EPA 810/6-81-018 United States Environmental Protection Agency Region 10 1200 Sixth Avenue Seattle W A 98101 Alaska Idaho Oregon Washington Hazardous Waste Division Federal Activities Program May 1881 Waste Minimization Implementation Plan U.S. Coast Guard Base Ketch ikan, Alaska Print*} on fl*cyc Ptpor ------- WASTE MINIMIZATION IMPLEMENTATION PLAN U.S. COAST GUARD BASE KETCHIKAN, ALASKA Prepared for: U.S. Environmental Protection Agency Region 10 Federal Activities Program 1200 Sixth Avenue Seattle, Washington 98101 Submitted by: Science Applications International Corporation 626 Columbia Street N.W., Suite 1-C Olympia, Washington 98501 EPA Contract No. 68-C8-0061, Work Assignment No. 2-25 SAIC Project No. 1-832-03-211-00 May 1991 ------- EXECUTIVE SUMMARY Based on results of a waste minimization opportunity assessment performed during late 1990, an implementation plan for selected waste minimization alternatives was developed for U.S. Coast Guard Base Ketchikan, Alaska. Funding for this waste minimization project was provided by the Environmental Protection Agency, and assistance was provided by the Alaska Department of Environmental Conservation Pollution Prevention Program. The report entitled Waste Minimization Opportunity Assessment, U.S. Coast Guard Base, Ketchikan, Alaska, documents a complete waste management profile for the Base and evaluates options for reducing the quantity and toxicity of wastes generated and enhanced waste management methods. The potential benefits of implementing the waste minimization alternatives recommended in the Assessment include savings of an estimated $112,000 per year in avoided disposal costs and reduced procurement expenditures, reduced liability for hazardous wastes, enhanced worker health and safety, and reduced threats to the environment. The purpose of the Implementation Plan is to outline a sequence of activities for Base Ketchikan to achieve these benefits. This Plan addresses activities at three Coast Guard levels: Base Ketchikan, Civil Engineering Unit (CEU) Juneau, and Coast Guard Headquarters. It is designed to be separated into functional sections, usable by the individuals tasked with specific waste handling responsibilities. The document is intended to serve as a flexible guideline for a comprehensive waste minimization program. Target dates are suggested for Base Ketchikan milestones based on functional priorities and a logical sequence of activities. As circumstances change, some target dates may need to be modified. The Plan addresses the following activities at Base Ketchikan: • Steps necessary to establish a Base-wide waste minimization program; • Testing blasting waste from the marine ways for hazardous waste designation; • Several new equipment options to reduce waste generation in the Industrial Division; • Recycling of thinning and degreasing materials, used oil, batteries, and antifreeze; ------- • Several directives for waste reduction in the galley, base exchange, and administration building; • Best management practices in handling toxic materials; and • Tracking progress in waste reduction for each of the targeted waste streams. For CELT Juneau, the Plan addresses regional contracts for recycling oil, batteries, and antifreeze. In addition, pilot projects on 180-foot and 110-foot vessels and a LORAN station are outlined to reduce the generation of waste oil, separate bilge waste, and recycle used oil. Suggested options to be implemented at the Coast Guard Headquarters level include coating-free buoy materials, improvements to vessel design to provide for bilge separation and oil recycling, new paint formulations, and improvements to the federal procurement system. 11 ------- TABLE OF CONTENTS Page EXECUTIVE SUMMARY i 1.0 INTRODUCTION 1 1.1 PURPOSE OF THE KETCHIKAN WASTE MINIMIZATION PROJECT 1 1.2 WASTE MINIMIZATION OPPORTUNITY ASSESSMENT 1 1.3 IMPLEMENTATION PLAN 2 2.0 WASTE MINIMIZATION IMPLEMENTATION PLAN: BASE KETCHIKAN 3 2.1 BASE-WIDE PROGRAM ESTABLISHMENT 3 2.2 INDUSTRIAL AND PUBLIC WORKS 5 2.2.1 Blasting Waste - Buov Shed 5 2.2.2 Blasting Waste - Marine Wavs 5 2.2.3 Painting 6 2.2.4 Solvents 6 2.2.5 Used Oil 7 2.2.6 Antifreeze 8 2.2.7 Batteries 8 2.3 GALLEY 9 2.4 BASE EXCHANGE 9 2.5 ADMINISTRATION AND OTHER BUILDINGS 9 3.0 CEU JUNEAU 10 3.1 USED OIL 10 3.2 ANTIFREEZE 10 3.3 BATTERIES 11 3.4 PILOT PROJECTS ON COAST GUARD VESSELS AND LORAN STATIONS .... 11 3.4.1 180-Foot Ship - Pilot Project 12 3.4.2 110-Foot Cutter - Pilot Project 14 3.4.3 Loran Stations - Pilot Project 16 4.0 COAST GUARD HEADQUARTERS 17 4.1 BUOYS - PAINTING AND PAINT REMOVAL 17 4.2 BILGE 17 4.3 OIL 18 4.4 PAINTS 18 4.5 PROCUREMENT . 