EPA Revises Provisions of Refrigerant Recycling Rule

EPA Revises Provisions of Refrigerant Recycling Rule
by Abdul H. Khalid, HTIS

This article serves to update individuals involved in maintaining
commercial and comfort-cooling refrigeration systems having a charge
of 50 pounds of refrigerant or greater.

On August 8, 1995, the EPA revised its leak repair provisions of
the Refrigerant Recycling Rule under Section 608 of the Clean Air
Act (CAA), as amended in 1990. According to the EPA, this revision
will provide greater flexibility to owners and operators of industrial
process sources and to some federally-owned commercial and comfort-cooling
refrigerant sources with regard to repairing leaks and retrofitting
leaky appliances without compromising public health and the environment.

The existing regulations require that persons servicing air-conditioning
and refrigeration equipment:

(1) observe certain service practices to reduce emissions;


(2) establish equipment and reclamation certification requirements;
and

(3) comply with a technician certification requirement.


Also, under these regulations, it is required that ozone-depleting
compounds contained in appliances be removed prior to disposal of
the appliances, and that all air-conditioning and refrigeration equipment,
except for small appliances, be provided with a servicing aperture
that will facilitate recovery and refrigerant.

The EPA, under this amended final rule, will:

a. Permit the owners or operators to have more than 30
days to complete repairs and more than one year to retrofit appliances,
where the conditions described in this final rule apply

b. Clarify that the owners and operators of all appliances
subject to the leak repair provisions must only reduce leak rates
to below the allowable leaks

c. Permit an additional time beyond the 30 day leak repair
period for federally owned chillers where the chillers are located
in areas subject to radiological contamination

d. Permit additional time beyond the one-year retrofit
period if appropriations and procurement requirements limit the feasibility
of completing the retrofit activities within one year

e. Permit the owners or operators to evaluate appliances
to slightly above atmospheric pressure, specifically to a pressure
not exceeding 5 psig, to perform oil changes or

f. Permit the owners or operators to recover the oil to
a system receiver where the receiver will be evaluated to atmospheric
pressure.

The effective date for this final rule was September 7, 1995.

For more information on refrigerant recycling rules, call the EPA
Stratospheric Ozone Hotline at  800-296-1996.

Reference: Federal Register, Vol. 60, No. 152, August 8, 1995,
40420, EPA.


Emergency Electrical Generators:EPA Guidance
by Dave Broocke, Dept. of Military Affairs, VA National Guard

Source owners attempting to determine their status under the
Clean Air Act (CAA) may soon be able to take advantage of a
relaxed Potential-To-Emit (PTE) scenario offered by EPA.  On
September 6, 1995, EPA's Director of Air Quality Planning and
Standards issued guidance to the EPA regional offices on
calculating the PTE for emergency electrical generators.  The
guidance applies only to generators, "whose sole function is to
provide back-up power when electric power from the local utility
is interrupted".  It excludes peaking units at electric
utilities, industrial generators that function in non-emergency
situations, and stand-by generators used during periods when
power is unavailable.

Emergency generators typically emit nitrogen oxides, carbon
monoxide, and, to a lesser extent, other criteria and hazardous
air pollutants.  Emissions from these units must be included when
calculating the cumulative emissions for a "source".  This is
critical because, under the CAA Amendments of 1990, sources are
classified based on their overall PTE, a scenario which assumes
that each elisions unit will operate 8,760 hours/year (24
hours/day, 365 days/year).  Although the actual emissions from an
emergency generator will likely be minimal, the PTE can bump
certain facilities into the "major" source/category, subjecting
them to Title V operating permit requirements..This approach,
while extremely conservative, has logical applications for some
sources, such as manufacturing units, which could reasonably be
expected to operate on the 8,760 hours/year schedule.  However,
the EPA recognizes that emergency generators have inherent
constraints on their use and recommends using a lower PTE
scenario that more accurately reflects actual operating
conditions.

The EPA recommends using an estimate that is based on the maximum
number of hours that power would be expected to be unavailable
and the hours needed for routine maintenance activities.  To
simplify this, EPA has established 500 hours/year as a default
value.  Calculations performed on average sized generators
indicate that individual generators will rarely emit at major
source levels under the 500-hour scenario.  Alternative estimates
may be made on a case-by-case basis where justified by the source
owner or permitting authority (e.g., historical data on power
outages can be used to calculate more accurate estimates).
Depending on the size and nature of the facility, the relaxed PTE
scenario for emergency electrical generators can have a
significant effect on the overall potential emissions levels
which drive the permitting process.

The September 6, 1995, memorandum is only guidance and is not
intended to discourage regulators from establishing operational
limits in construction permits when deemed appropriate.  Nor is
the guidance intended to be used as the basis for removing any
existing restrictions.  It simply provides Federal and state
permit authorities with an alternative option to use when
evaluating permit applications.  Nonetheless, the guidance is a
welcome relief and injects a dose of common-sense into an often
frustrating set of regulations.  It is also timely, as many
facilities across the country are gearing u for the Title V
process.  Owners of air emissions sources with emergency
electrical generators, should not hesitate to contact their
regulators concerning this information.  To obtain a copy of the
EPA memo contact Tim Smith, EPA Office of Air Quality Planning
and Standards at (919)541-4718.


