4. COMBUSTION

 

4.1 Medical Waste Incinerators Hospital/Medical/Infectious Waste Incinerator (HMIWI)
New Source Performance Standard (NSPS)
Existing Source Emission Guideline (EG)

The new medical waste incinerator rules will increase the cost of compliance of military medical waste incinerators. The DoD is researching alternatives to incineration. Please contact the Army CHPPM, the Navy PPEP, or the Air Force Human Systems Center (HSC/OEBQ) for a list of alternative technologies such as autoclaves and microwave irradiation.

P2 Option: Out-source medical waste for disposal off post

Success: A contract to ship medical waste off post proved to be less expensive than running the medical waste incinerator. By shipping medical waste off post at $0.28 per pound, $107,000 was saved in the first year.
POC: Fort Bragg, NC, Danny Terry, DSN 236-3372.
Success: Success: Mountain Home AFB’s 366th Medical group operates a 28 bed/two operating room hospital. They out-sourced 15,000 lbs of red bag waste at a cost of approximately $10,000. Cost estimates for maintaining and running an incinerator exceeded these values.
POC: POC: Mountain Home AFB, ID, Mr. Bill Spoerer, DSN 728-4247

P2 Option: Effective Red Bag Waste Pollution Prevention Program

Success: Malmstrom AFB’s 341st Medical Group implemented a red bag waste program to minimize red bag waste being sent off-site. The program reduced the amount of brown bag waste put in the red bags and vice versa.
POC: Malmstrom AFB, MT, Tsgt Morris, DSN 632-3301.
Option: Reclassify the HMIWI as a "Pathological" Incinerator
Success: A pathological incinerator burns solely pathological wastes. "Pathological" waste is defined as: waste material consisting of only human or animal remains, anatomical parts and/or tissue, the bags/containers used to collect and transport the waste material, and animal bedding (if applicable). In a recent situation, a Texas AFB faced with installing monitoring devices on its medical waste incinerator received a Standard Exemption upon agreeing to combust only pathological wastes. By definition if an incinerator burns less than 10% medical waste it does not qualify as a medical waste incinerator
POC: Brooks AFB, TX, Capt. Kyle Blasch, DSN 240-3305
Option: Reclassify Incinerator Size Category
Success: Reclassifying the HMIWI to a smaller size designation can reduce the cost of add-on controls due to less stringent emissions guidelines. A source may, during its most recent performance test, change its size designation by establishing a "maximum charge rate" lower than its design capacity. Before seeking other reclassification the incinerator should first be classified as "rural" if it meets the criteria described below.
POC: Brooks AFB, TX, Msgt Jagielski, DSN 240-3305
Option: Reclassify Incinerator Category as "Rural"
Note: Before seeking other reclassification the incinerator should first be classified as "rural" if it is located at least 50 miles from the nearest Standard Metropolitan Statistical Area (SMSA) boundary and burns no more than 2,000 pounds of hospital waste and medical/infectious waste per week. The "rural criteria" stipulates that an HMIWI is allowed to meet alternative emission limits.

For purposes of these emission guidelines, the list of areas comprising each SMSA as of 30 June 1993 will be used to determine whether a small HMIWI meets the "rural criteria." The SMSA is defined by the Office of Management and Budget (OMB). The list of areas comprising each SMSA is presented in OMB Bulletin No. 93-17 entitled "Revised Statistical Definitions for Metropolitan Areas." This document may be obtained by contacting the National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161, or by calling (703) 487-4650 and requesting document No. PB 93-192-664. This document is available for public inspection and copying at EPA's Air and Radiation Docket and Information Center (Docket A-91-61, item IV-J-125).



4.2 Classified Waste Incinerators Industrial Combustion Coordinated Rulemaking (ICCR)

Option: Replace Incinerator with a Disintegrator.
Success: A classified waste incinerator was replaced with a disintegrator. The process has no air emissions. The disintegrator is adequate for paper and cardboard, but not for microfiche. Payback estimated in 20 months and annual savings of $26,321. Paper from the disintegrator can be recycled.
POC: Peterson AFB, CO, Dave Kource, DSN 834-7328

 

4.3 Municipal Waste Combustors Municipal Waste Combustor NSPS/EG

P2 Option: Remove batteries from the waste stream.

Planned: A machine that removes batteries from the waste stream is planned as an upgrade to the recycling facility. Removing batteries before incineration will reduce emissions of heavy metals.
POC: Fort Lewis, WA, Cynthia Trout DSN 357-4786

 

4.4 Treatment, Storage, Disposal Facility Hazardous Waste Combustor NESHAP

Research: Molten Salt Oxidation Technology

Indian Head Division, Naval Systems Warfare Center (NSWC), is conducting a demonstration study that uses molten salt oxidation (MSO) technology to treat and destroy hazardous and non-hazardous waste materials. Tests are being conducted on both energetic and inert materials. Indian Head Division, NSWC has installed, and is operating a remote small scale energetic molten salt oxidation unit. Indian Head Division has also designed and built the first energetic solid feed system to meter dry energetics into a MSO system.

Molten salt oxidation (MSO) is an innovative technology that can efficiently and effectively dispose of a wide variety of materials, and can be an alternative to open burning/open detonation. MSO is a process for treating wastes via reacting the material with an excess of air by injecting them into a molten salt bed. Sodium carbonate (Na2CO3) is the salt used in the molten bed at Indian Head.

Molten salt oxidation is ideal for demilitarization of waste materials, because the organic composition of the material is oxidized to carbon dioxide and water. Any halogens present in the feed, such as chlorine and fluorine, will form an acidic gas; however, the acidic gas will quickly be neutralized by the molten sodium carbonate salt to form its corresponding benign salt, e.g., sodium chloride or sodium fluoride. Dioxins will not form in the stack gases since the halogen has reacted, creating a salt. The remaining inorganic materials will collect in the molten salt bed, thus preventing them from entering the environment. The inorganic material can later be separated and than reclaimed or resold. The molten salt in essence oxidizes and scrubs the material in one stage. Molten salt oxidation has the advantage over conventional thermal treatment processes, because aqueous scrubbers used to remove corrosive acidic gases from the off-gas are not necessary for a MSO system. Furthermore, molten salt has excellent retention for metallic elements, which is of particular importance for hazardous metals such as cadmium, lead, and chromium. The salt, which retains these components, can be removed from the MSO unit and handled as a solid salt matrix; compared to handling of an ash or slag in the case of incineration.

