the TRI list nearly doubled between those years.
                    Production  related wastes were projected to  decrease between 1996 and
                     1997.

                    Values in column C are intended to reveal the percentage of production
                    related  wastes that  are  either transferred off-site  or released to the
                    environment. Column C is calculated by dividing the total TRI transfers and
                    releases  (reported in Sections 5 and 6 of the TRI Form R)  by the total
                    quantity  of production-related waste (reported in Section 8). Since the TRI
                    releases and transfers from Sections 5 and 6 of the TRI Form R should all be
                    accounted for in Section 8 of Form R, the percentages shown in column C
                     should always be  less than  100 percent. For the  shipbuilding and repair
                    industry, the TRI data shows that erroneous reporting in Form R by a number
                     of shipyards in both 1994 and 1995 has undermined the data resulting in
                    unusually high values in Column C.

                    If it is assumed that the proportions of production related wastes managed
                     onsite and off-site using the methods shown in columns D-I were reported
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Shipbuilding and Repair Industry
                  Industrial Process Description
                       correctly, the data would indicate that about 60 percent of the TRI wastes are
                       managed off-site through recycling, energy recovery, or treatment (columns
                       G, H, and I, respectively) in 1995. Only about one percent of the wastes were
                       managed on-site.  The remaining portion of TRI chemical wastes (about 44
                       percent), shown in column J, were released to the environment through direct
                       discharges to air, land, water, and underground injection, or was disposed off-
                       site.
Table 4: Source Reduction and Recycling Activity for
Shipyards (SIC 3731) as Reported within TRI
A
Year
1994
1995
1996
1997
B
Quantity of
Production-
Related
Waste
(106lbs.)a
5.32
6.45
5.62
5.59
C
% Released
and
Transferredb
113%
100%
—
—
On-Site
D
%
Recycled
1.1%
0.5%
0.7%
0.8%
E
% Energy
Recovery
0.0%
0.0%
0.0%
0.0%
F
% Treated
0.7%
0.7%
0.7%
0.7%
Off-Site
G
%
Recycled
36.1%
45.7%
40.1%
40.6%
H
% Energy
Recovery
12.6%
11.2%
11.3%
11.1%
I
% Treated
3.6%
2.2%
3.1%
3.1%
J
% Released
and
Disposed"
Off-site
46%
44%
44%
44%
Source: 7995 Toxics Release Inventory Database.
 Within this industry sector, non-production related waste < 1% of production related wastes for 1995.
 Total TRI transfers and releases as reported in Section 5 and 6 of Form R as a percentage of production related wastes.
 Percentage of production related waste released to the environment and transferred off-site for disposal.
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Shipbuilding and Repair Industry
             Chemical Releases and Transfers
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
                    This section is designed to provide background information on the pollutant
                    releases that are reported by this industry.  The best source of comparative
                    pollutant release information is the Toxic Release Inventory (TRI). Pursuant
                    to the Emergency Planning and Community Right-to-Know Act, TRI includes
                    self-reported facility release and transfer data for over 600 toxic chemicals.
                    Facilities within SIC Codes 20 through 39 (manufacturing industries) that
                    have more than 10 employees, and that  are above weight-based reporting
                    thresholds are required to report TRI on-site releases and off-site transfers.
                    The information presented within the sector notebooks is derived from the
                    most recently available (1995) TRI reporting year (which includes over 600
                    chemicals), and focuses primarily  on the on-site releases reported by each
                    sector. Because TRI requires consistent reporting regardless of sector, it is
                    an excellent tool for drawing comparisons across industries. TRI data provide
                    the type, amount and media receptor of each chemical released or transferred.

                    Although this  sector notebook does not present historical  information
                    regarding TRI chemical releases over time, please note that in general, toxic
                    chemical releases have been declining.  In fact, according to the 1995 Toxic
                    Release Inventory Public Data Release,  reported onsite releases of toxic
                    chemicals to the environment decreased by 5 percent (85.4 million pounds)
                    between 1994 and 1995 (not including chemicals added and removed from the
                    TRI chemical list during this period).  Reported releases  dropped by  46
                    percent between 1988 and 1995. Reported transfers of TRI chemicals to off-
                    site locations increased by 0.4 percent (11.6 million pounds) between 1994
                    and  1995.  More detailed information can be obtained from EPA's annual
                    Toxics Release Inventory Public  Data Release book (which is available
                    through the EPCRA Hotline at 800-535-0202), or directly from the Toxic
                    Release Inventory System database (for user support call 202-260-1531).

                    Wherever possible, the sector notebooks present TRI data as the primary
                    indicator of chemical release within each industrial category.  TRI data
                    provide the type, amount and media receptor of each chemical released or
                    transferred. When other sources of pollutant release data have been obtained,
                    these data have been included to augment the TRI information.
TRI Data Limitations
                    Certain limitations exist regarding TRI data. Release and transfer reporting
                    are limited to the approximately 600 chemicals on the TRI list.  Therefore, a
                    large portion of the emissions from industrial facilities are not captured by
                    TRI. Within some sectors, (e.g. dry cleaning, printing and transportation
                    equipment cleaning) the majority of facilities are not subject to TRI reporting
                    because they are not considered manufacturing industries, or because they are
                    below TRI reporting thresholds.  For these sectors, release information from
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Shipbuilding and Repair Industry
             Chemical Releases and Transfers
                     other sources has been included. In addition, many facilities report more than
                     one SIC code reflecting the multiple operations carried out onsite. Therefore,
                     reported releases and transfers may or may not all be associated with the
                     industrial operations described in this notebook.

                     The reader should also be aware that TRI "pounds released" data presented
                     within the notebooks is not equivalent to a "risk" ranking for each industry.
                     Weighting each pound of release equally does not factor in the relative
                     toxicity of each chemical that is released.  The Agency is in the process of
                     developing an approach to assign toxicological weightings to each chemical
                     released so that one can differentiate between pollutants  with significant
                     differences in toxicity.  As a preliminary indicator of the environmental impact
                     of the industry's most commonly released chemicals, the notebook briefly
                     summarizes the toxicological properties of the top five chemicals (by weight)
                     reported by each industry.

Definitions Associated With Section IV Data Tables

       General Definitions

                     SIC  Code  -- the Standard Industrial Classification  (SIC) is a statistical
                     classification standard used for all establishment-based Federal economic
                     statistics. The SIC codes facilitate comparisons between facility and industry
                     data.

                     TRI Facilities — are manufacturing facilities that have 10 or more full-time
                     employees  and are  above established chemical throughput thresholds.
                     Manufacturing facilities are defined  as facilities  in  Standard Industrial
                     Classification primary codes 20-39. Facilities must submit  estimates for all
                     chemicals that are on the EPA's defined list and are above throughput
                     thresholds.

       Data Table Column Heading Definitions

                     The following definitions are based upon standard definitions developed by
                     EPA's Toxic Release Inventory Program. The categories below represent the
                     possible pollutant destinations that can be reported.

                     RELEASES - are an on-site  discharge of a  toxic chemical  to the
                     environment.  This includes emissions to  the air, discharges to bodies of
                     water,  releases at the facility to land, as well  as contained disposal  into
                     underground injection wells.

                     Releases to Air (Point and Fugitive Air Emissions) -- Include all air
                     emissions from industry activity. Point emissions occur through confined air
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Shipbuilding and Repair Industry
              Chemical Releases and Transfers
                     streams as found in stacks, vents, ducts, or pipes. Fugitive emissions include
                     equipment leaks, evaporative losses from surface impoundments and spills,
                     and releases from building ventilation systems.

                     Releases to Water (Surface Water Discharges) ~ encompass any releases
                     going directly to streams, rivers, lakes, oceans, or other bodies of water.
                     Releases due to runoff, including storm water runoff, are also reportable to
                     TRI.

                     Releases to Land ~ occur within the boundaries of the reporting  facility.
                     Releases to land include disposal  of toxic chemicals in  landfills, land
                     treatment/application farming, surface impoundments, and other land disposal
                     methods (such as spills, leaks, or waste piles).

                     Underground Injection -- is a contained release of a fluid into a subsurface
                     well for the purpose of waste disposal. Wastes containing TRI chemicals are
                     injected into either Class I wells or Class V wells. Class I wells are used to
                     inject liquid  hazardous wastes  or  dispose  of industrial  and municipal
                     wastewaters beneath the lowermost underground source of drinking water.
                     Class V wells are generally used to inject non-hazardous fluid into or above
                     an underground source of drinking water. TRI reporting does not currently
                     distinguish between these two types of wells, although there are important
                     differences in environmental impact between these two methods of injection.

                     TRANSFERS  ~ is a transfer of toxic chemicals in wastes to a facility that
                     is geographically or physically separate from the facility reporting under TRI.
                     Chemicals reported to TRI as transferred are sent to off-site facilities for the
                     purpose of recycling, energy recovery, treatment, or disposal. The quantities
                     reported represent a movement of the chemical away from the  reporting
                     facility. Except for off-site transfers for disposal, the reported quantities do
                     not necessarily represent entry of the chemical into the environment.

                     Transfers to POTWs — are wastewater transferred through pipes or sewers
                     to a publicly owned treatments works (POTW). Treatment or removal of a
                     chemical from the wastewater depend on the nature of the chemical, as well
                     as the treatment methods present at the POTW. Not all TRI chemicals can
                     be treated or removed by a POTW. Some chemicals, such as metals,  may be
                     removed,  but are not destroyed and  may be disposed of in landfills or
                     discharged to receiving waters.

                     Transfers to Recycling ~ are sent off-site for the purposes of regenerating
                     or recovery by a variety of recycling methods, including solvent recovery,
                     metals recovery, and acid regeneration.  Once these chemicals have been
                     recycled, they may be returned to the originating facility or sold commercially.
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Shipbuilding and Repair Industry
             Chemical Releases and Transfers
                    Transfers to Energy Recovery — are wastes combusted off-site in industrial
                    furnaces for energy recovery. Treatment of a chemical by incineration is not
                    considered to be energy recovery.

                    Transfers to Treatment -- are wastes moved off-site to be treated through
                    a  variety  of  methods, including  neutralization,  incineration, biological
                    destruction, or physical separation. In some cases, the chemicals  are not
                    destroyed but prepared for further waste management.

                    Transfers to Disposal — are wastes taken to another facility for disposal
                    generally as a release to land or as an injection underground.
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 Shipbuilding and Repair Industry
               Chemical Releases and Transfers
 IV.A.  EPA Toxic Release Inventory for the Shipbuilding and Repair Industry

                      This section  summarizes  TRI  data of shipbuilding and repair facilities
                      reporting operations under SIC code 3731. Of the 598 shipbuilding and repair
                      establishments reported by the 1992 Census of Manufacturers, 43 reported
                      to TRI in 1995.

                      According to the 1995 TRI data,  the reporting shipbuilding and  repair
                      facilities released and transferred 39 different TRI chemicals for a total of
                      approximately 6.5 million pounds of pollutants during calendar year 1995.
                      These releases and transfers are dominated by volatile organic compounds
                      (VOCs) and metal-bearing wastes which make up 52 percent and 48 percent,
                      respectively, of total releases and transfers.

                      Transferstf TRI chemicals account for 58 percent of shipbuilding and repair
                      facilities' total TRI-reportable chemicals (3.5 million pounds) while releases
                      make up 42 percent (2.5 million pounds).
       Releases
       Transfers
                     Releases to the air, water, and land accounted for 37 percent (2.4 million
                     pounds) of shipyard's total reportable chemicals (see Table 5).  Of these
                     releases, over 98 percent are released to the .air from fugitive (75 percent) or
                     point (24 percent) sources. VOCs  accounted  for about 86 percent of the
                     shipbuilding and repair industry's reported TRI releases. The remainder of the
                     releases  were primarily metal-bearing  wastes. Xylenes, n-butyl alcohol,
                     toluene, methyl ethyl ketone, and methyl isobutyl  ketone account for about 65
                     percent of the industry's reported releases.  These organic  compounds are
                     typically found  in solvents which are used  extensively by  the industry in
                     thinning paints and for cleaning and  degreasing metal parts and equipment.
                     Styrene, reported by eight facilities, accounts for about 4 percent of the
                     industry's releases.  Styrene comprises a substantial portion  of the resin
                     mixtures and gelcoat used in fiberglass reinforced  construction. Finally,
                     copper-, zinc-, and nickel-bearing wastes account for about 14 percent of the
                     industry's reported releases.  They are released primarily as fugitive emissions
                     during metal plating operations and as overspray in painting operations and
                     can also be released as fugitive dust emissions during blasting operations.
                     Off-site transfers of TRI chemicals account for 63 percent of shipyard's total
                     TRI reportable chemicals (4.1 million pounds). Over 72 percent of the
                     shipbuilding and repair industry's TRI transfers are sent off-site for recycling
                     followed by about 18 percent sent off-site for energy recovery (see Table 6).
                     Metals accounted for about 67 percent of the  industry's reported transfers.
                     VOCs made up almost all of the remainder of transferred TRI chemicals.
Sector Notebook Project
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Shipbuilding and Repair Industry
             Chemical Releases and Transfers
                     About 60 percent of the metals transferred were recycled, and almost all of
                     the remainder were either treated or disposed off-site.  Copper, zinc, and
                     chromium made up about 70 percent of the metals transferred off-site. Most
                     of these are in the form of scrap metal, metal shavings and dust, spent plating
                     baths, wastewater treatment sludges, and in paint chips and  spent blasting
                     abrasives.  About 53 percent of the VOCs transferred were sent off-site for
                     energy recovery with the remainder primarily going to off-site recycling and
                     treatment.  Waste solvents containing xylene, n-butyl alcohol, methanol,
                     carbon tetrachloride, and methyl ethyl ketone make up almost 70 percent of
                     the VOCs transferred off-site. These wastes were primarily transferred for
                     energy recovery.
 Sector Notebook Project
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November 1997

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Shipbuilding and Repair Industry
            Chemical Releases and Transfers












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Sector Notebook Project
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November 1997

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Shipbuilding and Repair Industry
                                             Chemical Releases and Transfers
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-------
Shipbuilding and Repair Industry
              Chemical Releases and Transfers
                     The TRI database contains a detailed compilation of self-reported, facility-
                     specific chemical releases. The top reporting facilities for the shipbuilding and
                     repair industry are listed below in Tables 7 and 8.  Facilities that have reported
                     only the primary SIC codes covered under this notebook appear on Table 7.
                     Table 8 contains additional facilities that have reported the SIC codes covered
                     within this notebook, or SIC codes covered within this notebook and one or
                     more SIC codes that are not within the scope of this notebook. Therefore, the
                     second list may include facilities that conduct multiple operations — some that
                     are under the scope of this notebook, and some that are not. Currently, the
                     facility-level data do not allow pollutant releases to  be broken apart by
                     industrial process.
Table 7: Top 10 TRI Releasing Shipbuilding and Repair Facilities Reporting
Only SIC 3731 1
Rank
1
2
3
4
5
6
7
8
9
10
Facility
Newport News Shipbuilding - Newport News, VA
Atlantic Marine Inc. - Mobile, AL
Platzer Shipyard Inc. - Houston, TX
Norshipco - Norfolk, VA
Bethlehem Steel Corp.-Port Arthur, TX
Cascade General, Inc. - Portland, OR
Trinity Industries-Gulfport, MS
Todd Pacific Shipyards - Seattle, WA
Avondale Industries Inc. - Avondale, LA
Jeflboat - Jeffersonville, IN
Total TRI Releases
in Pounds
309,000
268,670
268,442
229,000
133,020
116,929
90,983
85,081
84,650
82,108
 Source: US Toxics Release Inventory Database, 1995.
  Being included on this list does not mean that the release is associated with non-compliance with environmental laws.
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Shipbuilding and Repair Industry
              Chemical Releases and Transfers
Table 8: Top 10 TRI Releasing Facilities Reporting Only SIC 3731
or SIC 3731 and Other SIC codes 2
Rank
1
2
3
4
5
6
7
8
9
10
SIC Codes
Reported in TRI
3731,3441,3443
3731
3731
3731
3731
3731
3731
3731
3731
3731
Facility
Ingalls Shipbuilding Inc.-Pascagoula, MS
Newport News Shipbuilding - Newport News, VA
Atlantic Marine Inc. - Mobile, AL
Platzer Shipyard Inc. - Houston, TX
Norshipco - Norfolk, VA
Bethlehem Steel Corp.-Port Arthur, TX
Cascade General, Inc. - Portland, OR
Trinity Industries-Gulfport, MS
Todd Pacific Shipyards - Seattle, WA
Avondale Industries Inc. - Avondale, LA
Total TRI Releases
in Pounds
723,560
309,000
268,670
268,442
229,000
133,020
116,929
90,983
85,081
84,650
 .Source: US Toxics Release Inventory Database, 1995.
IV.B.  Summary of Selected Chemicals Released
                     The following is a synopsis of current scientific toxicity and fate information
                     for the top chemicals (by weight) that facilities within this sector self-reported
                     as released to the environment based upon 1995 TRI data.  Because this
                     section is based upon self-reported release data, it does not attempt to provide
                     information on management practices employed by the sector to reduce the
                     release of these chemicals. Information regarding pollutant release reduction
                     overtime may be available from EPA's TRI and 33/50 programs, or directly
                     from the industrial trade associations that are listed in Section IX of this
                     document. Since these descriptions are cursory, please consult the sources
                     referenced below  for a more detailed description  of both the  chemicals
                     described in this section, and the chemicals that appear on the full list of TRI
                     chemicals appearing in Section IV. A.

                     The  brief descriptions provided  below were taken from  the Hazardous
                     Substances Data Bank (HSDB) and the Integrated Risk Information System
                     (IRIS). The discussions of toxicity describe the range of possible adverse
                     health effects that have been found to be associated  with exposure to these
                     chemicals.  These adverse effects may or may not occur at the levels released
                     to the environment. Individuals interested in a more detailed picture of the
                     chemical concentrations associated with these adverse effects should consult
  Being included on this list does not mean that the release is associated with non-compliance with enviromental laws.
Sector Notebook Project
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Shipbuilding and Repair Industry
              Chemical Releases and Transfers
                      a toxicologist or the toxicity literature for the chemical to obtain more
                      information.  The effects listed below must be taken in context of these
                      exposure assumptions that are more fully explained within the full chemical
                      profiles in  HSDB.  For  more information on  TOXNET3  , contact  the
                      TOXNET help line at 1-800-231-3766.
       Xylenes (Mixedhomers) (CAS: 1330-20-7)

                      Sources. Xylenes are used extensively as cleaning solvents and in thinning
                      paints.