"Empty" Containers: EPA & DOT Perspectives & DRMS Guidance

by Fred Tramontin and Tom McCarley, HTIS

The HTIS Helpline receives a steady stream of inquiries involving
the regulatory status of empty containers.

Two regulatory communities, EPA and DOT, have regulations that address
the issue of "empty" containers which contained hazardous materials.  In
addition, the Defense Reutilization and Marketing Service (DRMS) provides
its policy/guidance in Chapter XX of DRMS-M 6050.1 titled "Environmental
Compliance for the DRMS Hazardous Property Program" (April 1994).
This article will point out the commonality and differences that exist
among the three.

EPA Perspective

Title 40 of Code of Federal Regulations (CFR), Part 261 describes
the attributes of a waste for regulation purposes.  In order for a
material or item to become subject to the hazardous waste regulations,
it must first meet the definition of a solid waste. This entire issue
of what attributes a material must have before becoming a regulated
solid waste is receiving a great deal of attention from the EPA and
will be the subject of continuing discussion.

Here, we will consider that when something is discarded, it becomes
subject to "solid" waste regulations but not necessarily as a "hazardous
waste".  A solid waste, for purposes of regulation can be a solid,
liquid, or contained gas. If in turn, a solid waste also meets any
of the criteria of 40 CFR 261.21 thru 40 CFR 261.33, it will in most
cases, be more highly regulated as a hazardous waste. In regulatory
jargon, such hazardous waste is also referred to as Subtitle-C waste,
whereas non-hazardous solid waste is referred to as Subtitle-D waste;
the subtitles referring to those of the Resource Conservation and
Recovery Act (RCRA), the nation's solid  and hazardous waste law.

There are items that the layman would call "loopholes", and the regulator
would call exclusions or exemptions from particular regulations. By
criteria of a RCRA definition, "empty" discarded containers are
solid waste, but not hazardous waste. Judging from the calls received,
this concept merits a short explanation.

40 CFR 261.7 describes the regulatory status of residues of hazardous
waste in empty containers. If a container of waste qualifies as
RCRA "empty", it need not be handled as a hazardous waste.

If the container or inner liner held most non-gaseous materials,
it would be considered empty if:

All the waste material has been removed that can be removed
by common practice be that pouring, pumping, aspirating etc.,

One inch or less of residue remains on the bottom of the
container or inner liner, or

An alternate to the one inch rule is that no more than
3% of the weight of the container contents may remain for containers
of 110 gallons or less.

For large containers such as "tank" trucks, railroad "tank" cars and
roll-off dumpsters, the rule is 0.3% of content capacity. Note that
"tank" cars and trucks are containers by RCRA definition. For a containerized
gas, the can or cylinder is considered empty when the internal pressure
approaches the external atmospheric pressure (14.7 psi or 760 mm at
sea level).  Aerosol cans are an issue of confusion and complexity
all of their own and will be covered in a future article.

Additional requirements are detailed for "acute" hazardous wastes.
These wastes are the 'P' listed wastes of 40 CFR 261.33 where the
'P' listed material is the sole active ingredient and certain 'F'
wastes of 40 CFR 261.31 (F020, F021, F022, F023, F026, and F027).
These additional requirements involve triple rinsing of the container
or liner or use of an equivalent removal method. With the triple rinse
technique, three successive rinses using an appropriate solvent must
be used and the discarded rinses (the rinsate) must be captured and
handled as the appropriate waste which is being removed.

The RCRA regulations do not address the volumes of solvent to use
for each of the three rinses. Industry practice suggests the use of
10-25% of the container's volume. EPA's pesticide regulations (40
CFR 165.1(x) indicate that 10% of a container's volume be used for
each rinse of a triple rinse. If an intact inner liner has prevented
any contact of material with the external container, then the external
container would be considered empty once the liner is removed.

Compressed gas cylinders would have to have their contents at atmospheric
pressure; i.e., zero gauge pressure, to be considered RCRA "empty".
If containers that held hazardous waste have not been emptied in
accordance with the aforementioned definition, the containers must
be managed as hazardous waste. Note that state regulations regarding
empty containers may be more stringent. In such states, the state
regulation must be followed in lieu of the Federal regulations.

DOT Perspective

DOT regulates the shipment of containers which previously held
hazardous materials. 49CFR173.29 states that an empty packaging (i.e.
container) containing only the residue of a hazardous material shall
be offered for transportation and transported in the same manner as
when it previously contained a greater quantity of that material.
This requirement does not apply to a container that has met certain
conditions. A few of these are:

The container is sufficiently cleaned of residue
and purged of vapors to remove any potential hazards;

The container is refilled with a material which is
not hazardous to such an extent that any residue remaining in the
packaging no longer poses a hazard;

Any hazardous material shipping name and identification
numbers, markings, and hazardous warning labels or placards are removed,
obliterated, or securely covered in transportation;

Any material contained in the container does not
meet the definition in 49CFR171.8 of a hazardous substance, waste,
or a marine pollutant.

Note that containers that contain less than one inch of residue
may be empty per EPA regulations, but are still regulated by DOT during
transportation.

