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


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   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

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                                 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;

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          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

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                             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

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                                   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

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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.

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       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)

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  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)

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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)

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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)

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         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)

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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)

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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)

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                                    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

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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

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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

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         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

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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

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         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

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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

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                          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

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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.
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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.
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                              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

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                   APPENDIX A
SUMMARY OF WASTE MINIMIZATION OPTIONS IDENTIFIED
IN THE WASTE MINIMIZATION OPPORTUNITY ASSESSMENT
               FOR BASE KETCHIKAN
                       21

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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

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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

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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

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                                       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.


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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.
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                                      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.
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