                      Toxicity.  Xylenes are rapidly absorbed  into the body  after inhalation,
                      ingestion, or skin contact.  Short-term exposure of humans to high levels of
                      xylene can cause irritation of the skin, eyes, nose, and throat, difficulty in
                      breathing, impaired lung function, impaired memory, and possible changes in
                      the liver  and  kidneys.   Both  short-  and  long-term exposure to  high
                      concentrations can cause effects such as headaches, dizziness, confusion, and
                      lack of muscle coordination.  Reactions of xylene (see environmental fate) in
                      the atmosphere contribute to the formation of ozone in the lower atmosphere.
                      Ozone can affect the respiratory system, especially in sensitive individuals
                      such as asthma or allergy sufferers.

                      Carcinogenicity. There is currently no evidence to suggest that this chemical
                      is carcinogenic.

                      Environmental Fate.  A portion of releases to land and water will quickly
                      evaporate, although some degradation by microorganisms will occur. Xylenes
                      are moderately mobile in soils and may leach into groundwater, where they
                      may persist for several years.  Xylenes are volatile organic chemicals.  As
                      such, xylene  in the lower atmosphere  will react  with other atmospheric
                      components, contributing to the formation of ground-level ozone and other
                      air pollutants.
  TOXNET is a computer system run by the National Library of Medicine that includes a number of toxicological
databases managed by EPA, National Cancer Institute, and the National Institute for Occupational Safety and Health.
For more information on TOXNET, contact the TOXNET help line at 800-231 -3766. Databases included in TOXNET
are: CCRIS (Chemical Carcinogenesis Research Information System), DART (Developmental and Reproductive
Toxicity Database), DBIR (Directory of Biotechnology Information Resources), EMCBACK (Environmental Mutagen
Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS
(Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical Substances), and TRI (Toxic
Chemical Release Inventory). HSDB contains chemical-specific information on manufacturing and use, chemical and
physical properties, safety and handling, toxicity and biomedical effects, pharmacology, environmental fate and exposure
potential, exposure standards and regulations, monitoring and analysis methods, and additional references.
Sector Notebook Project
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Shipbuilding and Repair Industry
              Chemical Releases and Transfers
       Zinc and Zinc Compounds (CAS: 7440-66-6; 20-19-9)
                     Sources. To protect metal from oxidizing, it is often coated with a material
                     that will protect it from moisture and air. In the galvanizing process, steel is
                     coated with zinc.

                     Toxicity.  Zinc is a nutritional trace element; toxicity from ingestion is
                     low.  Severe exposure to zinc might give rise to gastritis with vomiting due
                     to swallowing of zinc dusts.  Short-term exposure to very high levels of
                     zinc is linked to lethargy, dizziness, nausea, fever, diarrhea, and reversible
                     pancreatic and neurological damage.   Long-term zinc poisoning causes
                     irritability, muscular stiffness and pain, loss of appetite, and nausea.

                     Zinc chloride fumes cause injury to mucous membranes and to the skin.
                     Ingestion of soluble zinc salts may cause nausea, vomiting, and purging.

                     Carcinogenicity.   There is  currently no evidence to suggest that  this
                     chemical is carcinogenic.

                     Environmental Fate.  Significant zinc contamination of soil is only seen
                     in the vicinity of industrial point sources. Zinc is a relatively stable soft
                     metal, though burns in air.  Zinc bioconcentrates in aquatic organisms.
       n-Butanol fn-ButylAlcohol) (CAS: 71-36-3)

                     Sources. n-Butanol is used extensively for thinning paints and equipment
                     cleaning.

                     Toxicity.  Short-term exposure usually results in depression of the central
                     nervous system, hypotension, nausea, vomiting, and diarrhea.  Butanols may
                     cause gastrointestinal hemorrhaging.  Eye contact may cause burning and
                     blurred vision. Hypotension and cardiac arrhythmias may occur. Inhaling n-
                     butanol may cause pulmonary edema. Headache, dizziness, and giddiness may
                     occur.    Liver  injury may occur but is  probably rare.   Dermatitis  and
                     hypoglycemia may result from exposure to  this chemical.  Chronic exposure
                     may  result in dry, cracked skin, and eye inflammation.  Workers have
                     exhibited systemic effects of the auditory nerve as well as vestibular injury.

                     Carcinogenicity.  There are currently no long-term  studies  in hurnans or
                     animals to suggest that this chemical is carcinogenic. Based on this evidence,
                     U.S. EPA has indicated that this chemical cannot be classified as to its human
                     Carcinogenicity.  There  is some evidence of chromosomal abnormalities in
                     short-term tests in bacteria and hamster cells, which may suggest potential
                     Carcinogenicity.
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 Shipbuilding and Repair Industry
              Chemical Releases and Transfers
                     Environmental Fate.  This chemical may volatilize from soil surface. In
                     addition,  the chemical may  biodegrade from  the soil, and leach to
                     groundwater.  n-Butanol released to water is expected to biodegrade and
                     volatilize from the water surface, and is not expected to bioconcentrate in fish.
                     People  are exposed primarily from contact with products containing n-
                     butanol.

       Copper and Copper Compounds (CAS: 7440-50-8)

                     Sources. Copper and copper compounds are commonly used as biocides in
                     anti-fouling paints.  Many ship parts requiring anti-corrosive characteristics
                     (e.g., piping) are fabricated or plated with copper and copper alloys.

                     Toxicity. Metallic copper probably has little or no toxicity, although copper
                     salts are more toxic. Inhalation of copper oxide fumes and dust has been
                     shown to cause metal fume fever, irritation of the upper respiratory tract,
                     nausea, sneezing, coughing, chills, aching muscles, gastric pain, and diarrhea.
                     However, the respiratory symptoms may be due to a non-specific reaction to
                     the inhaled dust as a foreign body in the lung, and the gastrointestinal
                     symptoms may be attributed to the conversion of copper to copper salts in the
                     body.

                     It is unclear whether long-term copper poisoning exists in humans.  Some
                     have related certain central nervous system disorders, such as giddiness, loss
                     of appetite, excessive perspiration, and drowsiness to copper poisoning.
                     Long-term exposure to copper may  also  cause  hair,  skin,  and teeth
                     discoloration,  apparently without other adverse effects.

                     People at special risk from exposure to copper include those with impaired
                     pulmonary function, especially those with obstructive airway diseases, since
                     the breathing  of copper fumes  might cause exacerbation of pre-existing
                     symptoms due to its irritant properties.

                     Ecologically, copper is a trace element essential to many plants and animals.
                     However,  high levels of copper in soil can be directly toxic to certain soil
                     microorganisms and can disrupt important microbial processes in soil, such as
                     nitrogen and phosphorus cycling.

                     Carcinogenicity. There is currently no evidence to suggest that this chemical
                     is carcinogenic.

                     Environmental Fate.  Copper is typically found in the environment as a solid
                     metal in soils and soil sediment in surface water. There is no evidence that
                     biotransformation processes have a significant bearing  on the fate  and
                     transport of copper in water.
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Shipbuilding and Repair Industry
             Chemical Releases and Transfers
       Styrene (CAS: 100-42-5)

                     Sources. Styrene is a major constituent of fiberglass resins and gelcoats,

                     Toxicity. Short-term exposure may cause irritation to eyes, lungs, stomach,
                     and skin.  Problems may occur in the central nervous system as a result of
                     serious exposure and may also occur in the peripheral nervous system. Short-
                     term exposure  from  inhalation  is  commonly  associated with "styrene
                     sickness", which includes vomiting, loss of appetite, and a drunken feeling.
                     Short-term exposure also irritates the respiratory tract,  and is associated with
                     asthma and pulmonary edema.

                     Long-term exposure in those working with styrene has been associated with
                     impaired nervous system functions including memory, learning, arid motor
                     skills and impaired psychiatric functioning.  Styrene may also cause gene
                     mutations and birth defects. Styrene has been shown to cause liver damage.

                     Carcinogenicity.  The International Agency for Research on Cancer notes
                     that evidence of Carcinogenicity in experimental animals indicates that styrene
                     is  a possible carcinogen  in humans.   However, U.S. EPA  is currently
                     reviewing the evidence for Carcinogenicity of styrene, and may arrive at a
                     different decision.

                     Environmental Fate  and Potential for Human Exposure.   If styrene is
                     released to air, it will quickly react with hydroxyl radicals and ozone.  At
                     night, air concentrations  of styrene will degrade by reacting  with nitrate
                     radicals.  Styrene released to water volatilizes and biodegrades, but does not
                     hydrolyze. In soil, styrene biodegrades and is fairly immobile in soil. Styrene
                     has been found in drinking water,  but not in 945 groundwater supplies.  The
                     chemical has been found in industrial effluents and in air surrounding industrial
                     sources and in urban  areas.  The chemical has been found in some food
                     packaged in polystyrene containers.
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Shipbuilding and Repair Industry
             Chemical Releases and Transfers
IV.C. Other Data Sources
                    The toxic chemical release data obtained from TRI captures only about seven
                    percent of the facilities in the shipbuilding and repair industry. However, it
                    allows  for a comparison across years  and industry sectors.   Reported
                    chemicals are limited to the approximately 600 TRI chemicals.  A  large
                    portion of the emissions from shipbuilding and repair facilities, therefore, are
                    not captured by TRI. The EPA Office of Air Quality Planning and Standards
                    has compiled air pollutant emission factors for determining the total  air
                    emissions of priority pollutants (e.g., total hydrocarbons, SOx, NOx, CO,
                    particulates, etc.) from many shipbuilding and repair sources.

                    The Aerometric Information Retrieval System (AIRS) contains a wide range
                    of information related to stationary sources of air pollution, including the
                    emissions of a number of air pollutants which may  be of concern within a
                    particular industry.  With  the  exception of volatile organic compounds
                    (VOCs), there is little overlap with the TRI chemicals reported above. Table
                    9  summarizes annual releases (from the industries for which a Sector
                    Notebook Profile was prepared) of carbon monoxide (CO), nitrogen dioxide
                    (NO2),  particulate matter of 10 microns or less (PM10), total particulate
                    matter (PT), sulfur dioxide (SO2), and volatile organic compounds (VOCs).
Sector Notebook Project
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Shipbuilding and Repair Industry
             Chemical Releases and Transfers
Table 9: Air Pollutant Releases (tons/year)
Industry Sector
Metal Mining
Nonmetal Mining
Lumber and Wood
Production
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastics
Stone, Clay and Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Electronics and Computers
Motor Vehicles, Bodies,
Parts and Accessories
Dry Cleaning
Ground Transportation
Metal Casting
Pharmaceuticals
Plastic Resins and
Manmade Fibers
Textiles
Power Generation
Shipbuilding and Repair
CO
4,670
25,922
122,061
2,754
566,883
8,755
153,294
112,410
734,630
2,200
105,059
1,386,461
214,243
4,925
356
15,109
102
128,625
116,538
6,586
16,388
8,177
366,208
105
NO2
39,849
22,881
38,042
1,872
358,675
3,542
106,522
187,400
355,852
9,955
340,639
153,607
31,136
11,104
1,501
27,355
184
550,551
11,911
19,088
41,771
34,523
5,986,757
862
PM10
63,541
40,199
20,456
2,502
35,030
405
6,703
14,596
27,497
2,618
192,962
83,938
10,403
1,019
224
1,048
3
2,569
10,995
1,576
2,218
2,028
140,760
638
PT
173,566
128,661
64,650
4,827
111,210
1,198
34,664
16,053
36,141
5,182
662,233
87,939
24,654
2,790
385
3,699
27
5,489
20,973
4,425
7,546
9,479
464,542
943
SO2
17,690
18,000
9,401
1,538
493,313
1,684
194,153
176,115
619,775
21,720
308,534
232,347
253,538
3,169
741
20,378
155
8,417
6,513
21,311
67,546
43,050
13,827,511
3,051
voc
915
4,002
55,983
67,604
127,809
103,018
65,427
180,350
313,982
132,945
34,337
83,882
11,058
86,472
4,866
96,338
7,441
104,824
19,031
37,214
74,138
27,768
57,384
3,967
          Source: U.S. EPA Office of Air and Radiation, AIRS Database, 1997.
Sector Notebook Project
58
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Shipbuilding and Repair Industry
              Chemical Releases and Transfers
IV.D.  Comparison of Toxic Release Inventory Between Selected Industries

                     The following information is presented as a comparison of pollutant release
                     and transfer data across industrial categories.  It is provided to give a general
                     sense as to the relative scale of TRI releases and transfers within each sector
                     profiled under this project.  Please note that the following figure and  table do
                     not contain releases and transfers for industrial  categories that  are  not
                     included  in this project,  and thus cannot  be used to draw conclusions
                     regarding the total release and transfer amounts that are reported  to TRI.
                     Similar information is available within the annual TRI Public Data  Release
                     Book.

                     Figure 10 is a graphical representation of a summary of the 1995 TRI  data for
                     the shipbuilding and repair industry and the other sectors profiled in separate
                     notebooks. The bar graph presents the total TRI releases and total transfers
                     on the vertical axis. The graph is based on the data shown in Table 10 and is
                     meant to facilitate comparisons between the relative amounts of releases,
                     transfers, and releases per facility both within and between these sectors. The
                     reader should note, however, that differences in the proportion of facilities
                     captured by TRI exist between industry sectors. This can be a factor of poor
                     SIC matching and relative differences in, the number of facilities reporting to
                     TRI from the various sectors.   In the case of the shipbuilding and repair
                     industry, the 1995 TRI data presented here covers 43 facilities. These facilities
                     listed SIC 3731  (Shipbuilding and Repair) as primary SIC codes.
Sector Notebook Project
59
November 1997

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Shipbuilding and Repair Industry
                                  Chemical Releases and Transfers
         Figure 6: Summary of TRI Releases and Transfers by Industry
       600
IO   T-
™   s
0)   ^-  CM
•*   cn
CO   CD
                              °o  $9  oo  co
                                                O  CM
                                                CO  CO
                       CM  CM  CM  CM  CM  CM   CM
CD
CM   CO
s   s
                                     co~  •>-
                                     co  CD
                                     co
                                 •c-  CD  •*  -«t
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                                 co  co  co

                                    CM"  co"
                                    co  co
                                    co  co
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                                            co  r-
                                               co
                       CM   CM  CM  CM  CM  CM
                                  CM
                                         SC Range
                       D Total Releases
                                  •Total Transfers
Source: US EPA 1995 Toxics Release Inventory Database.
SIC Ranee
22
24
25
26 11 -263 1
271 1-2789
2812-2819
2821,
2S23. 2824
Industry Sector
Textiles
Lumber and Wood Products
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemical
Manufacturing
Plastic Resins and Manmade
Fibers
SIC Range
2833, 2834
2861-2869
2911
30
32
331
332, 336
Industry Sector
Pharmaceuticals
Organic Chem. Mfg.
Petroleum Refining
Rubber and Misc. Plastics
Stone, Clay, and Concrete
Iron and Steel
Metal Casting
SIC Range
333, 334
34
36
371
?731
Industry Sector
Nonferrous Metals
Fabricated Metals
Electronic Equip, and Comp.
Motor Vehicles, Bodies,
Parts, and Accessories
ShiDbuildineandReBair

Sector Notebook Project
                     60
                                             November 1997

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Shipbuilding and Repair Industry
             Chemical Releases and Transfers










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Source: US EPA Toxics
Sector Notebook Project
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November 1997

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Shipbuilding and Repair Industry
             Chemical Releases and Transfers
                            Page 62 intentionally left blank.
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 Shipbuilding and Repair
            Pollution Prevention Opportunities
 V. POLLUTION PREVENTION OPPORTUNITIES
                     The best way to reduce pollution is to prevent it in the first place. Some
                     companies have creatively implemented pollution prevention techniques that
                     improve efficiency and increase profits while at the same time minimizing
                     environmental impacts.   This can be done in many ways such as reducing
                     material inputs, re-engineering processes to reuse by-products,  improving
                     management practices, and employing substitution of toxic chemicals.  Some
                     smaller facilities are able to actually get below regulatory thresholds just by
                     reducing pollutant releases through aggressive pollution prevention policies.

                     The Pollution Prevention Act  of 1990  established  a national policy of
                     managing waste through source  reduction, which means preventing the
                     generation of waste.  The Pollution Prevention Act also established as national
                     policy a hierarchy of waste management options for situations in which source
                     reduction  cannot be implemented feasibly.   In  the waste  management
                     hierarchy, if source reduction is not feasible the next alternative is recycling
                     of wastes, followed by  energy recovery, and waste treatment  as  a last
                     alternative.

                     In order to encourage these approaches, this section provides both general
                     and company-specific descriptions of some pollution prevention advances that
                     have been implemented within the shipbuilding and repair industry.  While the
                     list is not exhaustive, it does provide core information that can be used as the
                     starting point for facilities  interested in beginning  their own  pollution
                     prevention projects.   This section provides summary  information from
                     activities that may be,  or are being implemented by this sector.   When
                     possible, information is provided that gives the context in which the technique
                     can be used effectively. Please note that the activities described in this section
                     do not necessarily apply to all facilities that fall within this sector.  Facility-
                     specific conditions must be carefully considered when pollution prevention
                     options are evaluated, and the full impacts of the change must examine how
                     each option affects air, land and water pollutant releases.

                     Much  of the information contained in this  Section  was obtained from
                     Hazardous Waste Minimization Guide for Shipyards,  produced by the
                     National Shipbuilding Research Program (NSRP) in cooperation with the U.S.
                     Navy and National Steel and Shipbuilding Company (NASSCO). The Guide
                     provides and extensive  discussion of pollution prevention opportunities
                     available to shipyards which could not all be reproduced in this document.
                     For further details on pollution prevention opportunities for shipyards, readers
                     are encouraged to consult the Guide and the additional references listed in
                     Section IX of this sector notebook.   In  addition, many of the pollution
                     prevention  opportunities listed  in the Profile of the Fabricated Metal
                     Products Industry Sector Notebook can also be applied to the shipbuilding and
                     repair industry.
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Shipbuilding and Repair
           Pollution Prevention Opportunities
V.A.  Surface Preparation
                     The  majority of wastes  generated  during surface preparation are spent
                     abrasives mixed with paint chips. One way the volume of waste generated can
                     be reduced is by using blast media that is relatively easy to reuse.  Some
                     abrasives, such as mineral abrasives, are not easily reused. Copper slag has
                     a very low reuse factor and in general, can be used no more than twice before
                     breaking down.

       Steel Shot and Grit

                     One of the most widely used reusable abrasives is steel grit, which is a crushed
                     form of steel shot. While slags and sands can only be used a couple of times,
                     steel abrasives can be used 50 times or more. With reused steel abrasive, care
                     must be taken to watch  that the abrasive does not become rounded. The
                     abrasive works best if it has a sharp angular shape. Steel shot and grit require
                     a high initial outlay of capital, but they can be used repeatedly to the point that
                     they are more cost effective than copper slag. This medium  is only deemed
                     hazardous when  it is contaminated with a sufficient amount of paint chips.