DRMS Guidance

DRMS uses the EPA "empty" criteria in 40 CFR 261.7 to define
whether a container qualifies as an "empty" container. For containers
that meet the criteria of empty, DRMS classifies them into three categories
(based on previous contents and residue) for disposal processing:


1. Non-hazardous containers;

2. Hazardous containers; and

3. Acutely hazardous containers.

A category 2 or 3 container can become a category 1 if it has
been triple rinsed. Containers having the conditions set forth in
categories 1, 2 and 3 will be offered for reuse consistent with DOD
4160.21-M (Defense Reutilization and Marketing Manual), i.e. reutilization,
transfer, donation (R/T/D), and sales. Should R/T/D and sales alternatives
fail, a downgrade to scrap is permitted for category 1, but not for
category 2 or 3 containers. Category 1 containers can be disposed
of as non- hazardous solid waste. Abandonment and destruction (A&D)
actions are permitted consistent with DOD 4160.21-M. Category 2 containers
are considered non-RCRA regulated for disposal. Category 3 containers
that have not been triple rinsed are regulated under RCRA for disposal.

DRMS considers "Non-Hazardous Containers" to be empty containers
whose previous contents were non-hazardous, containers with their
liners removed, or, if previously contained a hazardous material or
an acutely hazardous waste and have been tripled rinsed. On the
other hand, "hazardous containers" are empty containers whose
previous contents were hazardous, but not acutely hazardous, that
is, containers or inner liners that have previously contained material
that are hazardous by any Federal (DOT, RCRA, CERCLA, TSCA, FIFRA,
OSHA), or state definition. Acutely hazardous containers are
those containers that hold one inch or less of acutely hazardous material
and have not been tripled rinsed -- such containers must be managed
as hazardous waste. Triple rinsing of empty containers is not a turn-in
requirement, but an option. DRMS does not require triple rinsing for
turn-in of any containers (Chapter XX, D.1.c).

All DOD personnel are reminded that their installation or Command
may have specific policies and procedures for handling "empties";
be sure to check with your installation's environmental/ health and
safety office and your local Defense Reutilization and Marketing Office
(DRMO) regarding proper handling and disposition of excess and empty
containers.

References: 1.Titles 40,49 Code of Federal Regulations.
2. DRMS-M 6050.1 (Chapter XX)  "Environmental Compliance for the DRMS
Hazardous Property Program, April 1994.  3. Thanks to R. Scherer and
J. Plucinski, DRMS-SH, for their input.





Procurement & EO 12969

by Tom McCarley, HTIS

On August 8, 1995, President Clinton signed Executive Order
12969, which calls for Federal Agencies to only procure goods and
services from private sector vendors that have complied with the provisions
of the Emergency Planning and Community Right To Know Act (EPCRA).
For contracts of $100,000 or more, Federal Agencies need to require,
as part of the contract solicitations and eligibility criterion, that
contractors comply with the Toxic Release Inventory reporting provisions
of EPCRA Section 313, by filing Form R reports during the life of
the contract. Should the potential contractor not be subject to reporting
under EPCRA, they should certify as such.

On September 29, 1995, EPA issued guidance in complying with the EO
for Federal Agencies. Contracting officers and others involved in
the award of contracts valued over $100,000, need to review the guidance.

References: 1. FR, August 10, 1995, Vol. 60, No. 154, p.40987-40992.
2. FR, September 29, 1995, Vol. 60, No. 189, p. 50737-50743.

Hazcom Violations Leads OSHA List

by Beverly Howell, HTIS

On an annual basis, OSHA publishes a list of "Most Frequently Cited
OSHA Standard Sections". This list alerts the public to the type of
violations identified in the workplace along with the number of alleged
violations. Since Federal facilities must comply with the same standards
as the private sector, it would be beneficial to look at the standard
sections cited to ensure that our facilities are in compliance with
OSHA regulations.

For two consecutive fiscal years (1993-1994), Sections cited under
29 CFR 1910.1200, the Hazard Communication Standard have dominated
the list. The paragraph leading the list is (e)(1), the written
hazard communication program. This section requires employers to
develop, implement and maintain a written hazard communication program
at each workplace. The written program must describe how the employer
will meet the standard's requirements to provide container labeling,
collection and availability of material safety data sheets (MSDSs)
and how employee training will be conducted. The written program must
also contain a list of the hazardous chemicals in each work area and
the means the employer will use to inform employees of the hazards
of non-routine tasks. The second on the list is subsection (h):
employee information and training, which requires that employees
are trained at the time they are assigned to work with a hazardous
chemical. The intent of this provision is to have information prior
to exposure to prevent the occurrence of adverse health effects. Additional
training is to be done whenever a new physical or health hazard is
introduced into the work area, not a new chemical. The third section
identified is subsection (f):  labels and other forms of warning,
specifically subparagraphs (5)(i) and (ii), the provision requiring
that hazardous chemical containers are labeled with the identity and
appropriate hazard warning. Fourth, are the provisions affecting
material safety data sheets, paragraph (g)(1), contains the requirements
for manufacturers and importers to obtain or develop MSDSs, along
with the provision that employers have a MSDS for each hazardous chemical
that they use. Lastly, is paragraph (g)(8) requiring that employers
maintain copies of the MSDS in the workplace for each hazardous chemical
and ensure that they are readily accessible during the each workshift.