18 APPENDICES APPENDIX A SUMMARY OF WASTE MINIMIZATION OPTIONS IDENTIFIED IN THE WASTE MINIMIZATION OPPORTUNITY ASSESSMENT FOR BASE KITCHIKAN APPENDIX B BEST MANAGEMENT PRACTICES FOR VEHICLE/VESSEL MAINTENANCE AND MACHINE SHOPS APPENDIX C BEST MANAGEMENT PRACTICES FOR OFFICES iii ------- 1.0 INTRODUCTION 1.1 PURPOSE OF THE KETCHIKAN WASTE MINIMIZATION PROJECT The Environmental Protection Agency (EPA) Region 10 has made a regional priority of actively pursuing pollution prevention activities at federal facilities. In response to outreach activities by EPA Region 10 and the Alaska Department of Environmental Conservation Pollution Prevention Program, the U.S. Coast Guard requested technical assistance in exploring alternatives for the reduction of solid and hazardous waste at the Coast Guard Base in Ketchikan, Alaska. The purpose of this project is three-fold: 1) To identify alternatives and evaluate their feasibility to reduce the generation of waste at its source, reduce waste toxicity and volume, reuse waste products, recycle discarded materials, and improve solid and hazardous waste management at Base Ketchikan. 2) To promote implementation of selected waste minimization alternatives through the development of a unit- or command-specific implementation plan. 3) To use the experience gained in the Base Ketchikan waste minimization project to transfer technology to other Coast Guard facilities in Alaska and potentially to other federal facilities. 1.2 WASTE MINIMIZATION OPPORTUNITY ASSESSMENT The first phase of this project entailed a thorough review of waste handling procedures at Base Ketchikan, analysis of waste generating processes and of waste types and quantities produced, identification of potential barriers to waste minimization, and the development of several waste minimization alternatives for each of the most significant waste generating processes or waste streams. The feasibility of each of these alternatives was evaluated based on its applicability to Base Ketchikan processes or procedures, its technical viability and demonstrated success, and its economic characteristics. For several of the options, capital costs, savings in disposal and/or purchase expenditures, and payback periods were calculated. The results of this study were documented in the report, Waste Minimization Opportunity Assessment, U.S. Coast Guard Base, Ketchikan, Alaska. Several significant opportunities for waste minimization and enhanced waste management were identified, reducing both the quantity and toxicity of wastes generated, and reducing the costs of hazardous waste disposal. A summary of the alternatives considered in the Opportunity Assessment and their respective costs and payback is provided in Appendix A. 1 ------- From the assessment report, Coast Guard personnel at Base Ketchikan and CEU Juneau selected options for implementation. The "how to" of implementing the chosen options is the subject of the Implementation Plan. 1.3 IMPLEMENTATION PLAN The second phase of this project is the development of an implementation plan for Base Ketchikan, providing an outline of actions to employ the waste minimization options selected by the Coast Guard from the Opportunity Assessment. During the assessment and alternatives selection stages, it became apparent that some pollution prevention alternatives could be initiated at Base Ketchikan, other options required instigation by the Civil Engineering Unit (CEU) in Juneau, and others could only be effectively addressed by Coast Guard Headquarters. This Implementation Plan is organized into three parts to reflect these Coast Guard responsibilities. The first portion of the Implementation Plan outlines the strategy for Base Ketchikan itself. The second section addresses waste minimization and recycling options which can be implemented by CEU Juneau on a District-wide or Alaska-wide scale. The third part discusses pollution prevention options which require Coast Guard Headquarters' authority for implementation. In the first two sections regarding Base Ketchikan and CEU Juneau, the overall goal of the effort is stated. This is followed by a list of discrete tasks, the position responsible for the activity, and a projected date for completion based on a beginning date of June 1991. In the third section, which addresses Coast Guard Headquarters alternatives, suggestions for waste minimization by source reduction measures are discussed. This plan is intended to provide a framework for a Base-wide waste minimization program. As such, it should be viewed as a flexible document. Milestone dates are offered as suggestions only, indicating an appropriate priority and sequence for the tasks described. Once the Base has an employee dedicated to the waste minimization program, we suggest that the milestone dates and specific tasks be evaluated and revised as needed to adapt to the current circumstances at the Base and at CEU Juneau. ------- 2.0 WASTE MINIMIZATION IMPLEMENTATION PLAN: BASE KETCHIKAN GOAL: TO ESTABLISH A VIABLE, ONGOING WASTE MINIMIZATION PROGRAM AT BASE KETCHIKAN WITHIN TWO YEARS. Because ongoing activities at Base Ketchikan continue to generate waste, and because both technology and regulations are changing rapidly, waste minimization must be a continuous effort. New ideas must be incorporated as the technology, techniques, processes, disposal costs, base mission, and regulatory climate evolve. Though much can be accomplished in a one-time project, ultimate success in reducing the generation, volume, and toxicity of wastes will be achieved through an ongoing program operating at the base. In its initial phases, the base program may rely heavily on outside sources. However, in time, Base Ketchikan will be able to assume full responsibility for initiating additional measures to continue reducing waste generation.. 