       Improving Recyclability of Abrasive Blasting Media

                     In order to realize the maximum usage of reusable grit, measures must be
                     taken to ensure  it can be reused. Some media, such as steel shot, can be
                     reused hundreds of times. It is important that the used grit is recovered as
                     much  as  possible.  With  wheelabrator  type  equipment, this  is  done
                     automatically. The used abrasive may be vacuumed up or mechanically fed to
                     the blasting equipment. Containment of the abrasive allows it to be recovered,
                     where otherwise it could  suffer from loss to overspray. Protection from the
                     weather, such as rain, will also prolong the-life of the grit. It is very important
                     that  waste  streams, especially hazardous waste, are  not mixed with used
                     blasting media. Outside debris  and other waste could render the grit unfit for
                     reuse.

                     Often, air powered cleaning equipment is used to screen abrasive to separate
                     it from large paint particles. These systems may also remove lighter dust from
                     the heavy abrasive. This media separation can be especially important when
                     the paint being removed contains heavy metals.  An alternative to on-site
                     reclamation is to send it for processing off-site.

       Plastic Media Blasting

                     As a substitute for other blast media, the military has experimented extensively
                     with plastic media stripping. This process  is particularly good for stripping
                     coatings from parts  with fragile substrates such as zinc,  aluminum, and
                     fiberglass. It can be a lengthy process because it strips paint layer by layer.
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Shipbuilding and Repair
            Pollution Prevention Opportunities
                     The same types and quantities of waste are generated as with grit blasting, but
                     the plastic medium is more recyclable with the use of pneumatic media
                     classifiers that are part of the stripping equipment. The only waste requiring
                     disposal is the paint waste itself. However, the use of plastic media is fairly
                     limited in shipyards. Plastic blasting media do not work well on epoxy paints.
                     In addition,  the  blasting equipment  is  expensive and  requires trained
                     operators.

       Water Jet Stripping (Hydroblasting)

                     Hydroblasting is a cavitating high pressure water jet stripping system that can
                     remove most paints.  These system may use pressures as high as 50,000 psig.
                     Hydroblasting is an excellent method for removing even hard coatings from
                     metal substrates. The process can be used for stripping hulls, removing scales
                     and deposits from heat exchangers, and removing rubber liners.  Some
                     systems automatically remove the paint chips or stripped material from the
                     water and reuse the water for further blasting. By recirculating the water in
                     this manner, the amount of waste is greatly reduced.  Wastewater from this
                     process is usually suitable for sewer disposal after the paint particles are
                     removed. Although this process produces very little waste, it is not always as
                     efficient  as  abrasive grit blasting  and has relatively high capital  and
                     maintenance costs.

V.B.  Painting and Coating

                     Painting and coating operations are typically the largest single source of VOC
                     emissions from shipyards. In addition, paint waste can account for more than
                     half of the total hazardous waste generated at shipyards.  Paint waste at a
                     shipyard may include leftover paint in containers, overspray, paint that is no
                     longer usable (Non-spec paint), and rags and other materials contaminated
                     with paint.  In  many cases, the amount of paint waste generated can be
                     reduced through the use of improved equipment, alternative coatings, and
                     good operating practices.

                     Regulations under the CAA aimed at reducing VOC emissions  by limiting
                     VOC content in paints were finalized in 1996. Shipyards required to comply
                     with these rules and wishing to implement the pollution prevention options
                     discussed below, should consult the regulations to determine the practical and
                     legal implications of these options.

       V.B.I. Application Equipment

                     In  order to effectively reduce paint waste and  produce a quality coating,
                     proper application  techniques  should be supplemented with  efficient
                     application equipment.  Through the use  of equipment with high transfer
                     efficiencies, the amount of paint lost to overspray is minimized.
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Shipbuilding and Repair
           Pollution Prevention Opportunities
       High Volume Law Pressure (HVLP) Spray Guns

                     The  HVLP  spray gun  is basically  a conventional  air  spray  gun with
                     modifications and special nozzles that atomize the paint at very low air
                     pressures. The atomizing pressure of HVLP systems is often below 10 psi.
                     The design of this gun allows better transfer efficiency and reduced overspray
                     than that of conventional air guns.  The low application pressure decreases
                     excessive bounceback and allows  better adhesion of the coating to the
                     substrate.

                     Although  improvements are consistently being  made to overcome its
                     limitations, most HVLP systems have some definite drawbacks, including
                     difficulty atomizing viscous  coatings,  sensitivity to variations in incoming
                     pressure, sensitivity to wind,  and slow application rates.

       Airless Spray Guns

                     Instead of air passing through the spray gun, an airless system applies static
                     pressure to  the liquid paint.   As the paint passes through the nozzle, the
                     sudden drop  in pressure atomizes the paint and it is carried to the substrate by
                     its own momentum. Pressure is applied to the paint by a pump locatted at a
                     remote supply. These systems have become favorable over conventional air-
                     spray systems for three main  reasons: 1) reduced overspray and rebound, 2)
                     high application rates and transfer efficiency, and 3) permits the use of high-
                     build coatings with the result that fewer coats are required to achieve specific
                     film thickness.

                     One major  disadvantage of some airless spray systems is the  difficulty
                     applying very thin coats.  If coatings with less  than a mil in thickness are
                     required, such as primers applied to objects that require weld ability, it may
                     be difficult to use an airless system.

       Electrostatic Spray

                     Electrostatic spray system utilize paint droplets that are  given a negative
                     charge in the vicinity of a positively  charged  substrate.  The droplets  are
                     attracted to the substrate and a uniform coating is formed.  This system works
                     well on cylindrical and rounded objects due to its "wrap-around" effect that
                     nearly allows the object to be coated from one side. Very little paint is lost to
                     overspray, and it has been noted to have a transfer efficiency of over 95%.

                     In order for an electrostatic system to operate properly, the correct solvent
                     balance is needed.  The evaporation rate must be slow enough for the charged
                     droplets to reach the substrate in a fluid condition to flow out into a smooth
                     film, but fast enough to avoid sagging.  The resistivity of the paint must also
                     be low enough to enable the  paint droplets to acquire the maximum charge.
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           Pollution Prevention Opportunities
                     Although the operating costs of electrostatic spray systems are relatively low,
                     the initial capital investment can be high.  This system has been found to work
                     extremely well in small parts painting applications. Sometimes the installation
                     of an electrostatic powder coating system can replace a water curtain spray
                     paint booth.
       Heated Spray
                    .When paint is heated, its viscosity is reduced allowing it to be applied with a
                    higher solids content, thus requiring less solvent. When the paint is heated in
                    a special container and supplied to the gun at 140° to 160°F, coatings of 2 to
                    4 mils dry-film  thickness can be  applied in one operation, resulting in
                    considerable savings in labor cost. In addition, much of the associated solvent
                    emissions are eliminated.

                    Heating the coating  prior to application can be used with both conventional
                    and airless spray applications.  An in-line heater is used to heat the coating
                    before it reaches the gun.  As the coating is propelled through the air, it cools
                    rapidly and increases viscosity after it hits the surface, allowing for better
                    adhesion to the substrate.
       Plural Component Systems
                     A common problem that shipyards face when working with two-part coatings
                     is overmixing. Once the component parts of a catalyst coating are mixed, the
                     coating must be applied. Otherwise, the excess unused coating will cure and
                     require disposal.   Additionally, the coating  equipment must  be cleaned
                     immediately after use.

                     One large advantage of plural component technology is the elimination of
                     paint waste generated by mixing an excess amount of a two part coating.  This
                     is achieved through the use  of a  special mixing chamber that mixes the
                     pigment and catalyst seconds before the coating is applied. Each component
                     is pumped through a  device that controls the  mixing ratio and then is
                     combined in a mixing chamber.  From the mixing chamber, the mixed coating
                     travels directly to the spray guns.   The only cleaning that is required is the
                     mixing chamber, gun, and the length of supply hose connecting them.
       Recycle Paint Booth Water
                     Various methods and equipment are used to reduce or eliminate the discharge
                     of the water used in water-wash booths (water curtain). These methods and
                     equipment prevent the continuous discharge of booth waters by conditioning
                     (i.e., adding detacifiers and paint-dispersing polymers) and removing paint
                     solids. The most basic form of water maintenance is the removal of paint
                     solids by manual skimming and/or raking. This can be performed without
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 Shipbuilding and Repair
            Pollution Prevention Opportunities
                     water conditioning since some portion of solvent-based paints usually float
                     and/or sink.   With the use of detacifiers  and paint-dispersing  polymer
                     treatments, more advanced methods of solids removal can be implemented.
                     Some common methods are discussed below.

                     Wet-Vacuum Filtration. Wet-vacuum filtration units consist of an industrial
                     wet-vacuum head on a steel drum containing a filter bag. The unit is used to
                     vacuum paint sludge from the booth.  The solids are filtered by the bag and
                     the water is returned to the booth. Large vacuum units are also commercially
                     available that can be moved from booth to booth by forklift or permanently
                     installed near a large booth.

                     Tank-Side Weir.   A weir can be attached to the side of a  side-draft booth
                     tank, allowing floating material to overflow from the booth and be pumped to
                     a filtering tank for dewatering.

                     Consolidator.  A consolidator is a separate tank into which booth  water is
                     pumped.  The water is then conditioned by the introduction of chemicals.
                     Detacified paint floats to the surface of the tank, where it is skimmed by a
                     continuously moving blade.  The clean water is recycled to the booth.

                     Filtration.   Various types of filtration  units are used to remove paint solids
                     from booth water.  This is accomplished by pumping the booth water to the
                     unit where the solids are separated and returning the water to the booth.  The
                     simplest filtration unit consists of a gravity filter bed utilizing paper or cloth
                     media. Vacuum filters are also employed, some of which require precoating
                     with diatomaceous earth.

                     Centrifuge Methods.  Two common types of centrifugal  separators are the
                     hydrocyclone and the centrifuge.  The hydrocyclone is used to concentrate
                     solids. The paint booth water enters a cone-shaped unit under pressure and
                     spins around the inside surface. The spinning imparts an increased  force of
                     gravity, which causes most of the solid particles to be pulled outward to the
                     walls of the cone.  Treated water exits the top of the unit and the solids exit
                     from the bottom. Some systems have secondary filtration devices to further
                     process the solids.  The centrifuge works in a similar manner, except that the
                     booth water enters a spinning  drum,  which imparts the centrifugal force
                     needed for separating the water and solids. Efficient centrifugation requires
                     close control of the booth water chemistry to ensure a uniform feed. Also,
                     auxiliary equipment such as booth water agitation equipment may be needed
                     (EPA, 1995).

       Convert Wash-Water Booths to Dry Filter Booths

                     Water-wash booths can be converted to  or replaced by dry filter booths.  The
                     dry filter booths have the potential to eliminate the discharge of wastewater,
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Shipbuilding and Repair                               Pollution Prevention Opportunities

                     but they create a solid waste stream. The choice between using a water-wash
                     booth or a dry filter booth is primarily based on the quantity of overspray.  It
                     is usually cost effective to use a dry filter booth when paint usage does not
                     exceed 20 gallons/8 hour shift/10 feet of chamber width.

                     A 1989 Navy study concluded that conversion from wet to dry booths can be
                     cost effectively performed over a range of operational scenarios. The Navy
                     work  included a survey  of military  and  industrial facilities that have
                     successfully made the conversion and an economic analysis based on typical
                     Navy painting operational parameters (EPA, 1995).

       V.B.2. Alternative Coatings

                     The use of solvent-based coatings can lead to high costs to meet air and water
                     quality regulations.  In efforts to reduce the quantity and toxicity of waste
                     paint disposal, alternative coatings have been developed that do not require
                     the use of solvents and thinners.

       Powder Coatings

                     Metal substrates can be coated with certain resins by applying the powdered
                     resin to the surface, followed by application of heat. The heat melts the resin,
                     causing it to flow and form a uniform coating. The three main methods in use
                     for applying the powder coating are fluidized bed, electrostatic spray, and
                     flame spraying.

                     Flame spraying is the most applicable method for shipyards. The resin powder
                     is blown through the gun by compressed air.  The particles are melted in a
                     high temperature flame and propelled against  the substrate.  This process is
                     used widely with epoxy powders for aluminum surfaces.

                     The  electrostatic application  method uses  the same principles as the
                     electrostatic   spray.    The  resin  powder  is  applied to  the  surface
                     electrostatically.  Heat is applied to the covered surface and the powder melts
                     to form the coating.  The transfer efficiency and recyclability of this method
                     is very high.

                     The elimination of environmental problems associated with many liquid based
                     systems is one of the  major advantages  of powder coatings.  The use of
                     powder coatings eliminates the need for solvents and thereby emits negligible
                     volatile organic compounds (VOCs). Powder coatings also reduce the waste
                     associated with unused two-part coatings that have already been mixed. Since
                     powder overspray can be recycled, material utilization is high and solid waste
                     generation is  low.  Recent case studies demonstrate that powder coating
                     systems can be cleaner, more efficient, and more environmentally acceptable,
                     while producing a higher quality finish than many other coating systems.

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Shipbuilding and Repair
           Pollution Prevention Opportunities
       Water-Based Paints
                     Water-based coatings are paints containing a substantial amount of water
                     instead of volatile solvents. Alkyd, polyester, acrylic, and epoxy polymers can
                     be dissolved and dispersed by  water.    In addition to reduction  in
                     environmental hazards due to substantially lower air emissions, a decrease in
                     the amount of hazardous paint sludge generated can reduce disposal cost.

                     The application for water-based coatings in the shipyard are limited. Some of
                     the areas of use may include the inside of the superstructure of a vessel, and
                     other surfaces that are protected from extreme conditions.
       V.B.3. Good Operating Practices
                     In many cases, simply altering a painting process can reduce wastes through
                     better management.
       Coating Application
                     A good manual coating application technique is very important in reducing
                     waste.   Most shipyards rely primarily on  spraying methods for coating
                     application.   If not properly executed,  spraying techniques have a  high
                     potential for creating waste; therefore, proper application techniques are very
                     important.

                     Reducing Overspray One of the most common means of producing paint
                     waste at shipyards is overspray. Overspray not only wastes some of the
                     coating, it also presents environmental and health hazards. It is important that
                     shipyards try to reduce the amount of overspray as much  as  possible.
                     Techniques for reducing overspray include: 1) triggering the paint gun at the
                     end of each pass instead of carrying the gun past the edge of the surface
                     before reversing directions, 2) avoiding excessive air pressure, and 3) keeping
                     the gun perpendicular to the surface being coated.

                     Uniform Finish Application of a good uniform finish provides the surface with
                     quality coating with a higher performance than an uneven finish.  An uneven
                     coating does not dry evenly and commonly results in using excess paint.

                     Overlap An  overlap of 50 percent can reduce the amount of waste by
                     increasing the production rate and overall application efficiency.  Overlap of
                     50 percent means that for every pass that the operator makes with the spray
                     gun, 50 percent of the area  covered by the previous pass is also sprayed. If
                     less than a 50 percent overlap is used, the coated surface may appear streaked.
                     If more than  a 50 percent overlap is used,  the coating is wasted and more
                     passes are required to coat the surface.
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 Shipbuilding and Repair
            Pollution Prevention Opportunities
        General Housekeeping
                      Small  quantities of paint  and solvents  are frequently lost due to poor
                      housekeeping techniques.    There are  a variety  of ways that can  be
                      implemented to control and minimize spills and leaks.  Specific approaches to
                      product transfer methods  and container handling  can effectively reduce
                      product loss.

                      The potential for accidents and spills is at the highest point when thinners and
                      paints are being transferred from bulk drum storage to  the process equipment.
                      Spigots, pumps, and funnels should be used whenever possible.

                      Evaporation can be controlled by using tight fitting  lids, spigots, and other
                      equipment. The reduction in evaporation will increase the amount of available
                      material and result in lower solvent purchase cost.
       Paint Containers
                     A significant portion of paint waste is the paint that remains inside a container
                     after the container is emptied, and paint that is placed in storage, not used,
                     and becomes outdated or non-spec.  Shipyards should try to consolidate paint
                     use to facilitate the purchase of paint in bulk. Since large bulk containers have
                     less surface area than an equivalent volume of small cans, the amount of drag-
                     on paint waste is reduced. Large bulk containers can sometimes be returned
                     to the paint supplier to be cleaned for reuse.

                     If the purchase of paint in bulk containers is not practical, the paint should be
                     purchased in the smallest amount required to minimize outdated or non-spec
                     paint waste.  Workers should not have to open a gallon can when only a quart
                     is required.  Usually, any paint that is left in the can will require disposal as
                     hazardous waste.
V.C.  Metal Plating and Surface Finishing
                     Pollution prevention opportunities in metal plating and surface finishing
                     operations are discussed in detail in NSRP's Hazardous Waste Minimization
                     Guide for Shipyards and in the Profile of the Fabricated Metal Products
                     Industry Sector Notebook.    Readers are  encouraged to consult these
                     documents for pollution prevention information relating to metal plating and
                     surface finishing.
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V.D.  Fiberglass Reinforced Construction

       Material Application
                     Major waste  reduction  is available  by optimizing material application
                     processes.  These processes include spray delivery systems and non-spray
                     resin application methods.  Non-spray application methods include closed
                     mold  systems, vacuum bag mold systems, resin roller dispensers, prespray
                     fiber reinforcing, and in-house resin impregnation.  These no-spray techniques
                     reduce material  waste and energy costs during application.  The lower
                     application pressures reduce the cost and maintenance of pressure lines,
                     pumps, controls, and fittings.  Routine cleanups of work areas  are  also
                     reduced.
       Spray Delivery Systems
                     The fabrication process for fiberglass construction and the wastes produced
                     are highly dependent on the equipment and procedures used. The current
                     system of resin and gelcoat  delivery systems include  high-pressure air,
                     medium-pressure airless, and low-pressure air-assisted airless spray guns.

                            The high-pressure air system is used less due to the large amount of
                            expensive high-pressure compressed air required and significant air
                            emissions generated.

                            The  airless  method  produces   a  pressurized   resin  stream
                            electrostatically atomized through a nozzle.  The nozzle orifice and
                            spray angle can be varied by using different tips.  The size of the
                            orifice affects the delivery efficiency, with larger orifices resulting in
                            greater raw material loss. Airless spray guns are considered to be very
                            efficient in the delivery of resin to the work surface.