Additional standards cited in Part 1910 are as follows:

Standard Section .147 (c)(1)
	Standard: Lockout/ Tagout               	Subject: Energy Control

	Program

Standard Section .212 (a)(1)
	Machine Guarding
	Guarding Methods

Standard Section .215 (b)(9)
	Abrasive Wheel Guarding
	Guard Adjustments

Standard Section .151 (c)
	Medical Services/ First Aid
	Drenching Facilities

Standard Section .219 (d)(1)
	Power-Transmission Belts
	Pulley Guarding

Standard Section .147 (c)(7)(i)
	Lockout/Tagout
	Worker Training

Standard Section .147 (c)(4)(i)
	Lockout/ Tagout
	Energy Control Procedure

Standard Section .212 (a)(3)(ii)
	Machine Guarding
	Point of Operation

Standard Section .215 (a)(4)
	Abrasive Wheel Machinery
	Work Rests

Standard Section .23 (c)(1)
	Floor/Wall Opening Guarding
	Standard Railing

Standard Section .305 (b)(1)
	Wiring Methods/Protection
	Cabinets, Boxes and Fittings

Standard Section .132 (a)
	Personal Protective Equipment
	Provision, Use, Maintenance

Reference: Occupational Safety and Health Administration, Washington,
DC, 1995.




Soda Blasting

by Abdul H. Khalid, HTIS

This article updates soda blasting technology that has been tested
on concrete and steel surfaces contaminated with radioactive and hazardous
materials such as uranium, heavy metals, and polychlorinated biphenyls
(PCBs). Sodium bicarbonate (soda) is used as a blasting agent for
surface cleaning, degreasing, and depainting. Soda blasting is an
environmentally safe method for hazardous surface cleaning and decontamination
without damaging blasted surfaces.

Sodium bicarbonate has very low toxicity. Blasting residues or wastes
from blasting operations may be diluted with water and sent to the
POTW (publicly-owned treatment works) if the disposed coating or surface
material is non-hazardous. If the blasting residuals are hazardous,
the disposed materials are contained, dissolved and treated in specially
designed treatment equipment for proper disposal. This reduces waste
disposal costs.

According to the article on surface decontamination with soda blasting
in Nuclear Plant Journal, July-August, 1995, the O'Brien & Gere Companies
tested a decontamination system on concrete and steel surfaces contaminated
with uranium, technetium, heavy metals, and PCBs under the sponsorship
of Martin Marietta Energy Systems, Inc.(MMES) at DOE's K-25 former
gaseous diffusion plant in Oak Ridge, TN. Testing demonstrated that
the system was capable of removing greater than 95% of radioactive
and PCB surface contamination to below DOE's unrestricted use release
limits; aqueous radionuclides, heavy metals and PCBs were below DOE
and U.S. EPA treatment objectives after blasting residuals treatment.
Waste residuals volume was decreased by 71%. Preliminary analyses
suggested that the soda blasting/waste residuals treatment system
provided significant waste volume reduction and was more economical
than surface decontamination techniques that are commercially available.
The estimated full-scale system capital and operating costs (including
waste disposal) were $7.00 to $8.00 per sq.ft of surface area for
230,000 sq.ft. of surface area.

DOD personnel interested in soda blasting technology or for further
details on the removal and treatment of radioactive or hazardous contaminants,
contact Mr. Eric D. Neubauer, O'Brien & Gere Technical Services, Inc.,
Syracuse, NY at 315-437-6400.

Reference: "Removal and Treatment of Radioactive Contaminants", Nuclear
Plant Journal, Vol. 13, No. 4, July-August, 1995, pages 41- 46.

Edwards AFB: Pollution Prevention Initiatives

by Muhammad Hanif, HTIS

Within the DOD, Edwards AFB has set an example of controlling volatile
organic compounds (VOCs) emission and respirable particulates in air
during their corrosion control activities by building a large corrosion-control
facility to comply with the environmental requirements. The facility
measures 185 feet long, 176 feet wide, 53 feet high, with the ability
to accommodate many of the Air Forces' aircraft, such as the A-37,
T-38, F-15, F-16, C-130, and B-1, as well as ground support equipment.
These units are typically painted with an epoxy polyamide primer and
high- solids polyurethane topcoat using high-volume low-pressure (HVLP)
guns. In addition to corrosion control activities performed, the following
pollution prevention initiatives are co- located in the facility:

Plastic media blasting for de-painting in some operations
and projected plans for an aquamiser system, which uses medium to
high pressure water with baking soda to lift off paint

Computerized stencil machine for vinyl appliques instead
of spray paints

Enclosed paint gun cleaners

Hazardous material pharmacy concept in use

Magazines such as TODAY, and Industrial Paint & Powder have
covered details of the facility by publishing articles in December,
1994. The article ("Air Force Clears The Air") that follows is printed
with permission from TODAY. For additional information concerning
corrosion-control facility and pollution prevention at Edwards AFB,
California, contact John Franz, DSN 527-1401 or Comm 805-277-1401.


Air Force Clears The Air

The new "paint booth" at Edwards Air Force Base is so huge it can
hold an EC-18B or Boeing 707 -- and environmental regulators love
it. It includes a unique carbon adsorption/de-adsorption system; the
first ever this large to destroy over 98% of volatile organic compounds
(VOCs) and 99% of particulate emissions from the paint application
area.