2.1 BASE-WIDE PROGRAM ESTABLISHMENT Following is a list of steps suggested to facilitate achievement of the goal stated above. • Issue a base-wide pollution prevention policy statement which includes clear goals for waste reduction. (Base Commander, July 1991) • Acquire and train one civilian full time equivalent to become the Hazardous Waste Manager to take on all hazardous waste management responsibilities and to spearhead the waste minimization program. This employee should be dedicated to these efforts and not given any collateral duties. (Executive Officer, January 1992) • Establish a Pollution Prevention Team, comprised of the hazardous waste manager, the head of Public Works, head of Industrial, the comptroller, the executive officer, and any other key personnel. (Executive Officer, January 1992) • Host a pollution prevention kickoff meeting for the Pollution Prevention Team, when representatives of EPA and Alaska DEC or their contractors can lay out the program for the base, provide a clear description of the program's goals, objectives, schedule, and costs, supply information on specific pollution prevention initiatives and experience at other facilities, and build enthusiasm and confidence in the merits of the effort. (Hazardous Waste Manager, January 1992) ------- • Appoint one person in each shop or administrative unit (e.g., office building) to be responsible for waste handling in that shop. These Shop Waste Coordinators are responsible for appropriate color coding of drums, labeling, transfer records, maintenance of waste handling equipment (e.g., distillation unit, waste oil burner), and ensuring that waste operations are being done in conformance to the guidance provided by the Hazardous Waste Manager. (Pollution Prevention Team, February 1992) • Institute an award program to recognize employees for outstanding efforts toward achievement of the pollution prevention goals. (Pollution Prevention Team, February 1992) • Establish a means of monitoring base-wide and process-specific progress in waste minimization, including tracking of purchase costs in areas where waste minimization effort is expected to impact purchase of new materials, tracking of wastes disposed and disposal costs, and observing changes among Coast Guard personnel in waste handling practices and attitudes. Periodic assessments by an independent audit team may be helpful to provide objective measurement of waste minimization progress and additional ideas for implementation. (Hazardous Waste Manager, March 1992) ------- 2.2 INDUSTRIAL AND PUBLIC WORKS GOAL: TO REDUCE BY 50% THE QUANTITY OF HAZARDOUS WASTE GENERATED AND DISPOSED OF WITHIN SIX YEARS. Listed bullet-style in the following subsections are discrete steps which can be taken in specific functional areas to help accomplish the waste minimization goal. These activities fall under the general umbrella of responsibility of the Hazardous Waste Manager; however, each task may be more appropriately accomplished under the authority of the shop foreman, equipment operator, or other personnel. One potential key to the acceptance of best management practices and changes in procedures is to emphasize the health and safety benefits to the shop employees. The responsibility for this education process is primarily that of the Hazardous Waste Manager. 2.2.1 Blasting Waste - Buov Shed • Place screen over holes where blasting media currently escapes blasting room, to retain steel shot within blasting room so that it can be reused. (Shop Foreman, August 1991) • Test fines for hazardous waste designation. (Hazardous Waste Manager, September 1991) • Track quantity of paint chips and fines generated. (Buoy Blaster, begin now, document quantities monthly) • Track quantity of makeup material added to media hopper. (Buoy Blaster, begin now, document quantity quarterly) • Track time used to blast individual buoys, to assist in developing a record of waste per unit of production. (Buoy Blaster, begin now, document daily) 2.2.2 Blasting Waste - Marine Wavs • Test waste on a quarterly basis for hazardous waste designation. (Hazardous Waste Manager, every 90 days) • If grit tests out as non-hazardous waste, haul to city landfill for daily cover (with prior approval from City of Ketchikan). (Hazardous Waste Manager) ------- 2.2.3 Painting • Purchase and install high volume/low pressure paint spray guns. (Industrial Head, initiate purchase process