                     •      The air-assisted  airless  technology modifies the airless  gun by
                            introducing pressurized air on the outer edge of the resin stream as it
                            exits the pressure nozzle. The air stream  forms an envelope which
                            focuses the resin to follow a controllable spray pattern. Since more
                            resin  ends up on  the  mold with  this technology, the amount of
                            spraying is  reduced leading to a reduction  in air emissions.   It is
                            estimated that a savings of 5 to 20 percent in net loss of resin spray
                            waste for the air-assisted airless gun is achieved compared to the
                            airless gun.
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       Resin Roller Application
                     This  application uses  pumped resin and  catalyst from drums or bulk
                     containers.  The resin and catalyst are precisely metered in a gun-type line
                     much like the paint plural component systems.  A resin roller dispenser
                     transfers the catalyzed resin to the mold surface. This eliminates the material
                     lost due to overspray and bounceback of the resin. Air emissions are also
                     greatly reduced with this type of delivery system.
        Thermoplastic Resins
                     Thermoplastic resins have the advantage of being easily recycled by applying
                     heat which returns the resin to a liquid state. In its liquid state, the resin can
                     be reused in the manufacture of other fiberglass components in shipbuilding.
                     The use of thermoplastics offers faster curing cycles, lower emission during
                     processing,  lower costs per pound of raw material used, ease of recycling
                     material, and, in some cases, lower labor costs.  With the recent advances in
                     the processing technologies and thermoplastic resin systems, the shipbuilding
                     industries are reexamining the application of thermoplastics versus thermosets
                     material systems.
V.E. Solvent Cleaning and Degreasing
                     Shipyards often use large quantities of solvents in a variety of cleaning and
                     degreasing operations including parts cleaning, process equipment cleaning,
                     and surface preparation for coating applications.  The final cost of solvent
                     used for various cleanup operations is nearly twice the original purchase price
                     of the virgin solvent. The additional cost is primarily due to the fact that for
                     each drum purchased, extra disposal cost, hazardous materials transportation
                     cost, and manifesting time and expense are incurred. With the rising cost of
                     solvents and waste disposal services, combined with continuously developing
                     regulation,  reducing the quantities of solvents used and solvent wastes
                     generated can be extremely cost effective.
       Eliminating the Use of Solvents
                     Eliminating the use of solvents avoids any waste generation associated with
                     spent solvent.  Elimination can be achieved by utilization of non-solvent
                     cleaning agents or eliminating the need for cleaning altogether.  Solvent
                     elimination applications  include the  use of water-soluble  cutting fluids,
                     protective peel coatings, aqueous cleaners, and mechanical cleaning systems.

                     Water-soluble Cutting Fluids. Water-soluble cutting fluids can often be used
                     in place of oil-based fluids.  The cutting oils usually consist of an oil-in-water
                     emulsion used to reduce friction and dissipate heat.  If these fluids need to be
                     removed after the machining process is complete, solvents may be needed.
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                     In efforts to eliminate solvent degreasing and its subsequent waste, special
                     water-soluble cutting fluids have been developed. Systems are available that
                     can clean the  cutting fluid and  recycle the material back to the  cutting
                     operation.  Obstacles to implementing this method are: cost (water-soluble
                     fluids are generally more expensive), procurement (there are only a few
                     suppliers available), and the inability to quickly switch between fluid types
                     without thoroughly cleaning the equipment.

                     Aqueous Cleaners Aqueous cleaners,  such as alkali, citric, and caustic base,
                     are often useful substitutes for solvents. There are many formulations that are
                     suited for a variety of cleaning requirements. Many aqueous cleaners have
                     been found to be as effective as the halogenated solvents that are commonly
                     employed.

                     The advantages of substituting aqueous cleaners include minimizing worker's
                     exposure to solvent vapors, reducing liability  and  disposal  problems
                     associated with solvent use,  and cost.  Aqueous cleaners do not volatilize as
                     quickly as other solvents, thereby reducing losses due to evaporation. Since
                     most aqueous cleaners are biodegradable, disposal is not a problem once the
                     organic or inorganic contaminants are removed.

                     The use of aqueous cleaners can also  result in cost savings.  Although some
                     aqueous  cleaners may cost less than an equivalent amount of solvent, the
                     purchase price of each is about the same. The cost of disposal, loss due to
                     evaporation, and associated liabilities, however, favor aqueous cleaners.

                     The disadvantages of aqueous cleaners in  place of solvents may include:
                     possible  inability of the  aqueous  cleaners to provide the degree of cleaning
                     required, incompatibility between the parts being cleaned and the cleaning
                     solution, need to  modify  or replace  existing equipment, and  problems
                     associated with moisture left on parts  being cleaned. Oils removed from the
                     parts during cleaning may float on the surface of the cleaning solution and
                     may interfere with subsequent cleaning.  Oil skimming is usually required.

                     Mechanical Cleaning Systems Utilizing mechanical cleaning systems can also
                     replace solvents in degreasing and  cleaning operations. In many cases, a high
                     pressure steam gun or high pressure parts washer can clean parts and surfaces
                     quicker  and to the same degree of cleanliness as that of the solvents they
                     replace.  Light detergents can be added to the water  supply for improved
                     cleaning. The waste produced by these systems is usually oily wastewater.
                     This  wastewater can be sent through an oil/water separator, the removed
                     water discharged to the sewer, and the oil residue sent to a petroleum
                     recycler.  Some  hot water wash and steam systems can be supplemented by
                     emulsifying solutions to speed the process.  Although these additives speed
                     the cleaning process, they can make separation of the oil from the waiter very
                     difficult and create problems with disposal of the waste.
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                     Non-Solvent Based Paint Stripping Non-solvent  based paint stripping
                     methods are viable substitutes for solvent stripping.   Paint  stripping  is
                     normally performed by soaking, spraying, or brushing surfaces  with a
                     stripping agent such as methylene chloride, chromates, phenols, or strong
                     acids. After the agent has remained on the parts for a period, the surface is
                     rinsed with water and the loosened paint is sprayed or brushed off.   The
                     alternatives to solvent stripping agents include aqueous striping agents, use
                     of abrasives, cryogenic stripping, and thermal stripping.

                     Aqueous stripping agents, such as caustic soda (NaOH), are often employed
                     in place of methylene chloride based strippers.  Caustic solutions have the
                     advantage of eliminating solvent vapor emissions.  A typical caustic bath
                     consists of about 40 percent caustic solution  heated to about 200 degrees
                     Fahrenheit.  Caustic stripping is generally effective  on  alkyl resins  and oil
                     paints.

                     Cryogenic stripping utilizes liquid nitrogen and non-abrasive plastic beads as
                     blasting shot. This method relies on the freezing effect of the liquid nitrogen
                     and the impact of the plastic shot. Subjecting the  surface to extremely low
                     temperatures creates stress between the coating and  the substrate causing the
                     coating to become brittle.  When the plastic shot hits the brittle coating,
                     debonding occurs.  The process is non-abrasive,  and will not damage the
                     substrate,  but  effects  of the  metal shrinkage,  due  to extremely  low
                     temperatures,  should be monitored.  The process does not produce liquid
                     wastes, and nitrogen, chemically inert, is already present in the atmosphere
                     (U.S. EPA, March 1997).

                     The most common form of non-solvent paint  stripping in  shipyards is  the use
                     of abrasive blasting.  The use of various  metallic  grit propelled  at high
                     pressure against the surface is very effective  to remove marine coatings.

                     Thermal stripping methods can be useful for objects that cannot be immersed.
                     In this process, superheated air is directed against the surface of the object.
                     The high temperatures cause some paints to flake  off. The removal results
                     from the drying effects of the air and the uneven expansion of the paint and
                     the substrate. Some paints will melt at high temperatures, allowing the paint
                     to be scraped off. Hand-held units are available that produce a jet of hot air.
                     Electric units and open flame or torch units are also used. While this system
                     is easy to implement, it is limited to items that are  not heat sensitive and to
                     coatings that are affected by the heat.

       Reducing the Use of Solvent

                     By eliminating the use or need for solvent cleaning, the problems associated
                     with disposal  of spent solvent are  also  eliminated.  In cases  where the
                     elimination of solvent use is not possible or practical, utilization of various
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                     solvent waste reduction techniques can lead to a substantial savings in solvent
                     waste.

                     Methods of reducing solvent usage can be divided into three categories:
                     source control of air emissions, efficient use of solvent and equipment, and
                     maintaining solvent quality.  Source control of air emissions addresses ways
                     in which more of the solvent can be kept inside a container or cleaning tank
                     by reducing the chances for evaporation loss. Efficient use of solvent and
                     equipment through better operating procedures  can reduce the amount of
                     solvent required for cleaning. Maintaining the quality of solvent will extend
                     the lifecycle effectiveness of the solvent.

                     Source Control  of Air Emissions Source control of air emissions  can  be
                     achieved through equipment modification and proper operation of equipment.
                     Some simple control measures include installation and use of lids, an increase
                     of freeboard height of cleaning tanks, installation of freeboard chillers, and
                     taking steps to reduce solvent drag-out.

                     All cleaning units, including cold cleaning tanks and dip tanks, should have
                     some type of lid installed. When viewed from the standpoint of reducing  air
                     emissions, the roll-type cover is preferable to the hinge type.  Lids that swing
                     down can cause a piston effect and force the escape of solvent vapor.  In
                     operations such as vapor degreasing, use of lids can reduce solvent loss from
                     24 percent to 50 percent.  For tanks that are continuously in use, covers have
                     been designed that allow the work pieces to enter and leave the tank while the
                     lid remains  closed.

                     In an open top vapor degreaser,  freeboard is defined as the distance from the
                     top of the vapor zone to the top of the tank. Increasing the freeboard will
                     substantially reduce the amount  of solvent loss. A freeboard chiller may also
                     be installed above the primary  condenser coil. This refrigerated coil, much
                     like  the cooling jacket,  chills  the air above the vapor zone and creates a
                     secondary  barrier to vapor  loss.   Reduction in solvent usage, by use of
                     freeboard chillers, can be as high as 60 percent. The major drawback with a
                     freeboard chiller is that it can introduce water (due to condensation from air)
                     into the tank.

                     In addition to measures  that reduce air  emissions through equipment
                     modification, it is also possible to reduce emissions through proper equipment
                     layout, operation, and maintenance.  Cleaning tanks should be located in areas
                     where air turbulence and temperature do not promote vapor loss.

                     Maximize the Dedication of the Process Equipment In addition to reduction
                     in vapor loss, reducing the amount of solvent used can be achieved through
                     better operating practices that increase the  efficiency of solvent cleaning
                     operations.  Maximizing the dedication of the process equipment reduces the
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                     need for frequent cleaning.  By using a mix tank consistently for the same
                     formulation, the need to clean equipment between batches is eliminated.

                     Avoid Unnecessary  Cleaning  Avoiding unnecessary cleaning  also offers
                     potential for waste reduction. For example, paint mixing tanks for two-part
                     paints are often cleaned between batches of the same product.  The effect of
                     cross-contamination  between batches should be examined  from a product
                     quality control viewpoint to see if the cleaning step is always necessary.

                     Process pipelines are often flushed with some type of solvent to remove
                     deposits on the pipe walls. Cleaning the pipelines can be  achieved by using
                     an inert gas propellant to remove deposits.  This method can only be used if
                     the pipelines do not have many bends or sharp turns.

                     Proper  Production Scheduling Proper  production scheduling can reduce
                     cleaning frequency  by eliminating the need  for  cleaning  between  the
                     conclusion of one task and the start of the next.  A simple  example of this
                     procedure is to have a small overlap between shifts that  perform the same
                     operation with the same equipment. This allows the equipment that would
                     normally be cleaned and put away at the end of each shift, such as painting
                     equipment, to be taken over directly by the relief.

                     Clean Equipment Immediately Cleaning equipment immediately after use
                     prevents deposits from hardening and avoids the need for consuming extra
                     solvent. Letting dirty equipment accumulate and be cleaned later can  also
                     increase the time required for cleaning.

                     Better  Operating  Procedures Better operating procedures can minimize
                     equipment clean-up waste.  Some of the  methods already discussed are
                     examples of better operating procedures. Better operator training, education,
                     closer supervision, improved equipment maintenance, and increasing the use
                     of automation are very effective in waste minimization.

                     Reuse Solvent Waste Reuse of solvent waste can reduce or eliminate waste
                     and result in a cost  savings associated with a decrease in raw material
                     consumption.  The solvent from cleaning operations can be  reused in other
                     cleaning processes in  which the degree of cleanliness required is much less.
                     This will be discussed in more detail in the next section.

       Solvent Recycling

                     Although not a preferable  as source reduction,  solvent recycling may be a
                     viable alternative for some shipyards. The goal of recycling is to recover from
                     the waste solvent, a solvent of a similar purity to that of the  virgin solvent for
                     eventual reuse in the same  operation, or of a sufficient purity to be used in
                     another application. Recycling can also include the direct use of solvent waste
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                     from one waste stream in another operation. There are a number of techniques
                     that shipyards can use onsite to separate solvents from contaminants including
                     distillation, evaporation,  sedimentation, decanting, centrifugation, filtering,
                     and membrane separation.

V.F.  Machining and Metalworking

                     Coolant fluids account for the largest waste stream generated by machining
                     operations.  Waste metalworking fluids are created when the fluids are no
                     longer usable due to contamination by oils or chemical additives.  If the
                     contamination rate of the metalworking fluids is reduced, the need to replace
                     them will be less frequent.  This will reduce the waste generated.

       Preventing Fluid Contamination

                     Fluid  can become hazardous waste if it is contaminated.  Although it is not
                     possible to  eliminate contamination, it is possible to reduce the rate  of
                     contamination and thereby prolong its use.

                     The primary contaminant in these waste fluids is tramp oil. One way to
                     postpone contamination is to promote better maintenance of the wipers and
                     seals.  A preventative maintenance program should be installed and enforced
                     in the machine shop.  Scheduled sump and  machine cleaning as well  as
                     periodic inspections of the wipers and oil seals should be carried out.  The
                     responsibility for this should be assigned to  some person or group in a
                     position of authority to ensure its success.
       Synthetic Fluids
                     Synthetic fluids have many advantages over the non-synthetic counterparts.
                     Usually the synthetic varieties do not lubricate as effectively, but they are less
                     susceptible to contamination and highly resistant to biological breakdown.
                     Most synthetic fluids have superior longevity and can operate over a large
                     temperature range without adverse side  effects.   Straight  oils should  be
                     replaced with synthetic ones when possible.
       Recycling Fluids
                     Once all of the source reduction options have been considered, it is time to
                     explore the possibilities of reuse.  It should be noted that in many cases, after
                     the majority of the contaminants have been removed, further treatment with
                     chemicals  or  concentrated  fluid  is  necessary  before  the fluids can  be
                     recirculated through the machines.

                     Filtration. Filtration is a common way to remove particles from the fluid as
                     well as tramp oils or other contaminants. Many different types of filters can
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                      be used depending on the medium to be filtered and the amount of filtration
                      desired. Contaminated cutting fluids can be passed through a bag, disc, or
                      cartridge filter or separated in a centrifuge.

                      Skimming and  Flotation.  Although  it is  a slow process, skimming of
                      contaminants is inexpensive and can be very effective. The principle is to let
                      the fluid sit motionless in a sump or a tank, and after a predetermined amount
                      of time, the unwanted oils are skimmed off the  surface and the heavier
                      paiticulate matter is collected off the bottom.  A similar technique, flotation,
                      injects high pressure air into contaminated cutting fluid.  As the air comes out
                      of solution  and bubbles to the surface, it attaches itself to  suspended
                      contaminants and carries them up to the surface.   The resulting sludge is
                      skimmed off the surface and the clean fluid is reused.

                      Centrifugation . Centrifugation uses the same settling principles as flotation,
                      but the effects of gravity are multiplied thousands of times due to the spinning
                      action of the centrifuge. This will increase the volume of fluids which can be
                      cleaned in a given amount of time.

                      Pasteurization. Pasteurization uses heat treatment to kill microorganisms in
                      the fluid and reduce the rate at which rancidity (biological breakdown) will
                      occur. Unfortunately, heat can alter the properties  of the fluid and render it
                      less effective. Properties lost in this way are usually impossible to recover.

                     Downgrading. Sometimes it is possible to use high quality hydraulic oils as
                      cutting fluids. After the oils have reached their normal usable life, they no
                     longer meet the high standards necessary for hydraulic components. At this
                     time they are still good enough to be used for the less  demanding jobs. It may
                     be necessary to  treat the fluid before it can be reused, but changing fluid's
                     functions in this manner has proven successful in the past.
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             Federal Statutes and Regulations
VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS

                     This section discusses the Federal regulations that may apply to this sector.
                     The purpose of this section is to highlight and briefly describe the applicable
                     Federal requirements, and to provide citations for more detailed information.
                     The three following sections are included:

                     •      Section VI. A. contains a general overview of major statutes
                     •      Section VLB. contains a list of regulations specific to this industry
                     •      Section VI. C. contains a list of pending and proposed regulations

                     The  descriptions  within Section VI  are  intended  solely for general
                     information.   Depending upon the nature or scope of the activities at a
                     particular facility, these summaries may or may not necessarily describe all
                     applicable environmental  requirements.  Moreover, they do not constitute
                     formal interpretations or  clarifications of the  statutes and regulations.  For
                     further information,  readers should consult the Code of Federal Regulations
                     and other state or local regulatory agencies. EPA Hotline contacts are also
                     provided for each major statute.

VI.A. General Description of Major Statutes

      Resource Conservation and Recovery Act

                     The Resource Conservation And Recovery Act (RCRA) of 1976,  which
                     amended the Solid  Waste Disposal Act, addresses solid (Subtitle D) and
                     hazardous (Subtitle C) waste management activities.  The Hazardous and
                     Solid Waste Amendments (HSWA) of 1984 strengthened RCRA's waste
                     management provisions and added Subtitle I, which governs underground
                     storage tanks (USTs).

                     Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
                     260-299) establish a "cradle-to-grave" system governing hazardous waste
                     from the point of generation to disposal. RCRA hazardous wastes include the
                     specific materials listed in the regulations (commercial chemical products,
                     designated with the code "P" or "U"; hazardous  wastes from specific
                     industries/sources, designated with the code "K"; or hazardous wastes from
                     non-specific sources, designated with the code "F") or materials which exhibit
                     a hazardous waste characteristic (ignitability, corrosivity, reactivity, or toxicity
                     and designated with the code "D").