At Indian Head, the demonstration program thus far has successfully treated composite and doublebase propellants, oils, carbohydrates, paints, cellulose, solvents and fuel oils. In addition, process equipment is being designed and tested to allow the commercialization of this technology. Indian Head is working with government laboratories, private industry, academia and DoD facilities to continue the advancement of molten salt oxidation technology.

POC: Indian Head Division, NSWC Indian Head, MD
Mark Heslop, (301) 743-4272/DSN 354

 

4.5 Boilers Executive Order 12902 Section 305
Sulfur Dioxide (SO2) NAAQS
Nitrogen Dioxide (NO2) NAAQS
Particulate Matter (PM) NAAQS

P2 Option: Switch From Using Fuel #6 To Fuel#2

Success: This has been extremely effective in reducing Camp LeJeune’s total air pollution emissions since 80% of total emissions at the installation are from boilers.
POC: Marine Corps Base, Camp LeJeune, Dennis Abel (910) 451-5063

P2 Option: Control Operating Procedures (NOx Optimization)

Success: The Portsmouth Naval Shipyard (PNS) operates four steam boilers fired with No. 6 fuel oil. Typically, if a facility is a major source and located in a nonattainment area reasonably available control technology (RACT) would be required, such as retrofit with low NOx burners and flue gas recirculation. Instead the shipyard was able to control their operating procedures as an alternative to an expensive retrofit and permitting protocol. PNS submitted a NOx control operating procedure as an alternative to expensive continuous emission monitors (CEMS) to satisfy the compliance assurance monitoring requirements of EPA'S Title V Operating Permit Program. Simple combustion modifications reduced emissions from above 0.5 pounds per million BTU of heat input to below 0.3 pounds per million BTU of heat input. The program focuses on two NOx reduction techniques: fuel biasing and low excess air firing. Each boiler requires its own fuel biasing and air firing procedure relative to firing capacity. For example, for boiler one, carbon monoxide (CO) and opacity were monitored to determine the impact of fuel biasing on complete combustion. Elevated levels of CO or opacity were not observed during this test condition. Ten percent fuel biasing had the effect of reducing the NOx emission rate to 0.35 pounds per million BTU of heat input. This iterative procedure was continued until the emission rate had been reduced to under 0.3 pounds per million BTU of heat input with acceptable CO and opacity levels. NOx optimization involves only the cost of implementing the program and maintaining the demonstrated adjustments.
POC: Portsmouth Naval Shipyard, Kittery, ME
Ralph Hickson (207) 438-1481/DSN 684

P2 Option: Convert Coal-Fired Steam Plant to Natural Gas

Success: The Puget Sound shipyard steam generating facility was fired with coal. Conversion of the plant to natural gas reduced criteria air pollutants by 286 tons, eliminated 7,400 tons of coal ash (solid waste), eliminated stack monitoring, and saved approximately $2,500,000 annually.
POC: Puget Sound Naval Shipyard, Bremerton, WA,
Clark Pitchford (360) 476-0124
Success: The Warren AFB coal-fired heating plant was converted to natural gas and retrofitted with low NOx burners. Conversion of the plant to natural gas reduced air quality compliance requirements, National Pollutant Discharge Elimination System (NPDES) requirements, as well as air emissions.
POC: FE Warren AFB WY, Mr. Robert Alexander DSN 481-5493

P2 Option: Retrofit to low NOx burners reduced sizing.

Success: Reduce sizing of boilers and use of low NOx burners reduced air emissions. Many boilers and generators at DoD installations are oversized. The larger combustion sources are less efficient and potential emissions are greater than smaller sources. Operating levels of external combustion units on installations should be scrutinized to determine if they have been oversized.
POC: Vandenberg AFB CA, Mr. Jim Rohr DSN 276-7541
Problem: An Air Force Base recently installed low NOx boilers to reduce criteria pollutant emissions. Unfortunately, the contract for installation of the boiler went to an inexperienced group. The boilers were repeatedly stack sampled, but never complied with the local standards. Reinstalling the boilers will be an expensive task and add to the costs of P2. The old saying "you pay for what you get" certainly applies in this case.
Problem: The Air Force Human Systems Center (HSC/OEBQ) has source sampled many types of P2 emission reduction technologies. Some of these technologies have not passed the emissions criteria claimed in the manufacturer literature. As a lesson, it is important to ensure that the manufacturers of P2 technologies are responsible for their products’ performance. This dilemma should be resolved before the technology is purchased and a contract mechanism should be established to provide for the case when the technology does not meet the stated criteria.

P2 Option: Replace Oil Hot Water Heaters with Propane Units

Success: As oil fired hot water heaters in a mobile facility reached the end of their useful life, they were replaced with propane units. There is not enough propane stored to cross the risk management thresholds of Section 112(r).
POC: Marine Corps Air Ground Combat Center 29 Palms, CA
Phil Chambers, (619) 830-5764/DSN 957

P2 Option: Convert from Oil to Natural Gas

Success: Buildings with old oil-fired boilers and furnaces are being converted to natural gas. At Fort Drum fuel conversion can yield a significant reduction in both cost and pollution. This is an area of the country with an average of 7601 heating degree days, a design temperature of -7 degrees, and with actual temperatures expected to reach -20 degrees each year and occasionally dipping as low as -40 degrees. Of the approximately 1200 older buildings on post, which are generally small and all oil fueled, approximately 100 were converted in the first round completed in fiscal year 1997. There were several motivations for this project:

1. Cleaner fuel. Most notably SO2 emissions are eliminated.

2. Cheaper fuel. Gas is purchased through a broker directly from the source. This is generally much cheaper than buying from the utility. However, the utility transports the fuel and is paid for this service.

3. Compliance. Executive Order 12902 Section 305 directs Federal agencies to take steps to reduce the use of petroleum in their buildings and facilities by switching to less polluting and non-petroleum based energy sources such as natural gas or solar energy.

4. Elimination of the delivery problem. Oil tanks were too often running dry, as the various contractors did not keep up with the demand.