by November 1991) • Purchase and install spray gun cleaning station. (Industrial Head, initiate purchase process by November 1991) • Purchase and install paint/solvent distillation unit. (Industrial Head, initiate purchase process by December 1991) • Provide training to painters on operation of new equipment. (Industrial Head, when new equipment installed) • Reuse recycled solvent/thinner as cleanup solvent. (Head Painter, when distillation unit is installed) • Track paint and thinner purchases and disposal quantities. (Head Painter and Shop Waste Coordinator, document monthly and begin now) • Track paint application time and quantities to assist in developing a record of per unit usage. (Head painter, begin now) • Improve procurement and storage practices to avoid exceeding shelf life of product and product damage during storage. (Head Painter and Comptroller, begin now) 2.2.4 Solvents • Provide a kickoff training session to introduce concept of best management practices and new procedure for recycling solvents. (Industrial Head and Hazardous Waste Manager, when distillation unit installed in Paint Shop) • Install posters or signs in every shop to encourage appropriate solvent use and handling and waste segregation (Hazardous Waste Manager, March 1992) ------- • Implement best management practices (Appendix B) where possible (Shop Heads, March 1992) • Eliminate use of chlorinated solvents wherever possible (i.e. all shops except electronics, telecommunications) and substitute non-chlorinated solvents or other less toxic cleaners. (Hazardous Waste Manager, May 1992) • Recycle solvents in distillation unit purchased by Paint Shop (Shop Heads, when distillation unit installed) • Used distilled solvents from painting and solvent wastes for degreasing. (Industrial Head, when distillation unit installed) • Track solvent purchases by shop. (Shop Heads, document on monthly basis and begin now) 2.2.5 Used Oil • Provide a kickoff training session to introduce or reinforce concepts of waste segregation. (Hazardous Waste Manager, January 1992) • Employ best management practices (Appendix B) to ensure segregation of used oil from other wastes. (Shop Heads, January 1992) • Bulk oil on-site for energy recovery and reuse in 400 to 2000 gallon tank. (Shop Waste Coordinators, when bulk tank installed) • Test batches of bulk oil for burn specs. (Hazardous Waste Manager, every 90 days) • Burn acceptable oil ONLY in used oil heater when needed for heat. (Vehicle Maintenance Shop Head and Public Works Head, on-going) • Ship excess oil off-site for reblending (CEU Juneau contract). (Hazardous Waste Manager, when contract in place) ------- 2.2.6 Antifreeze • Provide a kickoff training session to introduce new procedures for used antifreeze and coolant mixtures and to reinforce best management practices. (Hazardous Waste Manager and CEU Juneau, when contract in place) • Employ best management practices (Appendix B) to ensure that used antifreeze is not contaminated with other wastes. (Shop Heads, December 1991) • Depending on contract with recycler, containerize or bulk used antifreeze on-site for recycling. (Shop Waste Coordinators, when contract in place) 2.2.7 Batteries • Package for shipment as hazardous waste; store on-site until load ready to ship to recycler. (Hazardous Waste Manager, when contract in place) • Time shipments to be most economic and prevent exceeding storage space. (Hazardous Waste Manager, when contract in place) ------- 2.3 GALLEY • Continue use of paper cups instead of s tyro foam. (Head Cook, on-going) • Use paper carry-out containers. (Head Cook, August 1991) • Flatten and deliver cardboard boxes to local recycler. (Head Cook, begin now) 2.4 BASE EXCHANGE • Flatten and deliver cardboard boxes to local recycler. (Exchange Supervisor, begin now) • Collect paper and deliver to local recycler. (Exchange Supervisor, begin now) 2.5 ADMINISTRATION AND OTHER BUILDINGS • Provide kickoff training session to introduce new procedures for reducing paper consumption, recycling, and best management practices. (Executive Officer and Hazardous Waste Manager, February 1992) • Implement office best management practices (Appendix C). (Executive Officer, February 1992) • Collect white paper and mixed paper for local recycler. (Executive Officer, begin now) • Collect and recycle aluminum cans (Hazardous Waste Manager, on-going) • Recycle laser jet cartridges (Hazardous Waste Manager, February 1992) • Procure recycled paper through federal procurement system. (Comptroller, September 1991) • Remain apprised of affirmative procurement guidelines published by EPA. (Comptroller, begin now) ------- 3.0 CEUJUNEAU GOAL: TO ESTABLISH REGIONAL CONTRACTS FOR THE RECYCLING OF VARIOUS WASTE PRODUCTS FROM COAST GUARD UNITS IN ALASKA WITHIN ONE YEAR, THEREBY AVOIDING DISPOSAL OF HAZARDOUS WASTES, AND TO PROVIDE ASSISTANCE TO BASE KETCHIKAN'S WASTE MINIMIZATION PROGRAM. In the following list of activities, the responsible organization is CEU Juneau unless otherwise noted. 