                     Regulated  entities  that generate hazardous waste  are subject to  waste
                     accumulation, manifesting, and record keeping standards.  Facilities must
                     obtain a permit either from EPA or  from  a State agency which EPA has
                     authorized to implement the permitting program  if they store hazardous
                     wastes for more than 90 days (or 180 days depending on the amount  of waste
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                    generated) before treatment or disposal. Facilities may treat hazardous wastes
                    stored in less-than-ninety-day tanks or containers without a permit provided
                    the procedure is  approved by a state  agency having RCRA delegation
                    authority.  Subtitle C permits contain  general facility standards  such as
                    contingency plans, emergency procedures, record keeping and reporting
                    requirements, financial assurance mechanisms, and unit-specific standards.
                    RCRA also contains provisions (40 CFR Part 264 Subpart S and §264.10) for
                    conducting corrective actions which govern the cleanup of releases of
                    hazardous  waste  or  constituents from  solid waste management  units at
                    RCRA-regulated facilities.

                    Although RCRA  is a Federal statute, many States implement the RCRA
                    program.  Currently, EPA has delegated its authority to implement various
                    provisions  of RCRA to  47 of the 50 States and two U.S. territories.
                    Delegation has not been given to Alaska, Hawaii, or Iowa.

                    Most RCRA requirements are not industry specific but apply to any company
                    that generates, transports, treats, stores, or disposes of hazardous waste.
                    Here are some important RCRA regulatory requirements:

                           Identification of Solid and Hazardous Wastes (40 CFR Part 261)
                           lays out the procedure every generator must follow to  determine
                           whether the material in question is considered a hazardous waste,
                           solid waste, or is exempted from  regulation.

                           Standards for Generators of Hazardous Waste (40 CFR Part 262)
                           establishes  the responsibilities of hazardous waste generators including
                           obtaining an EPA ID number, preparing a manifest,  ensuring proper
                           packaging and labeling, meeting standards for waste accumulation
                           units, and recordkeeping and reporting requirements.  Generators can
                           accumulate hazardous waste for up to 90 days (or 180 days depending
                           on the amount of waste generated) without obtaining a permit.

                    •      Land Disposal  Restrictions (LDRs)  (40 CFR  Part  268) are
                           regulations prohibiting the  disposal of hazardous waste  on  land
                           without prior treatment.  Under  the LDRs program, materials must
                           meet LDR treatment standards prior to placement in a RCRA land
                           disposal unit (landfill, land treatment unit, waste  pile, or surface
                           impoundment). Generators of waste subject to the LDRs must provide
                           notification of such to the designated TSD facility to ensure proper
                           treatment  prior to disposal.

                    •      Used Oil Management  Standards  (40 CFR Part 279) impose
                           management  requirements  affecting  the storage,  transportation,
                           burning, processing, and re-refining of the used oil.  For parties that
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            Federal Statutes and Regulations
                           merely generate used oil, regulations establish storage standards.  For
                           a party considered a used oil processor, re-refiner, burner, or marketer
                           (one who generates and sells off-specification used oil), additional
                           tracking and paperwork requirements must be satisfied.

                    •      RCRA contains unit-specific standards for  all units used to store,
                           treat, or  dispose  of hazardous  waste,  including  Tanks and
                           Containers.  Tanks and containers used to store hazardous waste
                           with a  high  volatile organic concentration must  meet emission
                           standards under RCRA. Regulations (40 CFRPart 264-265, Subpart
                           CC) require  generators  to test  the  waste to  determine  the
                           concentration of the waste, to satisfy tank and container emissions
                           standards,  and to inspect and  monitor regulated units.   These
                           regulations apply to all facilities that store such waste, including large
                           quantity generators accumulating waste prior to shipment off-site.

                    •      Underground Storage Tanks (USTs)  containing petroleum  and
                           hazardous  substances are regulated under Subtitle  I  of RCRA.
                           Subtitle I  regulations (40 CFR Part 280) contain tank  design and
                           release detection requirements, as well as financial responsibility and
                           corrective action  standards for USTs.   The UST program  also
                           includes upgrade requirements for existing tanks that must be met by
                           December 22, 1998.

                    •      Boilers  and  Industrial Furnaces (BIFs)  that use  or burn  fuel
                           containing hazardous waste must comply with design and operating
                           standards.  BIF regulations (40 CFR Part 266, Subpart H) address
                           unit design,  provide performance standards,  require emissions
                           monitoring, and restrict the type of waste that may be burned.

                    EPA'sRCRA, SuperfundandEPCRA Hotline, at (800) 424-9346, responds
                    to questions and distributes guidance regarding all RCRA regulations.  The
                    RCRA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., ET, excluding
                    Federal holidays.

       Comprehensive Environmental Response, Compensation, and Liability Act

                    The Comprehensive Environmental Response, Compensation, and Liability
                    Act (CERCLA), a 1980 law known commonly as Superfund,  authorizes EPA
                    to respond to releases, or threatened releases, of hazardous substances that
                    may endanger public health, welfare, or the environment.  CERCLA also
                    enables EPA to force parties responsible for environmental contamination to
                    clean it up or to reimburse the Superfund for response costs incurred by EPA.
                    The Superfund Amendments and Reauthorization Act (SARA) of 1986
                    revised various sections of CERCLA, extended the taxing authority for the
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                    Superfund, and created a free-standing law, SARA Title IE, also known as the
                    Emergency Planning and Community Right-to-Know Act (EPCRA).

                    The CERCLA hazardous substance release reporting regulations (40 CFR
                    Part 302)  direct the person in charge of a facility to report to the National
                    Response Center (NRC) any environmental release of a hazardous substance
                    which equals or exceeds a reportable quantity. Reportable quantities are listed
                    in 40 CFR §302.4. A release report may trigger a response by EPA, or by one
                    or more Federal or State emergency response authorities.

                    EPA implements hazardous substance responses according to procedures
                    outlined in the National Oil and Hazardous Substances Pollution Contingency
                    Plan (NCP) (40 CFR Part 300).  The NCP includes provisions for permanent
                    cleanups, known as remedial actions, and other  cleanups referred to  as
                    removals. EPA generally takes remedial actions only at sites on the National
                    Priorities List (NPL), which currently includes approximately 1300 sites.
                    Both EPA and states can act at sites; however, EPA provides responsible
                    parties  the opportunity to  conduct removal and remedial actions and
                    encourages community involvement throughout the Superfund response
                    process.

                    EPA'sRCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers
                    questions and references guidance pertaining to the Superfund program.
                    This Hotline, which addresses CERCLA issues, operates weekdays from 9:00
                    a.m. to  6:00 p.m., ET, excluding Federal holidays.

       Emergency Planning And Community Right-To-Know Act

                    The Superfund Amendments and Reauthorization Act (SARA) of 1986
                    created  the  Emergency  Planning  and Community  Right-to-Know Act
                    (EPCRA,  also known  as SARA Title III), a statute designed to improve
                    community access to information about chemical hazards and to facilitate the
                    development of chemical  emergency response plans by  State arid local
                    governments.  EPCRA required the establishment  of State emergency
                    response  commissions  (SERCs),  responsible  for coordinating  certain
                    emergency response activities and for appointing local emergency planning
                    committees (LEPCs).

                    EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four
                    types of reporting obligations for facilities which store or manage specified
                    chemicals:

                          EPCRA §302 requires facilities to notify the SERC and LEPC of the
                          presence of any extremely hazardous substance  (the list of such
                          substances is in 40 CFR Part 355, Appendices A and B) if it has such
                          substance in excess of the substance's threshold planning quantity, and
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                           directs the facility to appoint an emergency response coordinator.

                           EPCRA §304 requires the facility to notify the SERC and the LEPC
                         .  in the event of a release equaling or exceeding the reportable quantity
                           of  a CERCLA hazardous  substance  or an EPCRA extremely
                           hazardous substance.

                           EPCRA  §311 and §312  require a facility at which a hazardous
                           chemical,  as defined by the Occupational Safety and Health Act, is
                           present in an amount exceeding a specified threshold to submit to the
                           SERC, LEPC and local fire department material safety data sheets
                           (MSDSs) or lists of MSDSs and hazardous chemical inventory forms
                           (also known as Tier I and II forms).  This information helps the local
                           government respond in the event of a spill or release of the chemical.

                     •      EPCRA §313 requires manufacturing facilities included in SIC codes
                           20  through 39,  which have ten or more employees, and which
                           manufacture,  process, or use specified chemicals in amounts greater
                           than threshold quantities, to submit an annual toxic chemical release
                           report. This report, known commonly as the Form R, covers releases
                           and transfers of toxic chemicals to various facilities and environmental
                           media, and allows EPA to compile the national  Tbxic  Release
                           Inventory  (TRI) database.

                     All  information  submitted pursuant to EPCRA regulations is  publicly
                     accessible, unless  protected by a trade secret claim.

                     EPA'sRCRA, Super/and and EPCRA Hotline, at (800) 424-9346, answers
                     questions and distributes guidance regarding the emergency planning and
                     community  right-to-know regulations.   The EPCRA Hotline  operates
                     •weekdays from 9:00 a.m. to 6:00 p.m., ET, excluding Federal holidays.

       Clean Water Act

                     The primary objective  of the Federal Water Pollution Control Act, commonly
                     referred to as the Clean Water Act (CWA), is to restore  and maintain the
                     chemical, physical, and biological  integrity of the nation's surface waters.
                     Pollutants regulated under the CWA include "priority" pollutants, including
                     various toxic pollutants; "conventional" pollutants, such as biochemical
                     oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and
                     grease, and pH; and "non-conventional" pollutants, including  any pollutant not
                     identified as either conventional or priority.

                     The CWA regulates both direct and indirect discharges.  The National
                    Pollutant Discharge Elimination System (NPDES) program (CWA §502)
                     controls direct discharges into navigable waters. NPDES permits, issued by

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                     either EPA or an authorized State (EPA has authorized  42 States to
                     administer the NPDES program), contain industry-specific, technology-based
                     and/or water quality-based  limits, and establish  pollutant  monitoring
                     requirements. A facility that intends to discharge into the nation's waters
                     must obtain a permit prior to initiating its discharge.  A permit applicant must
                     provide quantitative analytical data identifying the types of pollutants present
                     in the facility's effluent.  The permit will then set the conditions and effluent
                     limitations on the facility discharges.

                     A NPDES permit may also include discharge limits based on Federal or State
                     water quality criteria or standards, that were designed to protect designated
                     uses of surface waters, such as supporting aquatic life or recreation. These
                     standards,  unlike the technological standards, generally do not take into
                     account technological feasibility or costs. Water quality criteria and standards
                     vary from State to State, and site to site, depending on the use classification
                     of the receiving body of water.  Most States follow EPA guidelines which
                     propose  aquatic life and human health criteria for many of the 126 priority
                     pollutants.

                     Storm Water Discharges

                     In 1987  the CWA was amended to require EPA to establish a program to
                     address storm water discharges.  In response, EPA promulgated the NPDES
                     storm water permit application regulations.  These regulations require that
                     facilities with the following storm water discharges apply for an NPDES
                     permit:  (1) a discharge associated with industrial activity; (2) a discharge
                     from a large or  medium municipal storm sewer system; or (3) a discharge
                     which EPA or the State determines to contribute to a violation of a water
                     quality standard or is a significant contributor of pollutants to waters of the
                     United States.

                     The term "storm water discharge associated with industrial activity" means a
                     storm water discharge from one of 11 categories of industrial activity defined
                     at 40 CFR 122.26. Six of the categories are defined by SIC codes while the
                     other five  are identified through narrative descriptions of the regulated
                     industrial activity. If the primary SIC code of the facility is  one of those
                     identified in the  regulations, the facility is subject to the storm  water permit
                     application requirements. If any activity at a facility is covered by one of the
                     five narrative categories, storm water discharges from those areas where the
                     activities occur are  subject to  storm  water discharge  permit application
                     requirements.

                     Those facilities/activities that are  subject to storm water discharge permit
                     application requirements are identified below.   To determine whether a
                     particular facility falls within one of these categories, consult the regulation.
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                      Category i: Facilities subject to storm water effluent guidelines, new source
                      performance standards, or toxic pollutant effluent standards.

                      Category ii:  Facilities  classified as  SIC 24-lumber and wood products
                      (except wood kitchen cabinets); SIC 26-paper and allied products  (except
                      paperboard containers and products); SIC 28-chemicals and allied products
                      (except drugs and paints); SIC 291-petroleum refining; and SIC 311-leather
                      tanning and finishing, 32 (except 323)-stone, clay, glass, and concrete, 33-
                      primary metals,  3441-fabricated structural metal, and 373-ship and boat
                      building and repairing.

                      Category iii:  Facilities classified as SIC 10-metal  mining;  SIC 12-coal
                      mining;  SIC  13-oil and gas extraction; and SIC  14-nonmetallic mineral
                      mining.

                      Category iv:  Hazardous waste treatment,  storage, or disposal facilities.

                      Category v: Landfills, land application sites, and open dumps that receive or
                      have received industrial wastes.

                      Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
                      SIC 5093-automotive scrap and waste material recycling facilities.

                      Category vii:  Steam electric power generating facilities.

                      Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41-
                      local passenger transportation; SIC 42-trucking and warehousing  (except
                      public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
                      transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
                      storage stations and terminals.

                      Category ix:  Sewage treatment works.

                      Category x:  Construction activities except operations that result in the
                     disturbance of less than five acres of total land area.

                     Category xi: Facilities classified as SIC 20-food and kindred products; SIC
                     21-tobacco products; SIC 22-textile mill  products; SIC 23-apparel related
                     products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
                     and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
                     paper and paperboard  products; SIC  27-printing,  publishing, and allied
                     industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
                     allied products;  SIC 30-rubber and plastics; SIC 31-leather  and  leather
                     products (except leather tanning and finishing); SIC 323-glass products; SIC
                     34-fabricated metal products  (except fabricated structural  metal); SIC 35-
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                    industrial  and commercial machinery and computer equipment; SIC 36-
                    electronic  and other electrical  equipment  and components; SIC 37-
                    transportation equipment (except ship and boat building and repair); SIC 38-
                    measuring, analyzing, and controlling instruments;  SIC 39-misceilaneous
                    manufacturing  industries; and SIC 4221-4225-public warehousing and
                    storage.

                    Pretreatment Program

                    Another type of discharge that is regulated by the CWA is one that goes to
                    a  publicly-owned treatment works (POTW). The national pretreatment
                    program (CWA §307(b)) controls the indirect discharge of pollutants to
                    POTWs by "industrial users." Facilities regulated under §307(b) must meet
                    certain pretreatment standards. The goal of the pretreatment program is to
                    protect municipal wastewater treatment plants from damage that may occur
                    when hazardous, toxic, or other wastes are discharged into a sewer system
                    and to protect the quality of sludge generated by these plants. Discharges to
                    a POTW are regulated primarily by the POTW, rather than the State or EPA.

                    EPA has  developed technology-based standards  for industrial users  of
                    POTWs. Different standards apply to existing and new sources within each
                    category.  "Categorical" pretreatment standards applicable to an industry on
                    a  nationwide basis are developed  by EPA.  In addition, another kind of
                    pretreatment standard, "local limits,"  are developed by the POTW in order to
                    assist the POTW in achieving the effluent limitations in its NPDES permit.

                    Regardless of whether a State is authorized to implement either the NPDES
                    or the pretreatment program, if it develops its own program, it may enforce
                    requirements more stringent than Federal standards.

                    Spill Prevention. Control and Countermeasure Plans

                    The 1990 Oil Pollution Act requires that facilities that could reasonably be
                    expected to discharge oil in harmful quantities prepare and implement more
                    rigorous Spill Prevention Control and Countermeasure (SPCC) Plan required
                    under the CWA (40 CFR §112.7). There are also criminal and civil penalties
                    for deliberate or negligent spills of oil.  Regulations covering response to oil
                    discharges and contingency plans (40 CFR Part 300), and Facility Response
                    Plans to oil discharges (40 CFR §112.20) and for PCB transformers and PCB-
                    containing items were revised and finalized in 1995.

                    EPA 's Office of Water, at (202) 260-5700, will direct callers with questions
                    about the CWA to the appropriate EPA  office.  EPA  also maintains a
                     bibliographic  database  of Office of Water publications -which  can be
                     accessed through the Ground Water and Drinking Water resource center, at
                     (202) 260-7786.
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       Safe Drinking Water Act
                     The  Safe  Drinking Water  Act (SDWA) mandates that  EPA establish
                     regulations to protect human health from contaminants in drinking water.
                     The law authorizes EPA to develop national drinking water standards and to
                     create a joint Federal-State system to ensure compliance with these standards.
                     The SDWA also directs  EPA to protect underground sources of drinking
                     water through the control of underground injection of liquid wastes.

                     EPA has developed primary and secondary drinking water standards under its
                     SDWA authority.  EPA and authorized States enforce the primary drinking
                     water standards, which are,  contaminant-specific concentration limits that
                     apply to certain public drinking water supplies.  Primary  drinking  water
                     standards consist of maximum contaminant level goals (MCLGs), which are
                     non-enforceable health-based  goals,  and  maximum contaminant  levels
                     (MCLs), which are enforceable limits set as  close to MCLGs as possible,
                     considering cost and feasibility of attainment.

                     The SDWA Underground Injection Control (UIC) program (40 CFR Parts
                     144-148) is a permit program which protects underground sources of drinking
                     water by regulating five  classes of injection wells.  UIC permits include
                     design, operating, inspection, and monitoring requirements.  Wells used to
                     inject hazardous wastes  must also comply with RCRA corrective action
                     standards in order to be granted a RCRA permit, and must meet applicable
                     RCRA land disposal restrictions standards.  The UIC permit program is
                     primarily State-enforced,  since EPA has authorized all but a few States to
                     administer the program.

                     The SDWA also provides for a Federally-implemented Sole Source Aquifer
                     program, which prohibits Federal funds from being expended on projects that
                     may contaminate the sole or principal source of drinking water for a given
                     area, and for a State-implemented Wellhead Protection program, designed to
                     protect drinking water wells and drinking water recharge areas.

                    EPA 's Safe Drinking Water Hotline, at (800)  426-4791, answers questions
                    and distributes guidance pertaining to SDWA  standards.   The Hotline
                    operates from 9:00 a.m. through 5:30 p.m., ET, excluding Federal holidays.
       Toxic Substances Control Act
                    The Toxic Substances Control Act (TSCA) granted EPA authority to create
                    a regulatory framework to collect data on chemicals in order to evaluate,
                    assess, mitigate, and control risks which may be posed by their manufacture,
                    processing, and use. TSCA provides a variety of control methods to prevent
                    chemicals from posing unreasonable risk.
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                    TSCA standards may apply at any point during a chemical's life cycle. Under
                    TSCA §5, EPA has established an inventory of chemical substances.  If a
                    chemical is not already on the inventory, and has not been excluded by TSCA,
                    a  premanufacture  notice (PMN) must  be submitted to  EPA prior to
                    manufacture or import. The PMN must identify the chemical and provide
                    available information on health and environmental effects.  If available data
                    are not  sufficient  to  evaluate the  chemicals effects, EPA can  impose
                    restrictions pending the development of information on its health  and
                    environmental effects. EPA can also restrict significant new uses of chemicals
                    based upon factors such as the projected volume and use of the chemical.