This project not only represents an improvement in environmental protection
at Edwards Air Force Base, it also represents a "quantum leap" in
best available control technology (BACT) for this category of equipment.
In fact, it is considered state of the art by Kern County Air Pollution
Control District officials. They have recommended it to the EPA as
a model for facilities of this kind all over the United States.

The 47,000-square-foot facility was designed by the Army Corps
of Engineers following environmentally-conscious directives from the
Air Force.  Although the permit required only 95 percent clean exhausted
air, tests show that the building is exhausting air that is 98 percent
clean.

The important air quality action happens at the rear of the
booth. Here air flows through a two- stage poly filter and then
through a 1-micron high-efficiency particulate air filter to trap
all paint particles. Solvent-laden air then proceeds to the carbon
bed behind the filters where 18 carbon banks filled with 80,000 pounds
of carbon adsorb 98% of the pollutants. The result is an impressively
clean exhausted air; cleaner in fact, than the ambient air outside.
The facility is considered 100% capture-efficient.

An automatic warning system alerts operators when the carbon
bed is saturated. One carbon bank at a time is emptied onto a conveyer
for transportation back to the de-adsorption unit, located in a small
enclosure adjacent to the main facility. De-adsorption is a two-step
process. First, the carbon is heated to 450o F to remove VOCs
and to clean the carbon. Then the solvent- laden air moves to a thermal
oxidizer which destroys the VOCs at temperatures from 1200o
to 1500o F. The carbon bed is only expected to reach saturation
about every one to two years. This is very cost-effective and it is
estimated that 93% of the carbon may be reusable.

Edwards has become a model for aerospace coating activities.
Celebrity has its benefits and Edwards now is receiving contract work
from all over, including the Army, Navy, and NASA. It also receives
paint jobs from out-of-state. Within five years, Edwards plans to
become the primary regional painting facility. At a time when many
military projects are leaving California, Edwards is bringing projects
back to the state because no other facility can offer the environmental
safeguards required.

Edwards is well on its way to repaying the money allocated for
building costs, thanks to its fast-growing reputation which continues
to attract outside business. The staff at Edwards is confident that
the nation's investment in clean air  will continue to pay dividends
in more ways than one, long into the future.

References: Renew America, 1994,1400 16th Street, NW, Suite 710, Washington,
DC 20036






DOD Environmental Measures of Merit

by Tom McCarley, HTIS

In response to the Government Performance and Results Act of 1993,
the DOD Environmental Security Office has developed a series of measures
by which DOD's overall environmental program will be measured. These
measures include a look at compliance, cleanup, pollution prevention,
conservation, occupational safety and health, and pest management.
Such measures will be used to develop the FY97 budget for DOD environmental
programs.

Environmental Goals

Reduce toxic release by 50% by December 31, 1999, as reported in the
EPCRA Section 313 Toxic Release Inventory. This is a goal mandated
by Executive Order 12856 using CY94 as a baseline.

Reduce hazardous waste disposal by 50% by December 31,
1999, as measured against a 1992 baseline.

Reduce solid waste disposal by 50% by December 31, 1999,
as measured against a 1992 baseline.

Recycle 50% of DOD generated non-hazardous solid waste
by December 31, 1999.

Have 75% of new non-tactical vehicles be alternate fuel-using
vehicles by December 31, 1999.

Reduce the number of Class I ozone-depleting-substance-using
units by 15% over the next five years.

Reduce the quantity of Class I ozone-depleting substances
in use by 15% over the next five years.

Reduce the number of weapons systems using Class I ozone-depleting
substances by 20% over the next five years.

Reduce the quantity of Class I ozone-depleting substances
in weapons systems by 20% over the next five years.

Reference: Mullenhard, Peter, editor, Navy CFC and Halon Clearinghouse
ODS News, August 10, 1995 as abstracted from the July 1995 Army Acquisition
Pollution Prevention News.






DOD MILSPEC Toxins Review

by R. A. Menuet, HTIS

The Department of Defense has announced that a review of nearly 32,000
military specifications and standards, to reduce or eliminate use
of toxic substances, has been completed. This review was mandated
by Executive Order 12856, which set a deadline of August 3, 1995,
for completion of the review and a 1999 completion date for rewriting
targeted specifications.

During the review, the DOD found 173,000 "potential references" to
toxic chemicals and "extremely hazardous substances". Next, these
references will be validated to insure that they actually require
the use of hazardous or toxic materials.

A specification revision system is being developed by DOD that will
reduce or eliminate use of materials harmful to human health and the
environment. The new system will emphasize the use of other alternative processes
first, then will rely on research and development to create new alternatives
if existing ones are inadequate. (Reference: Defense Environment Alert,
Vol. 3, No. 18, September 6, 1995.)


Selling Recyclables:  Local Markets

Reprint:  Army Acquisition Pollution Prevention News, May, 1995

Renewed interest in Executive Order 12873, "Federal Acquisition,
Recycling and Waste Prevention, " has been generated as the profitability
of the recycling market has increased. Army activities are encouraged
to take advantage of the market up-turn by selling directly to local
area markets. The Department of the Army issued a memo signed by Colonel
Frank R. Finch, Director, Environmental Programs outlining the approval
procedure for direct selling. The procedure is presented below:

With the prior review and concurrence of their military service
headquarters, generating activities will submit their request to the
servicing Defense Reutilization and Marketing Office (DRMO) with the
following information:

The past year's quantities generated, by the requested
commodity, at DRMO obtained prices.