3.1 USED OIL • Establish contract for recycling (blending for energy recovery). (January 1992) • Provide bulk containers (400-2000 gallons) at all collection points. (January 1992) • Ensure all batches/loads are sampled per contractor specifications before pickup/delivery. (CEU Juneau and Hazardous Waste Manager, after contract established, every 90 days) • Provide training to all units on new procedures. (January 1992) 3.2 ANTIFREEZE • Conduct pilot test with antifreeze purification company in Anchorage (May 1991) - Test with all types of antifreeze and coolants used in CG units - Compare purified product with mil specs or equivalent • If pilot test successful, establish contract for antifreeze recycling (September 1991) • Establish collection points and bulk transport to Anchorage OR mobile service contract (September 1991) • Provide training to all units on new procedures (October 1991) 10 ------- 3.3 BATTERIES • Establish contract(s) for battery recycling/reclamation (September 1991) • Establish collection points and procedures for units that generate spent batteries (September 1991) • Inform units of new procedures (September 1991) • Track quantities of batteries recycled and costs (begin September 1991) 3.4 PILOT PROJECTS ON COAST GUARD VESSELS AND LORAN STATIONS CEU Juneau may be able to arrange onboard waste minimization programs as a pilot study on one or two Coast Guard vessels and at LORAN stations. Following are suggested procedures for accomplishing waste minimization on a large Coast Guard ship, a mid-size cutter, and a LORAN station. 11 ------- 3.4.1 180-Foot Shin - Pilot Project GOAL: TO DEMONSTRATE EFFECTIVE WASTE MINIMIZATION TECHNIQUES ON A LARGE COAST GUARD VESSEL. 1. ESTABLISH PILOT PROJECT • Appoint one person onboard to be in charge of all solid and hazardous waste handling operations and the onboard waste minimization program. (Commanding Officer) • Hold a kickoff session involving all ship personnel to initiate new procedures, explain the reasons behind the changes, and convey an understanding of the benefits in health and safety, reduced disposal costs, and environmental improvements to be attained through the new methods. (Commanding Officer and District Engineering Officer) 2. NON-HAZARDOUS SOLID WASTE • Provide two receptacles onboard for trash: one for aluminum cans and one for other trash. (Waste Coordinator) • Transfer aluminum cans to Base Ketchikan can collection containers for recycling. (Waste Coordinator) 3. SOLVENTS • Eliminate use of all chlorinated solvents on board. (Waste Coordinator and CEU Juneau) • Substitute non-emulsifying degreasers. (Waste Coordinator and CEU Juneau) 4. POSSIBLE EXTENSION OF OIL LIFE BETWEEN CHANGES • Use Lubrisensor or equivalent device to track oil characteristics. (Engineering Officer and Waste Coordinator) 12 ------- • Continue routine lab tests and compare to Lubrisensor data. (Engineering Officer and Waste Coordinator) • Evaluate utility of Lubrisensor as substitute for lab tests. (Waste Coordinator and Engineering Officer) • Evaluate this technique for extending life of oil between changes. (Waste Coordinator, Engineering Officer, and CEU Juneau) 5. BILGE IMPROVEMENT • Pay extra attention to valves, fittings, and any places where oil, antifreeze, or fuel may leak into bilge. (Engineering Officer) • Avoid getting antifreeze in bilge. (All hands) • Keep all foreign material out of bilge. (All hands) 6. USE BILGE OIL (AFTER SEPARATION) FOR ENERGY RECOVERY OR REBLENDING • Ensure that bilge oil is acceptable. (Waste Coordinator) • Bulk bilge oil at Base Ketchikan and test for burn specs. (Base Ketchikan Hazardous Waste Manager) • If oil OK, Base Ketchikan to burn for energy recovery or ship off-site for reblending. (Base Ketchikan Hazardous Waste Manager) 13 ------- 3.4.2 110-Foot Cutter - Pilot Project GOAL: TO DEMONSTRATE EFFECTIVE WASTE MINIMIZATION TECHNIQUES ON A MID-SIZE COAST GUARD VESSEL. 1. ESTABLISH PILOT PROJECT • Appoint one person onboard to be in charge of all solid and hazardous waste handling operations and the onboard waste minimization program. (Commanding Officer) • Hold a kickoff session involving all ship personnel to initiate new procedures, explain the reasons behind the changes, and convey an understanding of the benefits in health and safety, reduced disposal costs, and environmental improvements to be attained through the new methods. (Commanding Officer and District Engineering Officer) 2. NON-HAZARDOUS SOLID WASTE • Provide two receptacles for trash: one for aluminum cans and one for other trash. (Waste Coordinator) • Transfer aluminum cans to Base Ketchikan can collection containers for recycling. (Waste Coordinator) 3. SOLVENTS • Eliminate use of all chlorinated solvents on board. (Waste Coordinator and CEU Juneau) • Substitute non-emulsifying degreasers. (Waste Coordinator and CEU Juneau) 4. POSSIBLE EXTENSION OF OIL LIFE BETWEEN CHANGES • Use Lubrisensor or equivalent device to track oil characteristics on daily basis. (Engineering Officer and Waste Coordinator) 14 ------- • Compare results to periodic lab tests and determine optimum time for oil change. (Engineering Officer and Waste Coordinator) • Evaluate utility of Lubrisensor to extend periods between oil changes, considering cost savings. (Engineering Officer and Waste Coordinator) 5. BILGE IMPROVEMENT • Pay extra attention to valves, fittings, and any places where oil, antifreeze, or fuel may leak into bilge. (Engineering Officer) • Avoid getting antifreeze in bilge. (All hands) • Keep all foreign material out of bilge. (All hands) • At Ketchikan, pump bilge into oil/water separator (mobile unit); containerize oil and put water into sewer if oil content acceptable. (Waste Coordinator) 6. USE BILGE OIL (AFTER SEPARATION) FOR ENERGY RECOVERY OR REBLENDING • Ensure that bilge oil is acceptable. (Waste Coordinator and Base Ketchikan Hazardous Waste Manager) • Bulk bilge oil at Base Ketchikan and test for burn specs. (Base Ketchikan Hazardous Waste Manager) • If oil OK, Base Ketchikan to burn for energy recovery or ship off-site for reblending. (Base Ketchikan Hazardous Waste Manager) 15 ------- 3.4.3 Loran Stations - Pilot Project GOAL: TO DEMONSTRATE A METHOD OF MINIMIZING WASTE OIL PRODUCTION AT LORAN STATIONS • In the re-engineering of LORAN stations, provide for ultrafiltration by-pass units on the generators. These by-pass filtration units can extend the life of the generator through their greater filtration efficiency and will extend the life of the oil used, thereby reducing the amount of waste oil generated. (CEU Juneau) 16 ------- 4.0 COAST GUARD HEADQUARTERS GOAL: TO EFFECT WASTE MINIMIZATION ON A COAST GUARD-WIDE SCALE THROUGH CHANGES IN EQUIPMENT DESIGN, MATERIALS AND PROCEDURES SPECIFICATIONS, AND OTHER METHODS, IN ORDER TO REDUCE ENVIRONMENTAL IMPACTS, IMPROVE WORKER HEALTH AND SAFETY, AND REDUCE DISPOSAL COSTS. 4.1 BUOYS - PAINTING AND PAINT REMOVAL Investigate buoy materials, design, and construction that would eliminate the need for painting and repainting the buoys, such as molded, pre-colored high density polyethylene, or another polymeric material which is designed specifically to withstand the rigors of the marine environment. Consider use of recycled raw material and the recyclability of the material when the buoys are retired from use. Environmental impacts throughout the life cycle of the buoys should be considered in the design phase, including manufacture of the buoys, maintenance during use, and ultimate destiny when retired from service. Should such a new design be developed, the existing buoys could be gradually replaced by the new environmentally superior model, thereby reducing the amount of painting and paint removal needed and eventually phasing out the painting and depainting processes. In this way, the waste streams resulting from buoy blasting and painting could be eliminated. 4.2 BILGE During the design of a new class of cutters, consideration should be given to methods to reduce and/or manage bilge waste. Current engine designs in some classes of vessels prevent draining of engine oil into anything but the bilge. With a redesign which considers the eventual handling of an expensive or potentially valuable waste stream, such as used engine oil, adequate space and a means for draining the waste and preventing its contamination could be accommodated. In addition, separation of bilge waste and recycling is very difficult if emulsifying degreasers are used on board or if chlorinated solvents are mixed into the bilge. Through design which prevents or minimizes the collection of rinse water, floor cleaning solutions, and waste streams from other parts of the vessel beside the engine room, and use of non-emulsifying degreasers, the bilge could be a separable and recyclable waste stream. 17 ------- 4.3 OIL Because of the high cost of disposing of used oil as hazardous waste, it would be worthwhile to investigate the use of synthetic oils, oil additives, and by-pass filtration (ultrafiltration) for oils used in vessel engines, generators, and shore vehicles. 4.4 PAINTS According to the Governor's Island report, lead-free paint is now being used throughout the Coast Guard and other reduced toxicity paint systems are being developed. This development is very important to effective pollution prevention for both buoys and vessels unless buoy and hull materials which do not require coatings can be developed. As with other source reduction approaches, consideration should be given to the entire life cycle of the paint system developed, including manufacture of the paints/coatings, application, removal, and disposal. Reduction in toxicity of the materials used is a valid waste minimization technique. Development of coating systems which last longer before requiring removal and recoating would also help minimize waste production. 