                    Under TSCA §6, EPA can ban the manufacture or distribution in commerce,
                    limit the use, require labeling, or place other restrictions on chemicals that
                    pose  unreasonable risks.  Among the  chemicals EPA regulates under §6
                    authority are asbestos, chlorofluorocarbons (CFCs), and polychlorinated
                    biphenyls (PCBs).

                    Under TSCA §8, EPA requires the producers and importers of chemicals to
                    report information on chemicals' production,  use, exposure, and risks.
                    Companies producing and importing chemicals can be required to report
                    unpublished health and safety studies on listed chemicals and to collect and
                    record any allegations of adverse reactions or any information indicating that
                    a substance may pose a significant risk to  humans or the environment.

                    EPA 's TSCA Assistance Information Service, at (202) 554-1404, answers
                    questions and distributes guidance pertaining to Toxic Substances Control
                    Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., ET,
                    excluding Federal holidays.
       Clean Air Act
                     The Clean Air Act (CAA) and its amendments, including the Clean Air Act
                     Amendments (CAAA) of 1990, are designed to "protect and enhance the
                     nation's air resources so as to promote the public health and welfare and the
                     productive capacity of the population." The CAA consists of six sections,
                     known as Titles, which direct EPA to establish national standards for ambient
                     air quality and for EPA and the States to implement, maintain, and enforce
                     these standards through a variety of mechanisms.  Under the CAAA, many
                     facilities will be required to obtain permits for the first time. State and local
                     governments oversee, manage, and enforce many of the requirements of the
                     CAAA.  CAA regulations appear at 40 CFR Parts 50-99.

                     Pursuant to Title I of the CAA, EPA has established national ambient air
                     quality standards (NAAQSs) to limit levels of "criteria pollutants," including
                     carbon monoxide, lead, nitrogen dioxide, particulate matter, volatile organic
                     compounds  (VOCs),  ozone, and sulfur dioxide.  Geographic areas that meet
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                     NAAQSs for a given pollutant are classified as attainment areas; those that do
                     not meet NAAQSs are classified as non-attainment areas.  Under section 110
                     of the CAA, each State must develop a State Implementation Plan (SIP) to
                     identify sources of air pollution and to determine what reductions are required
                     to meet Federal air quality standards. Revised NAAQSs for particulates and
                     ozone were proposed in 1996 and may go into effect as early as 1997.

                     Title I also authorizes EPA to establish New Source Performance Standards
                     (NSPSs), which are nationally uniform emission standards for new stationary
                     sources falling within particular industrial categories.  NSPSs are based on the
                     pollution control technology available to that category of industrial source.

                     Under Title I, EPA establishes and enforces National Emission  Standards for
                     Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
                     towards controlling particular hazardous air pollutants (HAPs).  Title I,
                     section 112(c) of the CAA further directed EPA to develop a list of sources
                     that emit any of 189 HAPs, and to develop regulations for these categories of
                     sources.  To date EPA has listed 174 categories and developed a schedule for
                     the  establishment of emission standards.  The emission standards will be
                     developed for both new and existing sources based on "maximum achievable
                     control  technology" (MACT). The MACT is defined  as  the  control
                     technology achieving the maximum degree of reduction in the emission of the
                     HAPs, taking  into account cost and other factors. Title I, section  112(r)
                     directed EPA to develop a list of hazardous chemicals and regulations to
                     control  and prevent  accidental  releases of these  chemicals.  Owners and
                     operators of facilities at which such substances are present in more than a
                     threshold quantity will have to prepare risk management plans for each
                     substance used at the facility. EPA may also require annual audits and safety
                     inspections to prevent leaks and  other episodic releases.

                     Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
                     and planes.  Reformulated gasoline, automobile  pollution control devices, and
                     vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses
                     to regulate mobile air emission sources.

                     Title IV of the CAA establishes a sulfur dioxide  and nitrogen oxides emissions
                     program designed to reduce the formation of acid rain. Reduction of sulfur
                     dioxide  releases  will be obtained by granting  to  certain  sources limited
                     emissions allowances, which, beginning in  1995, will be set below previous
                     levels of sulfur dioxide releases.

                     Title V of the CAA of 1990 created a permit program for all  "major sources"
                     (and certain other sources) regulated under the CAA. One purpose of the
                     operating permit  is to  include in a single  document all air emissions
                     requirements that apply to a given facility.  States are developing the permit
                     programs in accordance with guidance and regulations from EPA. Once a
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                    State program is approved by EPA, permits will be issued and monitored by
                    that State.

                    Title VI of the CAA is intended to protect stratospheric ozone by phasing out
                    the manufacture of ozone-depleting chemicals and restrict their use and
                    distribution.  Production of Class  I substances, including  15 kinds of
                    chlorofluorocarbons (CFCs) and chloroform, were phased out (except for
                    essential uses) in 1996.

                    EPA's Clean Air Technology Center, at (919) 541-0800, provides general
                    assistance and information  on CAA standards.  The Stratospheric Ozone
                    Information Hotline, at (800)  296-1996, provides general information about
                    regulations promulgated under Title VI of the CAA, and EPA's EPCRA
                    Hotline, at (800) 535-0202, answers questions about accidental release
                    prevention  under CAA §112(r). In addition, the Clean Air Technology
                    Center's website includes recent CAA rules, EPA guidance documents, and
                    updates of EPA activities (www.epa.gov/ttn then select Directory and then
                    CATC).
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 VLB. Industry Specific Requirements

       Resource Conservation and Recovery Act (RCRA)
                     A material is classified under RCRA as a hazardous waste if the material
                     meets the definition of solid waste (40 CFR 261.2), and that solid waste
                     material exhibits one of the characteristics of a hazardous waste (40 CFR
                     261.20-40) or is specifically listed as a hazardous waste (40 CFR 261.31-33).
                     A material defined as a hazardous waste may then be subject to  Subtitle C
                     generator (40 CFR 262), transporter (40 CFR 263), and treatment, storage,
                     and disposal facility (40 CFR 264 and 265) requirements.  The shipbuilding
                     and repair industry must be concerned with the regulations addressing all of
                     these.

                     Several common shipyard operations have the potential to generate RCRA
                     hazardous wastes.  Some of these wastes are identified below by process.

                     Machining and Other Metalworking

                     •      Metalworking fluids contaminated with oils, phenols, creosol, alkalies,
                           phosphorus compounds, and chlorine

                     Cleaning and Degreasing
                            Solvents (F001, F002, F003, F004, F005)
                            Alkaline and Acid Cleaning Solutions (D002)
                            Cleaning filter sludges with toxic metal concentrations
                    Metal Plating and Surface Finishing and Preparation
                     •      Wastewater treatment sludges from electroplating operations (F006)
                     •      Spent cyanide plating bath solutions (F007)
                     •      Plating bath residues from the bottom of cyanide plating baths (F008)
                     •      Spent  stripping and cleaning bath  solutions from cyanide plating
                           operations (F009)

                     Surface Preparation, Painting and Coating

                     •      Paint and paint containers containing paint sludges with solvents or
                           toxic metals concentrations
                           Solvents (F002, F003)
                     •      Paint chips with toxic metal concentrations
                     •      Blasting media contaminated with paint chips
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                    Vessel Cleaning

                    •      Vessel sludges
                    •      Vessel cleaning wastewater
                    •      Vessel cleaning wastewater sludges

                    Fiberglass Reinforced Construction

                           Solvents (F001, F002, F003, F004, F005)
                    •      Chemical additives and catalysts

                    Shipbuilding and repair facilities may also generate used lubricating oils which
                    are regulated under RCRA but may or may not be considered a hazardous
                    waste (40 CFR 266).

       United States Code, Title 10, Section  7311

                    Title 10, Section 7311 of the U.S. Code applies specifically to the handling of
                    hazardous waste (as defined by RCRA) during the repair and maintenance of
                    naval vessels. The Code requires the navy to identify the types and amounts
                    of hazardous wastes that will be generated or removed by a contractor
                    working on a naval vessel and that the navy compensate the contractor for the
                    removal, handling,  storage, transportation, or disposal of the hazardous
                    waste.  The Code also requires that waste generated solely by the navy and
                    handled by the contractor bears a generator identification number issued to
                    the  navy;  wastes generated and handled solely by the contractor bears a
                    generator identification number issued to the contractor; and waste generated
                    by both the navy and the contractor and handled by the contractor bears a
                    generator identification number issued to the contractor and a generator
                    identification number issued to the navy.
       Clean Air Act
                     Under Title HI of the 1990 Clean Air Act Amendments (CAAA), EPA is
                     required to develop national emission standards  for  189 hazardous air
                     pollutants (NESHAP).  EPA is developing maximum achievable control
                     technology (MACT) standards for all new and existing sources. The National
                     Emission Standards for Shipbuilding and Repair Operations (Surface Coating)
                     (40 CFR Part 63 Subpart IT) were finalized in 1995 and apply to major source
                     shipbuilding and  ship repairing facilities that  carry out  surface coating
                     operations. Shipyards that emit ten or more tons of any one HAP or 25 or
                     more tons of two or more HAPs  combined are subject to the MACT
                     requirements.  The MACT requirements set VOC limits for different types of
                     marine coatings and performance standards to reduce spills, leaks,  and
                     fugitive emissions. EPA estimates that there are approximately 35 major
                     source shipyards affected by this regulation. Shipbuilding and repair facilities
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                      may also be subject to National Emissions Standards for Asbestos (40 CFR
                      Part 61 Subpart M).  Both NESHAPs require emission limits, work practice
                      standards, record keeping, and reporting.

                      Under Title V of the CAAA 1990 (40 CFR Parts 70-72)  all of the applicable
                      requirements of the Amendments are integrated into one federal renewable
                      operating permit.  Facilities defined as "major sources"  under the Act must
                      apply for permits within one year from when EPA approves the state permit
                      programs.   Since most state  programs  were not  approved until  after
                      November 1994, Title V permit applications, for the most part, began to be
                      due in late 1995. Due dates for filing complete applications vary significantly
                      from state to state, based on the status of review and approval of the state's
                      Title V program by EPA.

                      A facility is designated as  a major source for Title V if it releases a certain
                      amount of any one of the CAAA regulated pollutants (SOX, NOX, CO, VOC,
                      PM10, hazardous air pollutants, extremely hazardous  substances, ozone
                      depleting substances, and pollutants covered by NSPSs) depending on the
                      region's air quality category. Title V permits may set limits on the amounts
                      of pollutant emissions; require emissions monitoring, and record keeping and
                      reporting. Facilities are required to pay an annual fee based on the magnitude
                      of the facility's potential emissions. It is estimated that approximately 35
                      shipyards will be designated as major sources and therefore must apply for a
                      Title V permit.

        Clean Water Act

                      Shipbuilding and  repair facility wastewater released  to surface waters is
                     regulated under the CWA. National Pollutant Discharge Elimination System
                     (NPDES) permits must be  obtained to discharge wastewater into navigable
                     waters (40 Part 122).  Facilities that discharge to a POTW may be required
                     to meet National Pretreatment Standards for some contaminants.  General
                     pretreatment standards applying to most industries discharging to a POTW
                     are described in 40 CFR Part 403.  In addition, effluent limitation guidelines,
                     new source performance standards, pretreatment standards for new sources'
                     and  pretreatment  standards for existing sources may apply  to  some
                     shipbuilding and repair facilities that carryout electroplating or metal finishing
                     operations.  Requirements for the Electroplating Point Source Category and
                     the Metal Finishing Point Source Category are listed under 40 CFR Part 413
                     and 40 CFR Part 433, respectively.

                     Storm water rules require certain facilities with storm water discharge from
                     any one of 11 categories of industrial activity defined in 40 CFR 122.26 be
                     subject to the storm  water permit application requirements (see Section
                     VI. A). Many shipbuilding and repair facilities fall within these categories.  To
                     determine whether a particular facility falls within one of these  categories, the

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                    regulation should be consulted. Required treatment of storm water flows are
                    expected to remove a large fraction of both conventional pollutants, such as
                    suspended solids and biochemical oxygen demand (BOD), as well as toxic
                    pollutants, such as certain metals and organic compounds.

       Comprehensive Environmental Response, Compensation,  and Liability Act (CERCLA)

                    The Comprehensive Environmental Response, Compensation, and Liability
                    Act (CERCLA) and the Superfund Amendments and Reauthorization Act of
                    1986 (SARA) provide the basic legal framework for the federal "Superfund"
                    program to clean up abandoned hazardous waste sites (40 CFR Part 305).
                    Metals and metal compounds often found in shipyards' air emissions, water
                    discharges,  or waste shipments  for off-site disposal include chromium,
                    manganese, aluminum, nickel, copper, zinc, and lead. Metals are frequently
                    found at CERCLA's problem sites. When Congress ordered EPA and the
                    Public Health Service's Agency for Toxic Substances and Disease Registry
                    (ATSDR) to list the hazardous substances most commonly found at problem
                    sites and that pose the greatest threat to human health, lead, nickel, and
                    aluminum all made the list.
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 VI.C. Pending and Proposed Regulatory Requirements

       Clean Water Act
                     Effluent limitation guidelines for wastewater discharges from metal products
                     and machinery (MP&M) industries are being developed.  MP&M industries
                     have been divided into two groups that originally were to be covered under
                     two separate phases of the rulemaking.  Effluent guidelines for Phase I
                     industries and Phase II industries (which includes the shipbuilding and repair
                     industry) will now be covered under a single regulation to be proposed in
                     October 2000 and finalized in December 2002.  (Steven Geil, U.S. EPA,
                     Office of Water, Engineering and Analysis Division, (202) 260-9817, email:
                     geil. steve@epamail. epa. go v)
       Clean Air Act
                     In August 1996, EPA published Control Technique Guidelines (CTG) for the
                     control of VOC emissions from surface coating operations in the shipbuilding
                     and ship repair industry. The CTG was issued to assist states in analyzing and
                     determining reasonably available control technology (RACT) standards for
                     major sources of VOCs in the shipbuilding and repair operations located
                     within ozone NAAQS nonattainment areas. EPA estimates that there are
                     approximately 100 facilities that will fall within this category in addition to the
                     approximately 35 major sources identified for the NESHAP MACT standards.
                     Within one year  of the publication of the CTG, states must adopt a RACT
                     regulation at least as stringent as the limits recommended in the CTG. Under
                     Section 183(b)(4) of the Clean Air Act, EPA is required to issue the CTG for
                     the  shipbuilding and  repair industry based on  "best available  control
                     measures" (BACM) for emissions of VOCs and particulates. In developing
                     the CTG, EPA determined that the MACT standard of the 1995 NESHAP for
                     Shipbuilding and  Repair  Operations  (Surface  Coating) is  the   only
                     technologically and economically feasible level of control for these sources.
                     Therefore, for shipbuilding and repair operations, EPA considers the RACT,
                     BACM, and MACT standards to be identical. For particulate emissions, EPA
                     determined the BACM to be no control.  (Mohamed Serageldin, U.S. EPA,
                     Office of Air Quality Planning and Standards, (919) 541-2379)
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         Compliance and Enforcement History
VII.  COMPLIANCE AND ENFORCEMENT HISTORY

       Background

                     Until  recently,  EPA has  focused  much of its  attention  on measuring
                     compliance with specific environmental statutes.  This approach allows the
                     Agency to track  compliance with the  Clean Air Act,  the Resource
                     Conservation  and Recovery  Act,  the  Clean Water Act,  and  other
                     environmental statutes. Within the last several years, the Agency has begun
                     to  supplement  single-media compliance indicators with facility-specific,
                     multimedia indicators of compliance. In doing so, EPA is in a better position
                     to track compliance with all statutes at the facility level, and within specific
                     industrial sectors.

                     A major step in building the capacity to compile multimedia data for industrial
                     sectors was the creation of EPA's Integrated Data for Enforcement Analysis
                     (IDEA) system. IDEA has the capacity to "read into" the Agency's single-
                     media databases,  extract compliance records, and match the records to
                     individual facilities.  The  IDEA system  can  match Air,  Water, Waste,
                     Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
                     facility, and generate a list of historical permit, inspection, and enforcement
                     activity. IDEA also has the capability to analyze data by geographic area and
                     corporate holder.  As the capacity to generate multimedia compliance data
                     improves,  EPA will  make  available  more  in-depth compliance  and
                     enforcement information. Additionally, sector-specific measures of success
                     for compliance assistance efforts are under development.

       Compliance and Enforcement Profile Description

                     Using inspection, violation and enforcement data from the IDEA system, this
                     section provides  information regarding  the  historical compliance and
                     enforcement activity of this sector. In order to mirror the facility universe
                     reported in the Toxic Chemical Profile, the data reported within this section
                     consists of records only from the TRI reporting universe.  With this decision,
                     the selection criteria are consistent across  sectors with certain exceptions.
                     For the sectors that do not  normally report to the TRI program, data have
                     been provided from EPA's Facility Indexing System (FINDS) which tracks
                     facilities in all  media databases. Please note, in this section, EPA does not
                     attempt to define the actual number of facilities that fall within each sector.
                     Instead, the section portrays the records of a subset of facilities within the
                     sector that are well defined within EPA databases.

                     As  a check on the relative size of the full sector universe, most notebooks
                     contain an estimated number of facilities within the sector according to the
                     Bureau of Census (See  Section  II).  With sectors  dominated by small
                     businesses, such as metal finishers and printers, the reporting universe within
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                    the EPA databases may be small in comparison to Census data. However, the
                    group selected for inclusion in this data analysis section should be consistent
                    with this sector's general make-up.

                    Following this introduction is a list defining each data column presented
                    within this section.  These values represent a retrospective  summary of
                    inspections and enforcement actions, and reflect solely EPA, State, and local
                    compliance assurance activities that have been entered into EPA databases.
                    To identify any changes in trends, the EPA ran two data queries, one for the
                    past five calendar years (April 1, 1992 to March 31, 1997) and the other for
                    the most recent twelve-month period (April 1, 1996 to March 31, 1997). The
                    five-year analysis  gives an average  level of activity for that  period for
                    comparison to the more recent activity.

                    Because most inspections focus on single-media requirements, the data
                    queries presented in this section are taken from single media databases.  These
                    databases do not provide data on whether inspections are state/local or EP A-
                    led. However, the table breaking down the universe of violations does give
                    the reader a crude measurement of the EPA's and states' efforts within each
                    media program.   The presented data illustrate the variations across EPA
                    Regions for certain sectors.4 This variation may be attributable to state/local
                    data  entry  variations, specific geographic concentrations, proximity to
                    population centers, sensitive ecosystems, highly toxic chemicals used in
                    production, or historical noncompliance.  Hence, the exhibited data do not
                    rank regional performance or necessarily reflect which regions may have the
                    most compliance problems.