The past year's quantities generated, by requested
commodity, at complete market value (net of overhead and transportation).

Written acknowledge of the requirements and provisions
of the Deputy Under Secretary of Defense (Environmental Security) Memorandum
of 28 September 1993, subject: Policy for DOD Recycling. The generating
activity must note in particular the following:

	The requirement that sales of
 recyclable materials be in accordance with Section 203 of the Federal
Property and Administration Act of 1949 (U.S. Code 484), as amended;

	The requirement that install-
ations selling directly maintain operational records for fiscal year
reporting requirements, review and program evaluation purposes. This
is to include, but is not limited to, quantities generated and sold,
prices obtained, copies of successful contracts, potential buy mailing
list; and

	The definition of eligible
 recyclable materials and applicable exclusions.

	Written acknowledgment that any approval granted is subject
to change or termination if the Office of the Secretary of Defense's
direct sale policy is changed or terminated.

	Failure to comply with the above requirements is justification
to withhold the granting of requested direct sales waivers or the
cancellation of existing waivers.

	DRMOs will confirm the validity of commodities, quantities generated,
prices, or any relevant changes as reflected on DRMO records and forward
request to the Defense Reutilization and Marketing Service (ATTN:
DRMS-MD). DRMOs will also include a recommendation as to the granting
of the requested direct sales waiver.

	DRMS will review the request and approve or disapprove as appropriate.
DRMS will then notify the requesting generating activity, appropriate
military service headquarters and the effected DRMO, with an information
copy to HQ DLA (ATTN: MMSC).  Subsequently, when there is a dispute
between DRMS recommendations and the appropriate military service
headquarters position, the request will be forwarded to HQ DLA for
assistance.

Approvals will be granted for a maximum period of six months.
As part of the consideration of any waiver renewal, the appropriate
military installations will submit to the DRMS (ATTN: DRMS-MD)
the following data:

	Commodities generated and successfully sold.

	Time period involved.

	Relevant proceeds obtained.

	Types of sales contract utilized.

Direct sales renewals will be granted only when it
can be clearly demonstrated that the applicable DRMO and DRMS sales
activities can not duplicate or exceed the same efficiency and cost
effectiveness as that of the generating activity.

For additional information, please contact Mr. Michael Stubblebine,
MMSCP, on (703)767-1537.





EPCRA Update

Andy Porth of the DOD Environmental Security Office has provided a  clarification
to our Sep-Oct issue article, "EPCRA Guidance For Federal Facilities".
The topic at issue is whether DOD installations can be fined for failure
to report under EPCRA and EO 12856. The answer as follows is in accordance
with DOD guidance, issued April, 1995.

No, EPA cannot fine a DOD facility if it does not comply with EO 12856.
EO 12856 does not give EPA the authority to fine DOD facilities.
However, Section 5-504 of EO 12856 authorizes EPA to conduct reviews
and inspections of DOD facilities to monitor compliance with toxic
release inventory, pollution prevention, and community right-to-know
reporting requirements, as set out in Sections 3-304 and 3-305. Section
5-507 requires EPA to report annually to the President on Federal
Agency compliance of the EO. For more information on EPCRA and EO
12856, contact Andy Porth at DSN 761-9697; 703-681-9697. (tm)




Fluorescent Lamp Recycling Services

by Abdul H. Khalid, HTIS

This article updates articles on "PCB-Containing Ballasts and Mercury-Containing
Lamps Disposal" and "Mercury Emissions and Used Fluorescent Lamps"
published in HTIS Bulletin, May-June 1994 and Jan-Feb, 1995, respectively.


As explained, mercury-containing lamps frequently fail the Toxicity
Characteristics Leaching Procedure(TCLP) test for mercury(D009) making
them a characteristic waste in various situations.

Recycling fluorescent lamps reduces the long term liability associated
with disposal and is an environmentally safe method to reduce waste
and meet the EPA requirements of waste minimization and pollution
prevention. Materials such as mercury batteries, mercury compounds,
mercury amalgams, mercury contaminated debris, and other mercury wastes
can be disposed of through mercury refining processes. Some of the
common accepted goals of fluorescent lamps recycling are:

	Recovery of mercury for resale

	Recovery of the aluminum in the end-caps

	Reuse of glass in asphalt or cement products.

With the recent developments in metallurgy, refining technologies,
and disposal capabilities for all types of mercury, recycling is a
better solution to the problem of handling the hazardous materials/wastes.
The Defense Reutilization and Marketing Service (DRMS) provides information/lists
of mercury recyclers who are currently on DRMS contracts. Since the
disposal requirements vary from state to state, it is a good idea
to check with local authorities/local DRMOs for all applicable regulations
in the areas where the DOD facilities are located. DRMS does not approve
or disapprove recyclers for disposal purposes.