4.5 PROCUREMENT Currently, one of the barriers to waste minimization is the federal procurement system. Lack of control over quantity, when the minimum orderable amount is far more than what is actually needed, or over quality, when an inferior product wears out quickly and must be disposed of, tends to create waste. Experience in the industrial arena has shown that some of the most effective waste minimization programs involve the marriage of procurement and disposal functions at a facility. One person is given the authority to make procurement decisions and handle waste management. In this way, products which may cost less off-the-shelf but are very expensive to dispose of may be replaced with products which may cost a little more to obtain, but cost far less for disposal, and furthermore, present much less health risk to workers. Preference should be given within the establishment of GSA contracts to products which are environmentally superior, creating less environmental impact during manufacture, useful life, and disposal, than other products in the same category. Markets for recycled products could be strengthened considerably if the federal procurement system favored such materials over "brand new" equivalents. 18 ------- Waste minimization efforts at facilities like Base Ketchikan would be facilitated if: - recycled products such as recycled office paper could be specified; - smaller quantities of materials, especially toxic materials, could be ordered; - products which can serve as substitutes for more toxic materials (such as solvents) could be specified. 19 ------- APPENDICES APPENDIX A SUMMARY OF WASTE MINIMIZATION OPTIONS IDENTIFIED IN THE WASTE MINIMIZATION OPPORTUNITY ASSESSMENT FOR BASE KETCHIKAN APPENDIX B BEST MANAGEMENT PRACTICES FOR VEHICLE/VESSEL MAINTENANCE AND MACHINE SHOPS APPENDIX C BEST MANAGEMENT PRACTICES FOR OFFICES 20 ------- APPENDIX A SUMMARY OF WASTE MINIMIZATION OPTIONS IDENTIFIED IN THE WASTE MINIMIZATION OPPORTUNITY ASSESSMENT FOR BASE KETCHIKAN 21 ------- SUMMARY OF WASTE MINIMIZATION FEASIBILITY ANALYSIS, Sheet 1 of 3 WASTE STREAM, LOCATION, . OPERATION BLASTING WASTE Marine nays, paint removal from vessels Buoy shed, paint removal from buoys PAINT WASTE Marine Ways and Buoy Shed, Painting Vessels and Buoys WASTE MIN OPTION • Lead-free, non-toxic paints • Concrete floor for marine ways • Geomembrane floor for marine Mays • Plastic blasting media * • Retest for new designation • Lead-free, non-toxic paints • Plastic blasting media • Magnetic separation • Lead-free nontoxic paints * • Nigh vol/low pressure paint guns * • Improve storage practices • Best application practices • Spray gun cleaning station * • Recycle paint wastes TOTAL CAPITAL INVESTMENT -- >$200,000 Unknown -- $6,000 -- -- -- -- $1,300 Minimal Minimal $500 $4.000 NET ANNUAL BENEFIT -- '$30,000 Unknown -- •$30,000 -• -• -- -- $12,250 Unknown Unknown Unknown $6,200 PAYBACK PERIOD -- 6,7 -- ' -- 0.2 •• -- -- -- 0.1 -- -- Unknown 0.6 COMMENTS • Long-range CG goal; may take several years to realize • Very expensive; w/nontoxic paints in a few yrs, may not be necessary • Not feasible w/out improved collection system • Less expensive than concrete, more durable ft effective than Visqueen • Cap. invest, is analytical costs for blasting waste 20 samples a $300/sample • Long range CG goal; may take several years to realize • Not effective for rust removal • No advantage over new steel shot recycling system • Long range CG goal; may take several years to realize • Strongly recommended; used by auto body paint shops • Will result in less wasted product • May require add. operator training • May reduce solvent thinner use; ' solvent can be recycled • Uses same distillation unit as solvent recycling option ------- SUMMARY OF WASTE MINIMIZATION FEASIBILITY ANALYSIS, Sheet 2 of 3 WASTE STREAM. LOCATION, OPERATION SOLVENTS Base-Hide, cleaning and Degress ing operations Industrial Machine Shop, "Gunk Tank" Industrial and Public Works, Small Parts Washers BILGE WASTE Base-wide, bilge management WASTE MIN OPTION • Solvent substitution * • Best management practices • Substitute "Hurri-Safe" • Add filtration units * • Solvent distillation • Oil /Mater separators on all vessels * • Oil /water separator on base * • Eliminate use of emulsifying detergents • IHtrnf iltration unit on base • Use oil/water separator at Ketch ikan Shipyard TOTAL CAPITAL INVESTMENT •- . Minimal -- Minimal $4,000 -- $26,050 -- $43.500 -- NET ANNUAL BENEFIT •• Unknown $600 Unknown So, 200 -- $18,680 -- $17,360 -- PAYBACK PERIOD •- N/A -- Unknown 0.6 -- 1.4 -- 2.5 -- COMMENTS • Considered case-by-case. Test product for effectiveness and disposal options. • Could reduce purchase and disposal costs significantly. • Sludge disposable as haz. waste • Could extend solvent life 2-3 times • Savings based on paint wastes; both can be distilled with same unit • Not feasible for smaller vessels • Oil can be recycled or burned for energy recovery • Necessary adjunct to use