5. Removal of underground storage tanks (USTs). This achieves compliance with regulations governing USTs and eliminates their associated liability.

6. Timing. Oil fired units are aging, with some as old as 20 years. When an oil furnace or boiler wears out before the building is retrofitted for gas, instead of installing new oil equipment, propane units are installed which can then be easily converted to natural gas when the gas lines get that far.

7. Efficiency. Replacing old oil units with new natural gas units increases the combustion efficiency from 75% to 90%. At the same time, automatic setback thermostats and zoned heating systems are being installed for further reductions in heating requirements. This adds up to lower fuel consumption, which means lower fuel costs and lower emission levels.

This first round of building conversions included 96 buildings, completed with about $2 million of P2 funds. The buildings selected for the change are those that meet three criteria. They are occupied year round, they have been retrofitted with insulation and energy efficient lighting, and they have been refurnished. It is hoped that about $1 million per year may be obtained to continue the conversion project. Funding sources are being explored such as construction, P2 and the Federal Energy Management Program (FEMP).

POC: Fort Drum, NY Steve Rowley DSN 341-5433

P2 Option: Efficient Energy Use Reduces Boiler Emissions

Success: The Air Force Materiel Command has instituted energy saving programs that reduce heating and electricity needs on base. The reduction in heating reduces boiler emissions.
POC: Wright-Patterson AFB, OH HQ AFMC/CEVC
Mr. James Ryckman, DSN 787-0093/5879

P2 Option: Geothermal Energy

Success: Geothermal energy is not an option for every installation, but a few have made good use of it. Naval Air Station China Lake is running large electricity generating turbines off of a geothermal field that is expected to last for 30 years. This was a public/private venture which will allow China Lake to sell electricity back to the power company when produced in excess of needs.
POC: Navy Geothermal Program Office, Code 83G000D
Dr. Frank Monastero (760) 939-4046/DSN 437

P2 Option: Geothermal Energy

Success: Fort Polk installed residential geothermal heat pumps (GHPs) that provide space heating, cooling, and humidity control. They may also provide water heating either to supplement or replace conventional water heaters. These systems work by moving heat, rather than by converting chemical energy to heat like in a boiler or furnace. In heating mode, a GHP extracts heat from the earth and distributes it to the building, or uses it to heat water.  Cooler air from the building is returned to the geothermal heat pump, where it cools the fluid flowing to the ground.  The fluid is then re-warmed as it flows through the heat exchanger buried deep in the ground. In cooling mode, the process is reversed.  The relatively cool fluid from the earth connection absorbs heat from the building and transfers it to the ground.

The Ft. Polk Joint Readiness Training Center has some 23,000 military personnel and family members living in on-post housing. The housing stock consists of 4,003 units in 1,296 buildings. About 80 percent of the units had air-source heat pumps and electric water heaters. The remainder were cooled by central air conditioning and heated by natural gas forced-air furnaces. Cooling is the main requirement in this area.

About half of the base’s energy bill has been for housing energy consumption. This project, including building envelope improvements, is expected to save about a third of residential energy costs. That translates into about $3.3 million annually in utility bills and maintenance over the 20-year life of the contract.

POC: Ft. Polk, LA, Environmental Engineering
Greg Prudhomme, (318) 531-6029/DSN 863

P2 Option: Cogeneration: Compressed Natural Gas Fuel Cell

Success: The Naval Hospital is almost completely powered by a compressed natural gas fuel cell which converts natural gas to electricity and heat. The system uses a cathodic system that reduces natural gas to water. The byproduct is a small amount of steam. In one year the facility has saved the base $60,000 in energy consumption not counting the added value of drastically reducing emissions. The fuel cell is extremely inexpensive to operate, and is expected to have a 5-6 year payback period.
Problem: The unit senses the air that comes into the unit and if the air is too dirty, the equipment shuts down. They located the fuel cell near emergency diesel generators, and when the emergency generators kick on, the fuel cell shuts down because of the amount of NOx in the air from the generators. This demonstrates the importance of considering emission sources when locating fuel cells.
POC: Marine Corps Air Ground Combat Center 29 Palms, CA
Phil Chambers, (619) 830-5764/DSN 957-5764

 

4.6 Vehicles PM and Ozone NAAQS
Executive Order 13031

Executive Order 13031 and the Energy Policy Act of 1992 direct Federal agencies to incorporate alternative fuel vehicles (AFVs) into their fleets. Typically, the biggest challenge of incorporating AFVs into the fleet is establishing a convenient source of alternative fuel. Natural gas is cleaner burning than most other alternative fuels. There are two types of natural gas fueling stations: rapid fill stations are much more expensive than slow fill ones, but there is also a difference in fueling times between minutes and hours. Slow fill is practical if the vehicles can be filled over night.

P2 Option: Install Compressed Natural Gas Station

Success: A Rapid Fill Compressed Natural Gas Station has been installed that has significantly reduced ozone precursors and PM. The station is also used by residents and businesses. This promotes a "good neighbor" image to the community. The facility is open 24 hours and is maintained by the Southern California Gas Company which funded and built the facility. MCAGCC 29 Palms provided the real estate for the facility which is significant to the overall partnering success.
POC: Marine Corps Air Ground Combat Center 29 Palms, CA
Phil Chambers, (619) 830-5764/DSN 957-5764

P2 Option: Alternative Fueled Vehicles - Compressed Natural Gas

Success: So far 80 Compressed Natural Gas bifuel vehicles have been added to Fort Hood’s GSA fleet of 500. Most of the CNG vehicles are light duty trucks at this time, with a couple of passenger vehicles. The GSA vehicles at Fort Hood average 1000 miles per vehicle per month, bringing the annual total up to around 6 million miles. If 15 percent of these miles are powered by natural gas, expected emission reductions would be 2.3 tons of carbon monoxide, 0.6 tons of nitrogen oxides, and 1.2 tons of non-methane hydrocarbons. The fueling station was put into service in 1996.
POC: Fort Hood, TX, GSA Motor Officer
Robert Chadwick, (254) 287-2225/DSN 737

P2 Option: Alternative Fueled Vehicles: Compressed Natural Gas

Success: To make a significant contribution to reducing local air pollution levels, Andrews AFB has embarked on an ambitious program to reduce the use of gasoline and reduce the emission of VOCs from base vehicles. Using a National Renewable Energy Laboratory (NREL) contract, the base has already converted 40 fleet vehicles from gasoline to a bi-fuel compressed natural gas (CNG) system.