 DOD personnel interested in mercury waste disposal can request further
information on mercury recyclers or references for various categories
of mercury wastes by calling Mr. Randy Smith, , DRMS-SHO, DSN: 932-5898,
Disposal Management and Environmental Protection Directorate, Battle
Creek Michigan. For technical inquiries and disposal of mercury-containing
lamps/ballasts, contact the HTIS staff at Defense General Supply Center,
Richmond Virginia; DSN 695-5168 or 1-800-848-4847; 804-279-5168.

Reference: EPA's "Lighting Waste Disposal", EPA 430-B-95-004, March
1995.



Training Symposium
by J.P. Smith, ACC/CEVPA

The U. S. Air Force, Air Combat Command's annual Environmental Training Symposium will be held
February 12-16, 1996, in St. Loius, MO. Air Combat Command will host over 800 environmental
engineering, logistical, legal, public affairs, industrial hygiene, contracting, and general
management professionals. This intense training event will provide a projected 230 class offerings
on over 55 environmental quality, pollution prevention, cleanup, information management, planning
and analysis, and product substitution/recycling topics. A concurrent exhibition will be held
February 12-14 for the purpose of information and technology exchange. For more information
on the symposium, contact J.P. Smith, ACC/CEVP, Langley AFB, VA; (804)764-2272; exhibitors only:
(703)683-0102.




DGSC Products Via Internet

Defense General Supply Center has brought the logistics system
of the 21st century a little closer to its customers through the World
Wide Web.

Military and civilian agency customers with access to the Internet
can now log on to DGSC's home page through http://www.dgsc.dla.mil
and order items directly online.

The Environmentally Preferred Products Catalog and the Energy
Efficient Lighting Catalog are available for browsing on the Internet
and more catalogs are planned for the future. However, customers are
not restricted to only ordering catalog items. With the National Stock
Number (NSN) and other data required to input a MILSTRIP or FEDSTRIP
requisition, any item managed by DGSC can be ordered online.

Some of the various commodities managed by DGSC includes chemicals,
pesticides, refrigerants, batteries, food service equipment, packaged
POL, and film. Services brochures and product catalogs are also available
in hard copy and on disk.

For more information on products managed by DGSC, contact our Marketing
Office at 1-800-352-2852 or DSN 695-5699.



ASK  HTIS !!!

HTIS is a technical support function operated by the
Defense Logistic Agency at DGSC.
It provides telephonic professional consultation services to DOD personnel
worldwide.
If you need assistance in the management of hazardous materials &
wastes,
need guidance with compliance to environmental regulations,
or are seeking technical information on environmentally-preferred
products,
call the HTIS Helpline at 1-800-848-4847 or DSN 695-5168.

Q:  Are Material Safety Data Sheets (MSDSs) necessary for all batteries?

A:  If the batteries provided to you meet OSHA's definition of an
"article", then an MSDS is not needed. Some manufacturers state that
their batteries meet OSHA's article definition and do not provide
an MSDS, while others provide a technical fact sheet which resembles
an MSDS. Others simply provide an MSDS with no explanation. Many people
use an MSDS as a means of identifying the components of a battery
prior to disposing of them through their local DRMO.

Q:  What type of shipping containers are needed for transporting
"used terne-plated" oil filters?

A:  Once these filters have been drained, IAW, the established regulatory
protocol, one can select any shipping container which will not leak
any of the residual oil remaining in the filters. If one elected to
use a fiberboard type container, one would be strongly advised to
use a "poly" liner of approriate thickness to act as a barrier between
the filters and the fiberboard surface.

Q:  Who is responsible for providing information on disposal of
items containing low levels of radioactivity?

A:  The owner/holder of the item needs to contact his/her respective
service component for policies and procedures. Personnel with Army
or DLA should contact: Radiological Waste Office at Rock Island Arsenal
in Rock Island, IL (DSN 793-2933) or Comm. 309-782-2933); Navy personnel
should contact the Radiological Affairs Support Office at the Naval
Weapons Station in Yorktown, VA (DSN 953- 4692 or Comm. 804-887-4692);
and Air Force personnel should contact the Low Level Radioactive Waste
Office at Kelly AFB, TX (DSN 945-8635 or Comm. 210-925-8635). A caller
will need to provide the isotope in question, its level of activity
as well as its form, and the number of items to be disposed.

Q:  Can you provide the name of some government organizations which
offer courses addressing environmental issues especially those related
to hazardous waste?

A:  The following organizations are among some of those which often
offer courses covering a variety of topics in the environmental arena.
DOD personnel may select courses at an appropriate level depending
on their background, departmental needs, and financial resources:
The U.S. Army Logistics Management College at Ft. Lee, VA (DSN  539-4636
or Comm. 804-765-4636);  Center for Environmental Initiatives at Ft.
Sill, OK, (DSN 639-2111 or Comm. 405-442-2111); OSHA Institute in
Des Plains, IL  (Comm. 708-297-9990/4810); and the  U.S. EPA Office
of Solid Waste and Emergency Response in Washington, DC (202-260-0095/6441).

Q:  Does OSHA conduct training with respect to electrical hazards
?

A:  OSHA does provide basic training in electrical hazards. One should
contact Mr. A. Hawez at 708-885-0489 or 708-297-4810 with the OSHA
Institute in Des Plains, IL.

Q:  Can DOD employers or employees train and test themselves under
DOT's HM-126F requirements?

A:  Yes, provided all training requirements set forth in 49CFR172.704
are met.