of oil/ water separator • Oil can be recycled or burned for energy recovery • Not currently available ------- SUMMARY OF WASTE MINIMIZATION FEASIBILITY ANALYSIS, Sheet 3 of 3 WASTE STREAM, LOCATION, ' OPERATION WASTE OIL Base-wide, lubricating and generator oils WASTE ANTIFREEZE/COOLANT Base-Hide, from vessels and vehicles BATTEKIES Base-Hide, primarily from ATOM units and vehicles PAPEI. GLASS. ALUMINUM. ETC. Base-wide WASTE Ml* OPTION • Waste oil heater (on-site energy recovery) • Off -site energy recovery- Ketchikan pulp mill • Combination off-site and on-site energy recovery * • Off-site oil recycling • Extended oil change intervals through oil testing • By-pass filtration * • Purify on-site and re-use • Recycle off -site • Recycle all batteries * • Recycle lead-acid batteries with payback * • Take paper to USFS collection point • Participate in City recycling program • Participate in regional recycling efforts *• Scrap equipment and metal to local scrapper TOTAL CAPITAL INVESTMENT $7,100 $1,400 $8,300 -- Unknown <$200 ea $8,000 -- -- -- -- -- -- NET ANNUAL BENEFIT $10,080 $16,480 $17,700 $25,750 Unknown Unknown $6,155 -- $7,240 $13,560 Unknown -- -- Unknown PAYBACK PERIOD 0.7 <0.1 0.5 N/A -- -- 1.3 -- N/A N/A -- •- •• -- COMMENTS • Ideal for heating buoy shed or warehouse; could use two heaters • Oil must meet burning specifications • One Haste oil heater; all other oil goes to pulp mill • Oil must be free of halogenated solvent contamination • Proven successful for fleet maintenance; expense & effort occurs in first year. • Extends life of oil, reduces purchase and disposal costs • Need to verify that system can purify Nalcool and Paxcool • Being investigated by SMD Juneau • All types of batteries accepted • Payback for lead in lead-acid batteries; all others recycled at Chempro • Avoids landfill disposal costs • Program planned to start in 1991 • In planning stages • Avoids landfill disposal costs and hauling ------- APPENDIX B BEST MANAGEMENT PRACTICES FOR VEHICLE/VESSEL MAINTENANCE AND MACHINE SHOPS 1. Prevent loss of chemicals through evaporation or spillage by ensuring that container lids are replaced and tightened. 2. Use spigots, pumps, or funnels when dispensing and transferring materials to reduce the possibility of spills. 3. Store products in locations that will preserve their shelf life, i.e. away from temperature extremes. 4. Accumulate waste indoors or in a covered area to prevent moisture from seeping in. 5. Avoid mixing different waste types together. 6. Clearly label and color code all waste accumulation containers. 7. Post signs above every waste accumulation container stating what may and may not be put into container. 8. Use drip pans to collect oils and fluids. 9. Keep used solvent separate from used oil. 10. Keep used chlorinated solvents (such as 1,1,1-trichloroethane and methylene chloride) separate from non-chlorinated solvents. 11. Use different funnels for used oil and solvents to reduce contamination potential. 12. Add drip trays to parts washing tanks. 13. Increase freeboard to slow evaporation of solvent from parts washers. 14. Place hoods on all parts cleaners and carburetor cleaning processes to control solvent evaporation. Organic solvents contribute to the ozone problem and the greenhouse effect. 15. Reduce dragout by allowing cleaned parts to drain thoroughly over the tank. 16. Use a fan to hasten drying of parts over the solvent tank, and ensure that air is exhausted through hood. 17. Used solvent can be used to prewash a part before it is cleaned with fresh solvent. 18. If high purity solvent is required to clean some parts, reuse this solvent for cleaning parts which do not require fresh solvent. 19. Use recycled solvent as much as possible. Few tasks require the use of brand new solvent. 25 ------- 20. Ensure that all liquid solvent waste is segregated from other types of waste. 21. Place liquid solvent waste in appropriate, labeled containers only. 22. Segregate oily and solvent filled rags from liquid wastes. 26 ------- APPENDIX C BEST MANAGEMENT PRACTICES FOR OFFICES 1. Use scrap paper for internal notes and memos. 2. Use electronic mail to eliminate paper communications. 3. Print draft documents on the unused side of discarded paper. 4. Save and reuse boxes, file folders, envelopes, and other packaging until each item is no longer useful. 5. Reply to memos directly on incoming copy to reduce paper use. 6. Circulate correspondence rather than distributing copies. 7. Establish a central bulletin board for announcements. 8. Photocopy documents double-sided. 9. Use recycled paper for photocopying and laser printers. 10. Separate and collect aluminum cans for recycling. 11. Separate and collect white paper for recycling. 12. Separate and collect colored paper and mixed paper trash for recycling. 13. Use recycled laser printer cartridges and recycle when spent. 14. Remain apprised of government procurement guidelines published by EPA. 27 ------- |