The base has recently obtained funding from the Advanced Research Project Agency (ARPA), through the Robins Alternative Fueled Vehicle Systems Program Office (AFVSPO) to assist in converting 27 diesel powered vehicles to dual fuel use. This will enable the vehicles to use 80% CNG and 20% diesel fuel. The contract for the conversion was awarded with an estimated completion date of May 1996. Finally, Andrews AFB is currently working with NREL and AFVSPO to convert an additional 76 vehicles to CNG.

POC: Andrews AFB, MD Mr. Awni M. Almasri, DSN 858-2337

P2 Option: Alternative Fueled Vehicles - Solar charged electric vehicle

Success: An electric powered six-passenger Chrysler van was purchased in 1997. This vehicle has a maximum speed of 80 miles per hour and a range of 80 miles per charge. This range figure is somewhat diminished when air conditioning is required. The white color of the vehicle minimizes solar gain and thus air conditioning requirements.
POC: Yuma Proving Ground, AZ Jack Nixon, (520) 328-2198/DSN 899

P2 Option: Alternative Fueled Vehicles - Electric Bicycles for intrabase travel

Success: Electric bicycles are being introduced in the base in a partnership with Southern California Edison to stimulate alternate forms of transportation. This contributes to NOx reduction. Unfortunately, these do not count as AFVs in the official tally.
POC: Marine Corps Air Ground Combat Center 29 Palms, CA
Phil Chambers, (619) 830-5764/DSN 957-5764

 

4.7 Aerospace Ground Equipment Carbon Monoxide (CO) NAAQS
Nitrogen Dioxide (NO2) NAAQS
Particulate Matter (PM) NAAQS

P2 Option: Reduce emissions from Aerospace Ground Equipment (AGE), a.k.a.
Aerospace Ground Support Equipment (AGSE), Ground Support Equipment (GSE)

Success: March Air Reserve Base (ARB) is in an extreme nonattainment area for ozone with NOx being the prime air quality offender. AGE accounts for almost one-half of all NOx emissions at March ARB. Not knowing exactly how the equipment would be regulated, they wanted to proactively pursue ways to reduce emissions. They conducted a study and have published the following recommendations:

Develop a procedure to encourage the users to minimize AGE use. Users are to be made aware of how much they use the equipment in a quarterly memo to encourage buy-in from operators to use the equipment only when necessary. Estimated NOx reduction using this method is 10%.

Switch from diesel to JP-8 fuel. Both NOx and SOx are slightly reduced when using JP-8. Even though emission reductons are small, JP-8 is desirable from a logistical standpoint. It is no longer necessary to stock multiple fuels. Estimated NOx reduction using this method is 2%.

Plan emission tests. Use the results of emission tests to determine the optimum combination of fuel injector type and timing. Request a Technical Order (TO) waiver and implement. Testing is underway to change both the fuel injector type and the timing and comparing NOx emissions and modifying TOs accordingly. Estimated NOx reduction using this method range from 10 to 30%.

Experiment with powering two aircraft off a single AGE engine. The users are not in favor of this option because cables are heavy and bulky and aircraft parking and maintenance schedules would have to be adjusted, however there is potential for significant reductions. No near-term reduction of NOx is associated with this option.

Supply users with 20 sets of battery powered explosive-proof lights. Much of the AGE use was to power aircraft lighting at night. Users should be encouraged to use rechargeable lanterns instead of AGE for night lighting. A product such as Eveready No. 459 Lantern (NSN: 6230-01-102-7999) is recommended. The NOx reduction using this method is estimated at 20%.

Supply the users with two of the Army’s 15kW skid mounted generators for evaluation. There are many advantages of these smaller generators including reduced fuel consumption and quieter operation. However concerns over compatibility, deployability, user acceptance and cost must be evaluated before recommending full base-wide implementation. No near-term reduction of NOx is associated with this option.

  For the full report: SAIC
Glenn E. Rolader
1225 Johnson Ferry Road, Suite 100
Marietta, GA 30068-2767
POC: March ARB, Moreno Valley CA
Vistas Tijina, Air Quality Manager, (909) 655-4070

P2 Option: Install Low Emissions Injectors And Retarded Injector Timing (RIT).

Success: The Air Force is currently field testing different injectors and timing settings for A/M 32 AD-86 AGE. The modifications have shown an 80% reduction in NOx and other criteria air pollutants. This technology will be used at several different Air Force Bases to determine if any side effects or performance limitations occur.
POC: Brooks AFB, TX, Capt. Kyle Blasch or Mark Wade DSN 240-3305

PC Option: Emission-Control Technologies for Aerospace Ground Support Equipment

Success: The Air Force is currently field testing additional NOx reduction strategies along with the retarded-injector timing mentioned above. These technologies include selective-catalytic reduction (SCR) and exhaust-gas recirculation. The technologies are going through a final stage of development with hopes of significantly decreasing NOx emissions. This is pollution control (PC) rather than prevention.
POC: Wright-Patterson AFB OH
Jill Ritter (Easterly), (937) 255-3871 and Dr. Jim Reuter, (614) 424-7916

 

4.8 Generators Carbon Monoxide (CO) NAAQS
Nitrogen Dioxide (NO2) NAAQS

P2 Option: Solar Photovoltaic Electricity Generation

Source: Photovoltaics and batteries provide 2 kW to a meteorological station that is off the grid out in the desert. A 112 kW photovoltaic system is under construction at another off-grid site. Photovoltaics and batteries were obtained from elsewhere in the Army where a solar project was canceled. Some of the donated materials were traded for the construction of a facility with a power conditioning unit. Note that batteries used for this type of application are deep cycle (e.g. marine) batteries. In this case, because materials were donated for this site and because of the distance from the grid, installing solar power is cheaper than extending the grid.
POC: Yuma Proving Ground, AZ Jack Nixon, (520) 328-2198/DSN 899