Compliance and Enforcement Data Definitions

       General Definitions

                    Facility Indexing System (FINDS) — this system assigns a common facility
                    number to EPA single-media permit records.  The FINDS  identification
                    number allows  EPA to compile  and  review  all  permit,  compliance,
                    enforcement and pollutant release data for any given regulated facility.

                    Integrated Data for Enforcement Analysis (IDEA) — is a data integration
                    system that can retrieve information from the major EPA program office
                    databases. IDEA uses the FINDS identification number to link separate data
                    records from EPA's databases.  This allows retrieval of records from across
                    media or statutes for any given facility, thus creating a "master list" of
4 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD, PA,
VA, WV); IV (AL, FL, GA, KY, MS, NC. SC, TN); V (EL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, TX); VII
(IA, KS, MO, NE); VHI (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR,
WA).
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                     records for that facility.  Some of the data systems accessible through IDEA
                     are:  AIRS (Air Facility Indexing and Retrieval System, Office of Air and
                     Radiation), PCS (Permit Compliance  System,  Office of Water), RCRIS
                     (Resource Conservation and Recovery Information System, Office of Solid
                     Waste), NCDB (National Compliance Data Base,  Office of Prevention,
                     Pesticides, and Toxic Substances), CERCLIS (Comprehensive Environmental
                     and Liability  Information System, Superfund),  and  TRIS  (Toxic Release
                     Inventory System).  IDEA also contains information from outside sources
                     Such as Dun and  Bradstreet and the Occupational  Safety and Health
                     Administration (OSHA). Most data queries displayed in notebook sections
                     IV and VII were conducted using IDEA.

        Data Table Column Heading Definitions

                     Facilities in Search — are based on the universe of TRI reporters within the
                     listed SIC code range.  For industries not covered under TRI reporting
                     requirements  (metal mining,  nonmetallic  mineral mining,  electric power
                     generation, ground transportation, water transportation, and dry cleaning), or
                     industries in which only a very small fraction of facilities report to TRI (e.g.,
                     printing), the notebook uses the FINDS universe for executing data queries.
                     The SIC code range selected for each search is defined by each notebook's
                     selected SIC code coverage described in Section II.

                     Facilities  Inspected —  indicates the level of EPA and state agency
                     inspections for the  facilities in this data search. These values show what
                     percentage of the facility universe is inspected in a  one-year or five-year
                     period.

                     Number  of Inspections ~  measures the  total  number  of inspections
                     conducted in  this sector.  An inspection event is counted  each time it is
                     entered into a  single media database.

                     Average Time Between Inspections ~ provides an average length of time,
                     expressed in months, between  compliance inspections  at a facility within the
                     defined universe.

                     Facilities with One or More Enforcement Actions ~  expresses the number
                     of facilities that were the subject of at least one enforcement action within the
                     defined time period.  This category is broken down further into federal and
                     state actions. Data are obtained for administrative, civil/judicial, and criminal
                     enforcement actions. Administrative actions include Notices of Violation
                     (NOVs). A facility with multiple enforcement actions is only counted once
                     in this column, e.g., a facility with 3 enforcement actions counts as 1 facility.
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                    Total Enforcement Actions ~ describes the total number of enforcement
                    actions identified for an industrial sector across all environmental statutes.  A
                    facility with multiple enforcement actions is counted multiple times, e.g., a
                    facility with 3 enforcement actions counts as 3.

                    State Lead Actions — shows what percentage of the total enforcement
                    actions are taken by state and local environmental agencies.  Varying levels
                    of use by  states of EPA data systems may limit  the volume of actions
                    recorded as state enforcement activity.   Some states extensively report
                    enforcement activities into EPA data systems, while other states may use their
                    own data systems.

                    Federal Lead Actions ~ shows what percentage of the total enforcement
                    actions are taken by the United States Environmental Protection Agency.
                    This value includes referrals from state agencies. Many of these actions result
                    from coordinated or joint state/federal efforts.

                    Enforcement to Inspection Rate — is a ratio of enforcement actions to
                    inspections, and is presented for comparative purposes only. This ratio is a
                    rough indicator of the relationship between inspections and enforcement. It
                    relates the number of enforcement actions and the number of inspections that
                    occurred  within the one-year or five-year period.  This ratio includes the
                    inspections and enforcement actions reported  under the Clean Water Act
                    (CWA), the Clean Air Act (CAA) and  the Resource Conservation and
                    Recovery  Act (RCRA).  Inspections and actions from the TSCA/FIFRA/
                    EPCRA database are not factored into this ratio because most of the actions
                    taken under these programs are not the result of facility inspections.  Also,
                    this ratio  does not account for enforcement  actions arising  from non-
                    inspection compliance  monitoring  activities  (e.g.,  self-reported  water
                    discharges) that can result in enforcement action within the CAA, CWA, and
                    RCRA.

                    Facilities with One or More Violations Identified  — indicates the
                    percentage of inspected facilities having a violation identified in one of the
                    following  data categories:  In Violation or Significant  Violation Status
                    (CAA); Reportable Noncompliance, Current Year Noncompliance, Significant
                    Noncompliance (CWA); Noncompliance and Significant Noncompliance
                    (FIFRA, TSCA, and EPCRA); Unresolved Violation and Unresolved High
                    Priority Violation (RCRA).  The values presented for this column reflect the
                    extent  of noncompliance within the  measured time frame, but do  not
                    distinguish between the severity of the noncompliance. Violation status may
                    be a precursor to an enforcement action, but does not necessarily indicate that
                    an enforcement action will occur.
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                      Media Breakdown of Enforcement  Actions and  Inspections -- four
                      columns identify the proportion of total inspections and enforcement actions
                      within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
                      column is a percentage of either the "Total Inspections," or the "Total
                      Actions" column.
 VILA.  Shipbuilding and Repair Industry Compliance History

                      Table 11 provides an overview of the reported compliance and enforcement
                      data for the shipbuilding and repair industry over the past five years (April
                      1992 to April 1997). These data are also broken out by EPA Region thereby
                      permitting geographical comparisons. A few points evident from the data are
                      listed below.

                      •      About half of shipbuilding and repair facility inspections and almost
                            70 percent of enforcement actions occurred in Regions IV and VI,
                            where most facilities in the database search (60 percent) were located'

                     •      In Region III,  a relatively large number of inspections (66) were
                            carried out in relation to the number of facilities (6) found in this
                            Region.  This is reflected in the relatively low average time between
                            inspections (5 months). However, the Region had the lowest rate of
                            enforcement actions to inspections (0.02).

                     •      Region X showed three facilities in the database search and only eight
                            inspections over the past five years, giving the Region the highest
                            average  time  between  inspections  (23  months).   However,
                            enforcement actions were brought against all three facilities in this
                            time period, resulting in the highest enforcement to inspection rate
                            (0.38).
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          Compliance and Enforcement History
 VII.B. Comparison of Enforcement and Compliance Activity Between Selected Industries

                     Tables 12 and 13 allow the compliance history of the shipbuilding and repair
                     sector to be compared to the other industries covered by the industry sector
                     notebook project.  Comparisons between Tables  12 and 13  permit the
                     identification of trends in compliance and enforcement records of the industry
                     by comparing data covering the last five years (April 1992 to April 1997) to
                     that of the past year (April 1996 to April 1997). Some points evident from
                     the data are listed below.

                     •     Of the sectors shown, the shipbuilding and repair industry had, by far,
                           the smallest number of facilities (44) in the database search. (The
                           facilities presented only include those facilities that report to TRI.)

                     •     The  shipbuilding  and repair industry had one of the  highest
                           enforcement to inspection  rates over the past five years (0.13).
                           However, this rate decreased significantly over the past year (0.08).

                     •     Compared to the other sectors shown, the industry was about average
                           in terms of the percent of facilities with violations (86 percent) and
                           enforcement actions (14 percent) in the past year, and in the average
                           time between inspections over the past five years (9 months).

                     Tables  14 and  15 provide  a more in-depth comparison  between the
                     shipbuilding  and  repair industry and other sectors by breaking out the
                     compliance and enforcement  data by environmental statute.   As in the
                     previous Tables (Tables 12 and 13),  the data cover the last five years (Table
                     14) and the last one year (Table 15) to facilitate the  identification of recent
                     trends. A few points evident from the data are listed below.

                     •      Inspections carried out under CAA and RCRA accounted for 81
                           percent and 89 percent of inspections  over the  past five years and one
                           year,  respectively. RCRA inspections made up only 14  percent of
                           inspections in the past five years, but accounted for 25  percent of
                           enforcement actions.

                     •      Over the past year, a larger percentage of inspections were carried out
                           under CAA (54 percent) compared to the past five years (39 percent).

                     •      Meaningful comparisons of enforcement actions taken under each
                           statute over the past year are not possible since only four enforcement
                           actions (two under RCRA and two under CWA) were taken in this
                           period.
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                               Compliance and Enforcement History

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         Compliance and Enforcement History
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VTI.C. Review of Major Legal Actions

       Major Cases/Supplemental Environmental Projects
                    This section provides summary information about major cases that have
                    affected this  sector,  and a list of Supplemental  Environmental Projects
                    (SEPs).

       VELC.l. Review of Major Cases

                    As indicated in EPA's Enforcement Accomplishments Report, FY1995 and
                    FY1996 publications, two significant enforcement actions were resolved
                    between 1995 and 1996 for the shipbuilding industry.

                    U.S. v. First Marine Shipyard Inc., etal (E.D.NY): On September 30, 1996
                    the U.S. filed a complaint for CERCLA cost recovery and penalties related
                    to Region II's cleanup of the barge Nathan Berman.  The complaint seeks
                    recovery of approximately $1,8 million from First Marine Shipyard, Marine
                    Facilities Inc., Marine Movements, Inc.,  and Peter Frank and Jane Frank
                    Kresch individually.  It also includes a second cause of action against First
                    Marine Shipyard for failure to comply with an administrative CERCLA §106
                    order issued to it in March of 1993.

                    Cascade General: Cascade General, a ship repair facility in Portland, Oregon,
                    agreed to a penalty of $78,568 for alleged EPCRA violations.  The company
                    agreed to pay $39,284 in cash and install air filtration dust collector and
                    solvent recovery systems and to switch to water-based paint to remediate the
                    balance of the penalty. The SEPs will cost about $117,000 to implement.  The
                    dust collector will improve air quality in the facility by reducing dust in work
                    areas. The solvent recovery system will reduce by 90% the amount of solvents
                    discharged to the air by recovering batch solvents for reuse in the facility.  For
                    TRI reporting years 1988-1993, total releases  were reported at 253,000
                    pounds.

       VTI.C.2. Supplementary Environmental Projects (SEPs)

                    Supplemental environmental projects (SEPs) are enforcement options that
                    require the non-compliant facility to complete specific projects. Information
                    on SEP cases can be accessed via the internet at EPA's Enviro$en$e website:
                    http://es.inel.gov/sep.
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 Shipbuilding and Repair
                        Activities and Initiatives
     . COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

                      This section highlights the activities undertaken by this industry sector and
                      public  agencies  to  voluntarily  improve  the   sector's  environmental
                      performance.  These activities include those independently initiated  by
                      industrial trade associations. In this section, the notebook also contains a
                      listing and description of national and regional trade associations.

 Vm.A. Sector-related Environmental Programs and Activities

        National Shipbuilding Research Program Panel SP-1

                      The  National  Shipbuilding  Research  Program  (NSRP)  is  a joint
                      industry/government program aimed at improving the global competitiveness
                      of American shipyards. NSRP's mission is to assist the shipbuilding and ship
                      repair industry in  achieving and maintaining global competitiveness with
                      respect to quality, time, cost, and customer satisfaction.  The program is also
                      expected to significantly reduce the costs and delivery times of ships ordered
                      by the U.S. Navy. NSRP's objectives are reached through individual projects
                      which form the content of the shipbuilding technology program.  Joint
                      Government and  industry  meetings  are held to identify  final project
                      descriptions.  NSRP utilizes  a panel structure to develop project proposals
                      and implement projects. The Panel SP-1 focuses on shipbuilding and repair
                     facilities and environmental effects.

                     The mission of Panel SP-1, Facilities and Environmental Effects, is to support
                     the NSRP by providing leadership and expertise to the shipbuilding and repair
                     industry, with respect to facilities and environmental issues. The following
                     goals have been established by SP-1:

                     •      increase participation of shipyards and other Maritime Associations
                            by 100 percent;

                     •      improve communication and visibility between NSRP Panels, with the
                            Executive Control Board, within NSRP participating shipyards and
                            beyond NSRP;

                     •      be proactive  in representing industry views regarding regulatory
                            matters;

                     •      identify, develop  and  implement cost-effective  technologies  in
                            facilities and environmental areas;

                     •       educate  and assist the shipbuilding  and repair industry and  its
                            customers in meeting environmental and regulatory requirements; and
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                                                               Activities and Initiatives
                    •      maintain and continue to improve SP-1 expertise.

                    Panel SP-1 has a number of active and proposed projects. The following is
                    a list of active projects:

                    •      Environmental Studies and Testing

                    •      Environmental Training Modules

                    •      Feasibility and Economic  Study of the  Treatment, Recycling &
                           Disposal of Spent Abrasives

                    •      Solid Waste Segregation & Recycling

                    •      Title V Permit for Shipyards Strategy Guide for Development of
                           Generated Permit

                    •      Wastewater Treatment Technology Survey

                    •      Impact on Shipyards from the Reauthorization of the Federal Clean
                           Water Act

                           Development  of Guidance  for Selecting Legitimate Recycling
                           Products and Processes

                           Developing a Shipyard Program for NPDES Compliance

                     More information  on Panel SP-1  activities can be obtained from the
                     Environmental Resources and Information Center (ERIC), a division of the
                     Gulf Coast Region Maritime Technology Center at the University of New
                     Orleans at (504) 286-6053.

        National Defense Center for Environmental Excellence

                     The National Defense Center for Environmental  Excellence (NDCEE) was
                     established by the Department of Defense to provide the military and private
                     sector industrial base clients with environmentally compliant technologies.
                     NDCEE conducts environmental technology research and disseminates
                     information on environmental technologies and regulations.  At the Army's
                     Armament Research, Development and Engineering Center at Picatinny
                     Arsenal, NJ, NDCEE has established an industrial-scale facility for the
                     demonstration of nonpolluting surface coatings. The NDCEE demonstration
                     facility is used to validate cost, schedules and performance parameters of new
                     coating technologies.  NDCEE also provides  assistance in the  form of
                     equipment, site engineers, economic analyses, training, and troubleshooting
                     for those clients implementing demonstrated coating technologies at their
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                     industrial facility. In its powder coating demonstration line, industrial parts
                     are cleaned, pretreated, sprayed with nonpolluting organic powders, then
                     cured in a process than nearly eliminates volatile organic compounds and
                     hazardous wastes. Contact: Dr. Dale A. Denny, Executive Director, NDCEE,
                     (814)269-2432.
       MARITECH
                    MARITECH is a five-year jointly funded by the Federal Government and
                    industry and is administered by the Department of Defense's Advanced
                    Research Projects  Agency  (ARPA),  in  collaboration  with MARAD.
                    MARITECH  provides  matching Government funds  to  encourage the
                    shipbuilding industry to direct and lead in the development and application of
                    advanced technology  to improve its competitiveness and to  preserve its
                    industrial base.  In the near-term MARITECH aims to assist industry in
                    penetrating  the international marketplace with competitive ship designs,
                    market strategies, and modern shipbuilding processes and procedures. In the
                    long-term, the program is meant to encourage advanced ship and shipbuilding
                    technology  projects  for  promoting continuous  product and  process
                    improvement in order to maintain and  enlarge the U.S. share of the
                    commercial  and international market.  MARITECH funded $30 million in
                    FY94, $40 million in FY95, $50 million in FY96, and $50 million in FY97 for
                    vessel design and shipyard technology projects.
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VIII.B. EPA Voluntary Programs
       33/50 Program
                     The "33/50 Program" is EPA's voluntary program to reduce toxic chemical
                     releases and transfers of seventeen chemicals from manufacturing facilities.
                     Participating companies pledge to reduce their toxic chemical releases and
                     transfers by 33% as of 1992 and by 50% as of 1995 from the  1988 baseline
                     year. Certificates of Appreciation have been given out to participants meeting
                     their 1992 goals. The list of chemicals includes seventeen high-use chemicals
                     reported in the Toxics Release Inventory. Table 16 lists those companies
                     participating in the 33/50 program that reported the four-digit SIC code 3731
                     to TRI.  Some of the  companies shown also listed facilities that are not
                     building or repairing ships.  The number of facilities within each company that
                     are participating in the 33/50 program and that report the shipbuilding and
                     repair SIC code is shown.  Where available and quantifiable against 1988
                     releases and transfers, each company's 33/50 goals for 1995 and the actual
                     total releases and transfers and percent reduction between 1988 and 1994 are
                     presented.  TRI 33/50 data for  1995  was  not available at the time  of
                     publication.

                     Twelve of the seventeen  target chemicals  were reported to TRI  by
                     shipbuilding and repair facilities in 1994. Of all TRI chemicals released and
                     transferred by the shipbuilding  and repair industry, xylenes (a 33/50 target
                     chemical), was released and transferred most frequently (32 facilities), and
                     was the top chemical by volume released and transferred. Toluene, the next
                     most frequently reported 33/50 chemical, was reported by six facilities. The
                     remaining 33/50 chemicals were each reported by four or fewer facilities.