Q:  Is there a DOD manual which explains how to store hazardous
materials in a proper fashion and also defines the HCCs ?

A:  The manual is titled "Storage and Handling of Hazardous Material
"  (May '92). The Service/Agency publication identification is:  Army:
TM 38-410;  Navy: NAVSUP PUB: 573;  Air Force: AFR 69-9;  Marine Corps:
MCO 4450-12; and Defense Logistics Agency:  DLAM 4145.11. One should
contact their respective publication center if one desires a copy.

Q:  Where does one return excess supplies of ozone depleting chemicals?

A:  The Defense General Supply Center serves as DOD's respository
of essential ODC supplies. One should contact Ms. Audrey Studevant,
DGSC-JDSB with detailed information (DSN 695-3756 or Comm. 804-279-3756).



Get Rid of HazMat Quickly, Legally, & Cheaply

Reprint : Air Force Journal of Logistics, Winter, 1995, by Lt. Colonel
Nichols S. Costa, Deputy Commander 36th ABW Logistics Group, Andersen
AFB, Guam

Late in 1994, the 37th Air Base Wing Logistics Group, Andersen AFB,
Guam, Hazardous Materials (HAZMAT) working group faced a potentially
serious problem in managing HAZMAT. Like many other organizations,
we opened a pharmacy to resolve this. To improve our operation, we
sought guidance which, except for PRO-ACT (an environmental information
clearinghouse), was hard to get. So we looked at our Navy counterparts
on Guam. The Navy has a Ship Repair Facility (SRF) and Fleet Industrial
Supply Center (FISC) here.  Both are substantial operations that use
many HAZMAT. We found their programs were light years ahead of ours.

The Navy has eight other FISCs worldwide (Norfolk, VA: Charleston,
SC, Jacksonville, FL: San Diego, CA; Puget Sound, WA: Pearl Harbor,
HI; Oakland, CA; and Yokosuka, Japan). Sigonella, Italy will eventually
have one also. Each FISC has a Hazardous Material Reutilization Center
(HAZMINCEN). That's Navy for pharmacy. What we found interesting is
that the HAZMINCEN will serve, or partner with, non-Navy units.

We subsequently signed an Interservice Support Agreement (ISSA) with
FISC Guam, adding a new dimension to our pharmacy procedures. This
agreement is the first of its kind in the Department of Defense. Our
Supply squadron is transferring HAZMAT to the FISC GUAM HAZMINCEN.
The FISC will store, stock, and deliver our HAZMAT (we keep five days
worth in our pharmacy). The change is nearly invisible to base customers.

Our ISSA so far has cut three major ECAMP (Environmental Compliance
and Management Program) write-ups without cost. The outcome is that
we will have less HAZMAT on Andersen and Guam, and we will free up
about 6,200 square feet of indoor storage area. This agreement lets
us operate with no constraints. It's win-win for all concerned.

Shortly after learning of this program, we got rid of several hundred
gallons of paint, we thought we would become waste. After we told
PACAF/LGQ about it, Hickham AFB got rid of 47 pallets through the
Pearl Harbor FISC, all at no charge. Hickham saved $200,000 that it
would otherwise have had to spend on waste disposal.

By using the Navy HAZMINCEN, our cost avoidance for 1994 was $799,432.11.
This included material ($128,662.38) and disposal avoidance ($670,769.73).
Disposal avoidance does not even include shipping costs off the island.
Our total cost avoidance as of 1 May 1995 was over $850,000.

Now for a few of the specifics about our agreement. The Navy HAZMINCEN:
(1) Reports our HAZMAT storage (Resource Conservation Reporting Act
(RCRA) and Emergency Planning Community Right to Know Act (EPCRA)
301/302). We report only our usage.

(2) Issues HAZMAT in only the quantities needed. Its larger organization
allows economies of scale to take the pharmacy concept one step better.

(3) Advertises our excess HAZMAT worldwide, real-time, and consolidates
all our excess, centralizes issues, and provides free redistribution
of excess HAZMAT.

(4) Takes the unused portion back, if uncontaminated.

(5) Offers a closed loop on HAZMAT life cycle management issue and
return. We take our quart, use it, ensure we did not contaminate the
container, then return it to FISC. FISC tracks the container.

(6) Provides training on shelf life extension.

(7) Transports HAZMAT to and from the HAZMINCEN.

(8) Examines our facility, analyzes our waste stream, and recommends
methods of improvement. This could potentially be a big money saver.

(9) Provides a list of environmentally safe substitutes. What does
it cost? Very little. We pay the cost of the material-period. There
is no value added charge. This means we pay the same as through Supply.
We still have our own pharmacy, but we are eliminating redundancy
and have less to report and to store.

These programs are standard, Navy- wide. Since there are usually several
DOD installations convenient to a FISC, check it out.

For further information call:

36 ABW/LGX, SSgt Hughes, DSN 315-366-3290; 36 ABW/LGSDH (HAZMAT pharmacy),
DSN 315-366-4770; 36 ABW/MG BioEnvironmental, DSN 315-366-6219; FISC
GUAM code 82H, Mr. Tom Nelms, Comm. 671-339-4628; CONUS information,
NAVSUPSYSCOM 452, LCDR Ed Payne, Comm. 703-607-1206.