P2 Option: Solar Power

Success: One third of the base’s NOx emissions comes from two 450 HP engines. These diesel generators run 24 hr/day. They are used to power moving targets at the tank firing range. In December 1997, installation of solar power to replace the generators was completed. Energy generation uses a 1 acre solar array of photovoltaic panels. It is an uninteruptable power supply with an inverter that converts DC power to AC. So far the project has proved to be highly successful.
POC: Marine Corps Air Ground Combat Center 29 Palms, CA
Phil Chambers, (619) 830-5764/DSN 957

P2 Option: Solar and Wind Energy

Success: The Mobile Power Center (MPC) is a prototype unit designed to test the feasibility of using solar and wind energy to supply electrical power to mobile Marine Corps units. The MPC was successfully demonstrated during the recent Marine Corps Hunter Warrior Advanced Warfighting Experiment (AWE) at Marine Corps Air Ground Combat Center (MCAGCC), 29 Palms, California. Performance data has been provided to representatives of the Combat Service Support Enterprise element of the Special Purpose Marine Air Ground Task Force for further correlation with user logs. An objective final report is expected from the Commandant's Warfighting Laboratory (CWL).

The system is constructed on a base which houses the main battery, DC/AC inverter, and control and monitoring equipment. The main source of power is a 3.42 kW solar panel array. The array is comprised of 3 banks of 6 solar panels which are supported by metal frames. A collapsible mast attached to the base supports a 1 kW wind generator.

POC: SPAWAR Systems Center, San Diego, Applied Technology Branch, Code D745 Dave Carlton (619) 553-3456, e-mail carlton@nosc.mil, http://manta.nosc.mil/~uhrich/mpc.html

 

4.9 Jet Engine Testing Engine Test Facilities NESHAP
CO, NO2, PM NAAQS

P2 Option: Reduce Engine Tests

Success: NAVAVNDEPOT Cherry Point has 22 jet engine test cells. The engines come from all branches of the Armed Forces to undergo performance testing and rework. Since emissions from test cells are significant, Cherry Point looked for P2 opportunities to reduce emissions. The goal was to reduce emissions and improve jet engine test cell operations with a corresponding reduction in jet engine test cell fuel usage, labor, and operation costs. Cherry Point considered applying P2 to test cells by decreasing the test cell reject rate. A reject occurs when a jet engine does not meet certain criteria of a test or fails mechanically. When a jet engine is rejected, it must be re-tested and pass a performance test before it can be reintroduced into production.

Cherry Point reviewed the achievements of the Propulsion and Power Engineering Department from the years 1991 to 1994. Significant improvements had been made to reduce engine-inherent test rejects as a result of regular wear and tear on a particular engine type. Reduction of rejects was accomplished by running the test cell through a series of maintenance checks that included such actions as vibration analysis, casing examination to restore clearances to "as new" conditions, and oil testing. They also adopted a Reliability-Centered Maintenance (RCM) philosophy that emphasized safety and operational goals in addition to the minimization of maintenance man-hours, material usage, and costs. They estimated that approximately 40 percent of the rejects were eliminated through the combination of these rigorous pretest checkouts and the RCM program.

In 1995, another review of operations was conducted, and a strategy to reduce emissions from test cells was considered for the overall P2 plan. The pollution prevention team and the Propulsion and Power Engineering Department considered letting a contract to collect data to further reduce the reject rate. The teams found that they did not need to let this contract because the Propulsion and Power Engineering Department continued to make improvements in reducing the reject rate. Improvements made since 1995 are as follows for a few of the engine types:

F402: Rejects over three years since 1995 revealed the main causes to be excessive vibration and low performance (high jet pipe temperature or low thrust). The reject rate was approximately 21 percent. In 1995, the Propulsion and Power Engineering Department established a research project with North Carolina State University to develop an engine diagnostic method to better identify the causes of excessive F402 engine vibration. This resulted in the establishment of the computer based "Diagnostic Engine Vibration System" now operational in the F402 test cell and the installation of an additional vibration transducer on the engine during the test. Results of the use of this system have been positive, allowing better isolation of the discrepant component causing the excessive vibration. The reject rate is anticipated to decrease in the future with the use of this system and the accumulation of historical vibration reject data. Low performance has been addressed by the introduction of improved rework and assembly procedures required by a Local Engineering Specification.

T58: Efforts have focused on elimination of the primary degraders including low power, oil leaks, and oil consumption. There have been dramatic results. Rejects were reduced by 75 percent. There is also a new Data Reduction Program for each test cell installed. This provides the tools to isolate problem components in reject engines.

Auxiliary Power Units (APUs): Efforts have been made to reduce test cell time and reject rate for all models of APUs. Although the test cell reject rate is higher than the ideal, it is about 30 percent lower than it was in 1994. Data on test cell rejects, corrective actions, and resolution of problems (statistical process control data being collected in the shop) is currently being kept. They are working with shop and Quality Evaluation personnel to try and organize the information better to assist with further reducing the reject rate.

As of early 1998, fuel usage records have been fully automated for 6 of the 22 test cells. It is anticipated that all test cells will be fully automated by the end of 1998. Software tracks the type of engine, duration of each engine run and the amount of fuel used.

Technical directives to the shop have cut the rejections to a minimal level. Test cell rejects of engines will continue although significant reductions in the reject rate have been achieved. Emission control devices may have to be considered to further decrease emissions.

POC: NADEP Cherry Point, NC Clifton Game, (919) 464-7690/DSN 582

 

5. STORAGE

 

5.1 Listed Substance Storage Accidental Release Prevention Program
(Risk Management Programs and Plans)

P2 Option: Eliminate The Use And Storage Of Substances Listed Under The Accidental Release Prevention Program

Success: Chlorine and sulfur dioxide were eliminated. Eight one ton cylinders of chlorine and four one ton cylinders of sulfur dioxide were used in treating water at a Sewage Treatment Plant. These quantities of materials trigger the threshold for the Risk Management Program. They have changed their system to use ultraviolet light and sand filters to process wastewater at the sewage treatment plant.
POC: PWC Pearl, Pearl Harbor, HI Darren Chun, (808) 471-4189
Success: Chlorine used to treat wastewater was eliminated by using ultraviolet light and advanced oxidation at the oily wastewater treatment plant.
POC: Naval Station Mayport, FL Bob Tierney (904) 270-6730

P2 Option: Reduce or Divide the Storage of Chlorine (or other listed substances)

Success: A number of installations are reducing the risk of harm to people and the environment by reducing the amount of listed substances stored in one place. Alternately, the same benefit can be achieved by dividing up storage so that only an amount below the threshold is located in one place or in such a way that it could be involved in a single catastrophic event. This both reduces the risk and eliminates the need to develop a Risk Management Program and Plan.