                     Table 16 shows that 7 companies comprised of 15 facilities reporting SIC
                     3731 are participating in  the 33/50 program.  For those companies shown
                     with more than one shipyard, all shipyards may not be participating in 33/50.
                     The 33/50 goals shown for companies with multiple shipyards are company-
                     wide, potentially aggregating  more than one shipyard and facilities not
                     carrying out shipbuilding and repair operations. In addition to company-wide
                     goals, individual facilities within a company may have their own 33/50 goals
                     or may be specifically listed as not participating in the 33/50 program. Since
                     the actual percent reductions shown in the last column apply to all of  the
                     companies' shipbuilding and repair facilities and only shipbuilding and repair
                     facilities,  direct comparisons to  those company goals incorporating non-
                     shipbuilding and repair facilities  or excluding certain facilities may not be
                     possible. For information on specific facilities participating in 33/50,  contact
                     David Sarokin (202-260-6907) at the 33/50 Program Office.
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Table 16: Shipbuilding and Repair Industry Participation in the 33/50 Program
Parent Company
(Headquarters Location)
Avondale Industries Inc.
Avondale, LA
Bethlehem Steel Corp.
Bethlehem, PA
Fulcrum II Limited Partner.
(Bath Iron Works)
New York, NY
General Dynamics Corp.
Falls Church, VA
Tenneco Inc.
(Newport News)
Houston, TX
U.S. Air Force
Washington, DC
Unimar International Inc.
Seattle, WA
TOTAL
Company-
Owned
Shipyards
Reporting 33/50
Chemicals
3
2
4
2
1
1
1
15
Company-
Wide %
Reduction
Goal1
(1988 to 1995)
54
50
24
84
8
***
*
—
1988 TRI
Releases and
Transfers of
33/50 Chemicals
(pounds)
1,558,614
92,000
116,500
316,777
896,292
0
0
2,980,183
1994 TRI
Releases and
Transfers of
33/50 Chemicals
(pounds)
20,285
129,020
15,331
8,182
268,950
108,835
0
550,603
Actual °/o
Reduction for
Shipyards
(1988-1994)
99
-40
87
97
70
-
-
86
Source: U.S. EPA 33/50 Program Office, 1996.
1 Company- Wide Reduction Goals aggregate all company-owned facilities which may include
facilities not building and repairing ships.
* = Reduction goal not quantifiable against 1988 TRI data.
** = Use reduction goal only.
*** = No numeric reduction goal.
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Shipbuilding and Repair
                     Activities and Initiatives
       Environmental Leadership Program
       Project XL
                     The Environmental Leadership Program  (ELP) is a national initiative
                     developed by EPA that focuses on improving environmental performance,
                     encouraging voluntary compliance, and building working relationships with
                     stakeholders.  EPA initiated a one year pilot program in 1995 by selecting 12
                     projects at  industrial facilities and  federal  installations which would
                     demonstrate the principles of the ELP program. These principles include:
                     environmental management systems, multimedia compliance assurance, third-
                     party verification of compliance, public measures of accountability, pollution
                     prevention, community involvement,  and mentor programs. In return for
                     participating, pilot participants received public recognition and were given a
                     period of time to correct any violations  discovered during these experimental
                     projects.

                     EPA is making  plans to  launch its  full-scale  Environmental Leadership
                     Program in 1997. The full-scale program will be facility-based with a 6-year
                     participation cycle. Facilities that meet certain requirements will be eligible
                     to participate, such as having a community outreach/employee involvement
                     programs  and an environmental management system (EMS) in place for 2
                     years.   (Contact: http://es.inel.gov/elp or Debby Thomas, ELP Deputy
                     Director, at 202-564-5041)
                     Project XL was initiated in March  1995 as a part of President Clinton's
                     Reinventing Environmental Regulation  initiative.  The projects seek to
                     achieve cost effective environmental benefits by  providing  participants
                     regulatory flexibility on the condition that they produce greater environmental
                     benefits. EPA and program participants will negotiate and sign a Final Project
                     Agreement, detailing  specific environmental objectives  that the regulated
                     entity shall satisfy. EPA will  provide regulatory flexibility as an incentive for
                     the participants' superior environmental performance.  Participants are
                     encouraged to seek stakeholder support from local governments, businesses,
                     and environmental groups.  EPA hopes to implement fifty pilot projects in
                     four categories, including industrial facilities, communities, and government
                     facilities regulated by EPA.  Applications will be accepted on a rolling basis.
                     For additional  information regarding XL projects, including application
                     procedures and criteria,  see the May 23,  1995  Federal Register Notice.
                     (Contact:     Fax-on-Demand     Hotline     202-260-8590,     Web:
                     http://www.epa.gov/ProjectXL, or Christopher Knopes at EPA's Office of
                     Policy, Planning and Evaluation 202-260-9298)
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Shipbuilding and Repair
                      Activities and Initiatives
       Climate Wise Program
                     Climate Wise is helping US industries turn energy efficiency and pollution
                     prevention into a corporate asset.  Supported by the technical assistance,
                     financing information  and public recognition that Climate Wise  offers,
                     participating companies are  developing  and  launching  comprehensive
                     industrial energy efficiency and pollution prevention action plans that save
                     money and protect the environment. The nearly 300 Climate Wise companies
                     expect to save more than $300 million and reduce greenhouse gas emissions
                     by 18 million metric tons of carbon dioxide  equivalent by the year 2000.
                     Some of the actions companies  are undertaking to achieve these  results
                     include:  process improvements, boiler and steam system optimization, air
                     compressor system improvements, fuel switching, and waste heat recovery
                     measures including cogeneration. Created as part  of the President's Climate
                     Change Action Plan, Climate Wise is jointly operated by the Department of
                     Energy and EPA.  Under the Plan many other  programs were also launched
                     or upgraded including Green Lights, WasteWi$e and DoE's Motor Challenge
                     Program.  Climate Wise provides an umbrella for these programs which
                     encourage company participation by providing information on the range of
                     partnership opportunities available.  (Contact:  Pamela Herman, EPA, 202-
                     260-4407 or Jan Vernet, DoE, 202-586-4755)
       Energy Star Buildings Program
                    EPA's ENERGY STAR Buildings Program is a voluntary, profit-based program
                    designed to improve the energy-efficiency in commercial  and industrial
                    buildings. Expanding the successful Green Lights Program, ENERGY STAR
                    Buildings was launched in 1995. This program relies on a 5-stage strategy
                    designed to maximize energy savings thereby lowering energy bills, improving
                    occupant comfort,  and preventing pollution « all at the  same time.  If
                    implemented in every commercial and industrial building in the United States,
                    ENERGY STAR Buildings could cut the nation's energy bill by up to $25 billion
                    and prevent up to 35% of carbon dioxide emissions. (This is equivalent to
                    taking 60 million cars of the road). ENERGY STAR Buildings  participants
                    include corporations; small and medium sized businesses; local, federal and
                    state governments; non-profit groups; schools; universities; and health care
                    facilities. EPA provides  technical  and non-technical support  including
                    software, workshops, manuals, communication tools, and an  information
                    hotline.  EPA's Office of Air and Radiation manages the operation of the
                    ENERGY STAR Buildings Program. (Contact: Green Light/Energy Star Hotline
                    at 1-888-STAR-YES or Maria Tikoff Vargas, EPA Program Director at 202-
                    233-9178  or  visit  the ENERGY  STAR  Buildings  Program  website at
                    http ://www. epa.gov/appdstar/buildings/)
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Shipbuilding and Repair
Activities and Initiatives
       Green Lights Program
                    EPA's Green Lights program was initiated in 1991 and has the goal of
                    preventing pollution by encouraging U.S. institutions to use energy-efficient
                    lighting  technologies.   The  program  saves  money for businesses  and
                    organizations and creates a cleaner environment by reducing pollutants
                    released into the atmosphere. The program has over 2,345 participants which
                    include major corporations, small and medium sized businesses, federal, state
                    and local governments, non-profit groups, schools, universities, and health
                    care facilities.  Each participant is required to survey their facilities and
                    upgrade lighting wherever it is profitable.  As of March 1997, participants had
                    lowered their electric bills by $289 million annually.  EPA provides technical
                    assistance to the participants through a decision support software package,
                    workshops and manuals, and an information hotline. EPA's Office of Air and
                    Radiation is responsible for operating the Green Lights Program. (Contact:
                    Green Light/Energy Star Hotline at 1-888-STARYES or Maria Tikoff
                    Vargar, EPA Program Director, at 202-233-9178 the )
       WasteWiSe Program
                     The WasteWi$e Program was started in 1994 by EPA's Office of Solid Waste
                     and Emergency Response. The program is aimed at reducing municipal solid
                     wastes by  promoting waste prevention,  recycling collection  and the
                     manufacturing and purchase of recycled products. As of 1997, the program
                     had about 500 companies as members, one third of whom are Fortune 1000
                     corporations. Members agree to identify and implement actions to reduce
                     their solid wastes setting waste reduction goals and providing EPA with
                     yearly progress reports.   To member companies, EPA, in turn, provides
                     technical assistance, publications, networking opportunities, and national and
                     regional recognition.  (Contact: WasteWi$e Hotline at 1-800-372-9473 or
                     Joanne Oxley, EPA Program Manager, 703-308-0199)
       NICE3
                     The U.S. Department of Energy is administering a grant program called The
                     National  Industrial Competitiveness through Energy,  Environment, and
                     Economics (NICE3).  By providing grants of up to 45 percent of the total
                     project cost, the program encourages industry to reduce industrial waste at
                     its source and become more energy-efficient and cost-competitive through
                     waste minimization efforts. Grants are used by industry to design, test, and
                     demonstrate new processes and/or equipment with the potential to reduce
                     pollution  and increase energy efficiency.   The program is open to all
                     industries; however, priority is given to proposals from participants in the
                     forest products, chemicals, petroleum refining, steel, aluminum, metal casting
                     and glass  manufacturing sectors. (Contact: http//www. oit.doe.gov/access/
                     nice3, Chris Sifri, DOE, 303-275-4723 or Eric Hass, DOE, 303-275-4728.)

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 Shipbuilding and Repair
                        Activities and Initiatives
        Design for the Environment (DfE)
                      DfE is working with several industries to identify cost-effective pollution
                      prevention strategies that reduce risks to workers and the environment.  DfE
                      helps businesses compare and evaluate the performance, cost, pollution
                      prevention benefits, and human health and environmental risks associated with
                      existing and alternative technologies.  The goal of these projects is to
                      encourage businesses to consider and use cleaner products, processes, and
                      technologies. For more information about the DfE Program, call (202) 260-
                      1678.  To obtain copies of DfE materials or for general information about
                      DfE, contact EPA's Pollution Prevention Information Clearinghouse at (202)
                      260-1023 or visit the DfE Website at http://es.inel.gov/dfe.
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Shipbuilding and Repair
                                                               Activities and Initiatives
VIH.C. Trade Associations
             American Shipbuilding Association
             600 Pennsylvania Ave. Suite 305
             Washington, DC 20003
             Phone: (202)-544-8170
             Fax: (202)-544-9618
              Members: 6
              Contact: Frank Losey
              (202)-544-9614
              The American Shipbuilding  Association (ASA) is  a private, non-profit trade
              association comprising America's six largest private sector shipyards.  The shipyards
              are: Avondale Industries, Bath Iron Works, Electric Boat,  Ingalls Shipbuilding,
              National Steel & Shipbuilding Company, and Newport News Shipbuilding.  These six
              shipyards employ the large majority of shipbuilding employees in the U.S.  More than
              98 percent of the Navy's shipbuilding budget is spent on ships constructed in ASA
              shipyards. The goals of ASA are to preserve and promote the U.S. naval shipbuilding
              industrial base as well as to educate the  U.S.  public and government to the
              importance of shipbuilding to the country.   ASA publishes American Shipbuilder
              Newsletter monthly.
              National Shipyard Association                    Members: 44 companies
              1600 Wilson Blvd.                              Staff: 6
              Arlington, VA 22209
              Phone: (703) 351-6734
              Fax:(703)351-6736

              The National Shipyard Association (NSA) is a national trade association representing
              the commercial shipbuilding, repair, and cleaning  industry.  NSA represents 44
              shipyard companies that own and operate over 90 shipyards in 17 states along the
              Gulf, Pacific, and Atlantic coasts of the U.S. NSA also has among its membership 16
              companies that supply services and products to the shipbuilding and repair industry.
              NSA aims to promote high standards of health, safety, and environmental awareness
              throughout the industry. NSA publishes a monthly newsletter, NSA Newsline.
              Shipyard Association for                      Members: 67
              Environmental Responsibility                  Staff: 5
              Post Office Box 250                          Contact: Scott Theriot
              Lockport, LA 70374
              Phone: (504)-532-7272
              Fax: (202)-532-7295

              The Shipyard Association for Environmental Responsibility (SAFER) was formed by
              67 shipbuilding and repair facilities in the states of Alabama, Louisiana, Mississippi,
              and Texas. The goal of SAFER is to work cooperatively with the federal and state
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Shipbuilding and Repair
                       Activities and Initiatives
              agencies to ensure that environmental standards truly reflect the environmental
              concerns of the vastly different sizes and capabilities of the Gulf Coast shipyards.
              Shipbuilders Council of America
              901 No. Washington St. Suite 204
              Arlington, VA 22314
              Phone: (703) 548-7447
         Members: 10
         Staff: 10
         Contact: Penny Eastman
              The Shipbuilders Council of America (SCA) was founded in 1921 and is made up of
              companies engaged in the construction and repair of vessels and other marine craft;
              manufacturers of all types of propelling machinery, boilers, marine auxiliaries, marine
              equipment and supplies; and drydock operators.  SCA promotes and maintains sound
              private shipbuilding and ship repairing industries and adequate mobilization potential
              of shipbuilding and repairing facilities, organizations, and skilled personnel in times
              of national emergencies. A newsletter, Shipyard Chronicle, is published weekly.
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                     Activities and Initiatives
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Shipbuilding and Repair Industry
                      Contacts and References
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS
For further information on selected topics within the shipbuilding and repair industry a list of contacts
and publications are provided below.

Contacts5
Name
Anthony Raia
Mohamed Serageldin
Steve Guile
Bhaskar Kura
Organization
U.S. EPA - Office of Compliance
U.S. EPA - Office of Air Quality
Planning and Standards
U.S. EPA -Office of Water
University of New Orleans
Telephone
(202) 564-6045
(919)541-2379
(202)260-9817
(504) 280-6572
Subject
Multimedia Compliance
Regulatory Requirements
(Air)
MP&M water regulations
Multimedia pollutant
outputs and pollution
prevention
Section II; Introduction to the Shipbuilding and Repair Industry	

U.S. Department of Commerce, International Trade Administration, 1994 U.S. Industrial Outlook,
1995.

U.S. Department of Commerce, Bureau of the Census, 1992 Census of Manufacturers Industry
Series: Ship and Boat Building, Railroad and Miscellaneous Transportation Equipment, 1996.

U.S. Department of Transportation, Maritime Administration, Outlook for the U.S. Shipbuilding and
Repair Industry 1996, April 1996.

U.S. Department of Transportation, Maritime Administration, Report on Survey of U.S. Shipbuilding
and Repair Facilities 1995, December 1995.

ICAF  Publications,  Shipbuilding  Industry  Study  Report,   1996,  http://198.80.36.91/ndu/icaf
/isshp.html, March 1997.

OECD, Overview of the Agreement Respecting Normal Competitive Conditions in the Commercial
Shipbuilding and Repair Industry, http://www.oecd.org/dsti/sid/wp7.html, March 1997.

National Shipbuilding Research Program, Panel SP-4), US Shipbuilding International Market Study
1996-2005, June 1995. SPFA:0001.
5  Many of the contacts listed above have provided valuable information and comments during the development of this
document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily endorse all
statements made within this notebook.
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Shipbuilding and Repair Industry
                     Contacts and References
Section HI: Industrial Process Description
Kura, Bhaskur (University of New Orleans) and Lacoste, Steve (Avondale Industries, Avondale, LA),
Typical Waste Streams in a Shipbuilding Facility., 1996.

Storch, R.L., Hammon, C.P., Bunch, H.M., & Moore, R.C., Ship Production, 2nd ed., The Society
of Naval Architects and Marine Engineers, Jersey City, New Jersey, 1995.

Thornton, James R., Ship and Boat Building and Repair, ILO Encyclopaedia of Occupational
Health and Safety 4th ed., International Labour Office, Geneva, Switzerland, 1996.

Development Document for the Proposed Effluent Limitations Guidelines and Standards for the
Metal Products and Machinery Phase 1 Point Source Category, 1995, U.S. EPA, Office of Water,
(EPA-821-R-95-021).

Water Environment Federation, Pretreatment of Industrial Wastes, Manual of Practice No.  FD-3,
Alexandria, Virginia, 1994.

National Shipbuilding Research Program, Hazardous Waste Minimization Guide for Shipyards, U.S.
Navy and National Steel and Shipbuilding Company (NASSCO), January 1994.

National Shipbuilding Research Program, Introduction to Production Processes and Facilities in the
Steel Shipbuilding and Repair Industry,  U.S. Navy and National Steel and Shipbuilding Company
(NASSCO), February 1993.

Levy, Doug, Boat Paint Tied to Dolphin Deaths, USA Today, December 31, 1996.

Section IV; Chemical Release and Transfer Profile	

1994 Toxics Release Inventory Public Data Release, U.S. EPA Office of Pollution Prevention and
Toxics, June 1996. (EPA 745-R-96-002)

Section V: Pollution Prevention Opportunities	

National Shipbuilding Research Program, Hazardous Waste Minimization Guide for Shipyards, U. S.
Navy and National Steel and Shipbuilding Company (NASSCO), January 1994.

Guides to Pollution Prevention, The Marine Maintenance and Repair Industry, U.S. EPA, Office
of Research and Development, Cincinnati, OH, October 1991. (EPA/625/7-91/015)

Development Document for the Proposed Effluent Limitations Guidelines and Standards for the
Metal Products and Machinery Phase 1 foint Source Category, 1995, U.S. EPA, Office of Water,
(EPA-821-R-95-021).
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Shipbuilding and Repair Industry
                     Contacts and References
Natan, Thomas E., Jr., Examples of Successful Pollution Prevention Programs, from Industrial
Pollution Prevention Handbook, ed. Freeman, Harry M., McGraw-Hill, Inc., New York, 1995. pp.
142-144.

Identification of Pollution for Possible Inclusion in Enforcement Agreements Using Supplemental
Environmental Projects (SEPs) and Injunctive Relief, Final Report, March 1997. U.S. EPA, Office
of Enforcement and Compliance Assurance, (EPA-300-R-97-001).

Section VI: Summary of Applicable Federal Statutes and Regulations	

Personal Correspondence -with Mohamed Serageldin, U.S. EPA, Office of Air Quality Planning and
Standards, Research Triangle Park, North Carolina, March 1997.

Personal Correspondence with Steve Guile, U.S. EPA, Office of Water, Engineering and Analysis
Division, Washington, DC, April 1997.

Section VIII: Compliance Activities and Initiatives	

National Shipbuilding Research Program, SNAME Panel SP-1 Newsletter, Volume 1, Number 1,
Summer 1996.
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                               APPENDIX A
      INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK

         Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance  Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.

ACCESS THROUGH THE ENVIROSENSE WORLD WIDE WEB

      To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide
      Web Browser to the folio whig address:
      http://es.epa.gov/comply/sector/index.html
      or use


      WWW.epa.gOV/OeCa -   then select the button labeled Industry and Gov't
                                    Sectors and select the appropriate sector from the
                                    menu. The Notebook will be listed.

      Direct technical questions to the Feedback function at the bottom of the web page or to
      Shhonn Taylor at (202) 564-2502
                                  Appendix A

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