 

6. TRAINING

 

6.1 Fire Fighting Training Particulate Matter (PM) NAAQS - Fugitive Emissions

P2 Option: Reduce The Amount Of Soot Emitted During Fire Fighting Training

Success: PM contributors are being reduced at the Fire Fighting Training Facility at the Expeditionary Air Field. Fuel additives allow a 90% decrease in the amount of soot emissions. This technology was originally developed in Kuwait during Operation Desert Storm where soot suppressant contributed to the success of the war. The MCAGCC 29 Palms is doing additional testing at the installation. The fires still burn hot and dark which is necessary for training purposes, but yet show drastic reductions in the amount of soot emitted.
POC: Marine Corps Air Ground Combat Center 29 Palms, CA
Phil Chambers, (619) 830-5764/DSN 957

 

6.2 Field Training Exercises Particulate Matter (PM) NAAQS – Fugitive Emissions

P2 Option: Reduce the Amount of Dust During Field Training

Success: Particulate matter (PM) contributors are being reduced during off road vehicular travel in a number of ways. Tank travel has been narrowed using railroad ties. Native vegetation has been planted in rutted areas to help stabilize the soil. Soil stabilization projects are in place to prevent PM. Soil stabilizers are used on roadways, roadway access points, edges of roadways, parking lots, and turnouts. The stabilizers work better and are cheaper than asphalt (stabilizers cost approximately 4 cents/square foot). They have found soil penetration as deep as 10 inches when using the correct mixture of water. Stabilizers seem to work best where there are 20% fines existing within the soil.
POC: Marine Corps Air Ground Combat Center 29 Palms, CA
Phil Chambers, (619) 830-5764/DSN 957

 

Research: Use Dust Control Agents
Findings: Five dust control agents were chosen to study at three installations. These dust control agents ranged in price from $0.28 to $0.70 per square yard applied.

 

Agent Composition
Dust-Fyghter 38% CaCl (absorbs moisture from the air)
Lignin calcium lignosulfonate
SoilSement polyvinyl acrylic polymer emulsion
SoyaSeal6 soybean feedstock processing by-products
Top Seal polyvinyl acrylic polymer emulsion

Results of dust deposition and dust obscuration tests are included in a report called Dust Control Material Performance on Unsurfaced Roadways and Tank Trails published by the U.S. Army Environmental Center and the US Army Corps of Engineers, September 1996.

POC: Army Environmental Center hotline, (800) USA-3845 or (410) 671-1699/DSN 584

P2 Option: Helicopter Rotor Washout Control

Success: A soil conservationist at Fort Rucker developed an effective way to turn a patch of flying dirt into a stable landing pad. Large crush rock is spread in the washout area. This holds everything in place. The rocks must be large enough so they will not get caught up in the air currents. After a while, vegetation will begin to grow through the rocks, increasing the stability of the soil.
POC: Fort Rucker, AL Mr. Delarie Palmer (334) 255- 9363/DSN 558

 

6.3 Weapons Training at Firing Ranges Lead NAAQS

P2 Option: Reduce The Amount Of Lead Dust During Weapons Training

Success: Bullets (lead) fired from weapons impact a dirt berm. Lead emitted during firing and other lead already embedded within the berm stirred up on impact cause significant lead dust emissions. Typically installations clean up berms after extended periods of time (often as long as 30 years). This also contributes to significant atmospheric loading of lead. Backloaders and other heavy equipment dig up the berms for removal which contributes to lead emissions and excessive worker exposure to lead. MCAGCC 29 Palms is in the process of incorporating a range management plan where berms are serviced at the maximum of every three years. A system is being installed to capture lead after they are fired into collection facilities located behind the target after penetration of the target. A water mister is being sprayed across targets to knock down lead dust as the lead impacts collectors. Berms are being constructed in a concrete basin and painted with an epoxy paint to ensure runoff does not pollute groundwater. What is essentially a baghouse is also being installed over targets to draw in lead contaminated air.
POC: Marine Corps Air Ground Combat Center 29 Palms, CA
Phil Chambers, (619) 830-5764/DSN 957-5764
Research: "Green Bullets"

The Department of Defense is addressing the issue of hazardous materials in the manufacture and use of small caliber ammunition. The Army’s Armament Research, Development and Engineering Center (ARDEC) Small Caliber Ammunition Branch is looking for ways to reduce or eliminate ODSs, VOCs, and heavy metals in the manufacture of primers and projectiles in small-caliber ammunition.

POC: US Army ARDEC, Mr. Wade Bunting, DSN 880-6040
Research: P2 on Ranges

The U.S. Army Environmental Center (USAEC) conducts demonstration and evaluation projects through the Range XXI program, which is the environmental component of Force XXI, designed to bring warfighting into the 21st century. Pollution prevention, maintenance, and remediation technologies and techniques are being demonstrated and evaluated in 5 thrust areas:

  1. Small Arms Range Technology (soil washing; bullet traps; Range Management Manual; Range Evaluation Software Tool; Army Sampling and Analysis Plan)
  2. Impact Area Design and Management (preventing erosion and lead migration; unexploded ordnance (UXO) management)
  3. Training Area Sustainment (dust control; land based carrying capacity; tactical concealment areas; VegSpec computer-based tool)
  4. Acquisition Support (non-toxic ammunition, such as a non-toxic, tungsten-based alternative to the current 556 round)
  5. Training and Test Emissions Management
POC: For information, fact sheets, reports, or software, contact the USAEC:
(800) USA-3845
t2hotline@aec.apgea.army.mil
http://aec-www.apgea.army.mil:8080/

 

7. MISCELLANEOUS

 

7.1 Ethylene Oxide Sterilizing State-Specific Regulations

P2 Option: Plasma Sterilization Technologies

Success: Ethylene oxide (EtO) has been used extensively as a medical equipment sterilant. However, EtO is highly explosive in nature and therefore it has traditionally been mixed with a carrier agent, CFC-12 (Freon), which is an ODS. Because of the carcinogenicity of ethylene oxide and ODS phaseout required under the Montreal Protocol, researchers sought alternatives. In 1994 the Food and Drug Administration (FDA) approved the process known as "Hydrogen Peroxide Plasma Sterilization", which is marketed under the trade name STERRADTM. In 1995 the FDA approved Peracetic Acid Gas/Plasma technology which is marketed under the trade name PLAZLYTETM. There are a number of STERRADTM units in use throughout the Services. The cost for either of these safe, effective units is $100,000. Both the Navy Medical Logistics Command and Bureau of Medicine (BUMED) Environmental Programs are looking for a way to phase out all existing medical ethylene oxide sterilizers.
POC: Navy Environmental Health Center, Norfolk, VA
Bill Rodgers, (757) 363-5546/DSN 864

References:

  1. Fire Hazard from Carbon Adsorption Deodorizing Systems, EPA 550-F-97-002E, May 1997.
  2. EPA Memorandum from John Seitz to Regional Air Toxics Coordinators, Subpart O-Ethylene Oxide Commercial Sterilization Plant Explosions, 29 July 1997.

P2 Option: Out-Source

Success: STERRADTM units have their advantages, but are not able to sterilize all the items that an ethylene oxide sterilizer is capable of sterilizing. Wilford Hall Medical Center is out-sourcing the items its STERRADTM and its steam units are not able to handle. Unfortunately this is not the greatest example because they are out-sourcing the items to Brooke Army Medical Center at Ft. Sam Houston. The STERRADTM design is improving. Newer models are expected to handle more items. Its newer version is pending FDA approval. Until then, any items needing sterilization may need to be out-sourced.
POC: Wilford Hall Medical Center, San Antonio, TX
Captain Deedecker (210) 292-5675

P2 Option: Steam Sterilization

Success: Wilford Hall Medical Center is using steam as an alternative for items that need to be disinfected but not fully sterilized. This reduces the amount of items needing to be sent through the ethylene oxide sterilizer.
POC: Wilford Hall Medical Center, San Antonio, TX
Captain Deedecker (210) 292-5675

 

7.2 Fuel Dispensing VOC and HAP Emissions

P2 Option: Stage II Vapor Recovery System

Success: Fuel dispensing from Government owned facilities and from on-base fueling stations is a large source of VOCs and organic HAPs. Many states in nonattainment regions are already required to use stage II vapor recovery systems because of VOC reduction goals. Eleven pounds of VOCs are emitted for every 1000 gallons of MOGAS dispensed. Stage II vapor recovery can provide a range of control from 88%-99%. Stage II vapor recovery will also provide a reduction in total HAPs from the base. Malmstrom AFB and Mountain Home AFB used stage II vapor recovery at their fuel dispensing facilities as a means to stay under the HAP major source threshold. By maintaining HAP levels (potential and actual) below major source thresholds, these bases do not fall under the costly Aerospace NESHAP. Installation costs for stage II vapor recovery depends on the fuel dispensing facility.
POC: Malmstrom AFB Mr. Dave Heckler, DSN 632-7099 or
Mountain Home AFB Mr. Bill Spoerer, DSN 728-4247

 

7.3 Pesticides VOC and HAP Emissions

Background: Pest Management

The Armed Forces Pest Management Board is the DoD group which addresses pest management issues, forms DoD policy, and makes a unified effort to meet the DoD 50% pesticide use reduction goals. The term "pesticide" generally refers to insecticides, rodenticides, herbicides, fungicides, and antimicrobial pesticides. Pest management experts are found within the military community both in engineering and in preventive medicine as pest control issues relate to grounds maintenance as well as disease prevention. There may be certified pesticide applicators employed by the installation as a whole or by the MWR for the golf course. Examples of P2 range from Air Force efforts to avoid the need for pesticides by developing the population of martins (birds which eat mosquitos) to Army efforts to use alternative pest control methods in food handling facilities.

POC: Army Environmental Center hotline, (800) USA-3845 or (410) 671-1699/DSN 584

P2 Option: Alternative Pest Management Methods

Success: Air Mobility Command is using several methods to reduce use of pesticides containing VOCs and HAPs. A reduction in fungicide use was accomplished through use of resistant turf types and proper care. Steam and hot water are being used for weed control (which, by the way, also works for fire ants). Mechanical devices are also being used for weed control. This eliminates VOCs but replaces it with combustion emissions. Andrews AFB is using a joint sealant to prevent and reduce weed infestation
POC: Scott AFB IL Maj Alan R. IIOlek (618)256-5704 ext.347/DSN 576

P2 Option: Aqua Heat for Weed Control

Success: Langley AFB is experimenting with heated water treatments to reduce weed growth. The testing is at its beginning stages, but could prove effective.
POC: Langley AFB VA, Mary Ruth Senn (757) 764-3324/DSN 574

P2 Option: Biological Control of Noxious Weeds

Success: Fairchild AFB is experimenting with the use of biological controls to reduce the quantity of noxious weeds. The biological controls are a substitute for sprayed herbicides possibly high in VOCs.
POC: Fairchild AFB WA 92 CES/CEVN
Gerald Johnson (509) 247-2313/DSN 657

P2 Option: Integrated Pest Management (IPM) at Golf Courses

Success: Golf Courses receive from 25% to 65% of pesticide use at an installation in terms of active ingredients. The Army has about 108 golf courses and has an active golf course Integrated Pest Management (IPM) program. IPM uses a variety of materials and methods to control pest populations while minimizing the quantity and toxicity of the active ingredients. Pesticide usage reduction can generally be achieved through product substitution, changes to application schedules (e.g. applying as needed instead of on a schedule), and using innovative physical or biological controls. Golf courses that have taken part in the program have seen significant reductions in pesticide use. Exact reduction amounts have not yet been determined but a preliminary estimate is that typical reductions for the golf courses that have participated so far is about a one-third reduction on average.
POC: US Army CHPPM Tom Harkins (410) 671-3613/DSN 584

 

7.4 Lubricants VOC and HAP Emissions

Background: Alternative Chemicals

Lubricants are a vital part of normal maintenance operations and must be available for aircraft maintenance; however, various lubricant products often contain ozone depleting substances (ODS) and Environmental Protection Agency 17 priority pollutants (EPA-17) in product formulations or for use as lubricant propellant and carrier solvents. Lubricants of particular concern for Ogden ALC are solid film lubricants (MIL-L-46010, MIL-L-23398, MIL-L-46147), release agents (MIL-L-60326), and penetrating oils (A-A-50493).

The Montreal Protocol and subsequent Federal statutes (e.g. Title VI of the Clean Air Act Amendments of 1990) and regulations have resulted in the implementation of a ban on the production and importation of Class I ODSs. In addition, the Aerospace NESHAP requires the reduction of hazardous solvents used at facilities such as Ogden ALC. Solvents covered by the NESHAP include: methylene chloride, toluene, xylene, and MEK.

Due to Federal legislation, Air Force policy, product availability constraints, and air permitting issues, there is a need to identify and/or develop new solid film lubricants, release agents, and penetrating oils which do not contain ODS and EPA-17 constituents. Identification of alternatives will allow the replacement of products which contain ODSs and minimize EPA-17 chemicals from maintenance and repair activities.

Research: Lubricants

The Air Force has two projects under development. The objectives are: (1) documentation and discussion of existing replacements for solid film lubricants (MIL-L-46010, MIL-L-23398, MIL-L-46147), release agents (MIL-L-60326), and penetrating oils (A-A-50493), and (2) documentation and discussion of potential replacements.

Existing Replacements for Solid Film Lubricants, Mold Release and Penetrating Oils

Specification changes and the introduction of alternative propellant systems and carrier solvents have eliminated most ODSs from several lubricant products. In addition, product reformulation has eliminated EPA-17 chemicals from certain lubricants. Table 7.4.1 provides a summary of the available products that are ODS/EPA-17 free. Note that there are currently several alternative products available for mold release agents (MIL-L-60326) that do not contain ODS and EPA-17 constituents. However, the military specification continues to contain reference to ODS. The specification needs to be updated to remove this reference and allow alternative products to be used.

Table 7.4.1: Existing Replacements For Lubricant Products

Military SpecificationSpecification Title

Vendor

Description

 
MIL-L-46010, Type III Lubricant, Solid Film, Heat Cured, Corrosion Inhibiting 1. Sandstrom Products, #099
Port Byron, IL
(800) 747-1084

2. E/M Corporation,
West Lafayette, IN
(317) 497-6100

MIL SPEC compliant; ODS/EPA-17 free
MIL-L-23398 Lubricant, Solid Film, Air Drying, Corrosion Inhibiting 1. Mr. Zip Graphite
American Grease Stick Company
Muskegon, MI
(800) 253-0403
MIL SPEC compliant, ODS/EPA/17 free
MIL-L-60326 Lubricant, Fluorocarbon Telomer Dispersion (for use with ammunition) 1. Miller-Stephenson
Danbury, CT
(203) 743-4447

2. Sprayon Products
300 Sries
Solon, OH
(800) 777-2966

3. Camie
St. Louis, MO
(314) 968-3222

ODS/EPA-17 free; Aerosol, Dip, Spray, and Brush / substrate specific products.

ODS/EPA-17 free




ODS/EPA-17 free

A-A-50493 Penetrating Oils 1. Kano Laboratories, Aerokroil
Nashville, TN
(615) 833-4101

2. Octagon Processing
Edgewater, NJ
(201) 945-9400

 

Potential Replacements for Solid Film Lubricants (MIL-L-46147 and MIL-L-23398)

A potential replacement product has been identified for solid film lubricants. Currently, the potential replacement products approved for MIL-L-46147 typically contain lead (<10%), methyl ethyl ketone (<10%), xylene (<10%) and methylene chloride (>50%), while the products approved for MIL-L-23398 contain lead, methyl ethyl ketone, xylene, and toluene. Manufacturer claims indicate that the product was designed to meet MIL-L-46147 and MIL-L-23398; however, the product has not been tested and is not accepted for military use. A review of the MSDSs for this product was conducted, and a summary of the hazardous consitituents is identified.

Table 7.4.2: Potential Replacement For Solid Film Lubricant (MIL-L-46147 and MIL-L-23398)

Tiodize, 15701 Industry Lane, Huntington Beach, CA 92649, (714) 898-4377

Material

Hazardous constituents

CAS Number

Tiolube 75/75

Molybdenum Disulfide

Sb203

1317-33-5

1309-64-4

 

POC: Hill AFB, UT Mr. John Vidic, (801) 777-2050

 

7.5 Adhesives and Sealants Ozone NAAQS (measured in VOCs and NOx)
Aerospace NESHAP

P2 Option: Alternative Chemicals

Sources:
  1. The Air Force Pollution Prevention Pillar Needs Assessment Report for FY 96, Wright Laboratory Pollution Prevention Customer Focus IPT, Volume 1-3, Wright-Patterson AFB Ohio, July 1996.
  2. Hill AFB, UT Mr. John Vidic, (801) 777-2050

The current regulatory drivers governing the use of adhesives and sealants at Federal facilities are: executive orders, DoD policy, Defense Authorization Act Requirements and Service level policy. These documents have (1) removed DoD exemptions from environmental regulation and (2) set goals for elimination or reduction of the use of various classes of materials (ozone depleting substances and the EPA-17 industrial toxics) and the disposal of hazardous waste.

In addition, the EPA has promulgated the Aerospace NESHAP which imposes strict emission limits on a variety of cleaning, coating, and depainting processes. Table 7.5.1 provides definitions and allowable VOC limits for the NESHAP specialty coatings pertaining to adhesives and sealants. A study by the Aerospace Industries Association indicates that a vast majority of commercially available adhesives and sealants currently meet the requirements of the Aerospace NESHAP. Adhesives and sealants in use at Ogden (OO-ALC) must be individually examined to determine which products need to be replaced.

John Vidic, OO-ALC, provided a list of adhesives and sealants used at Ogden ALC. In general, most of the adhesive systems are currently compliant with all existing and pending regulations. Several adhesives contain EPA-17 materials or HAPs. Of primary concern are the sealants and their continued reliance on solvents (high VOC) and heavy metals, especially chromium as a corrosion inhibitor.

Reformulated MIL-SPEC Sealants

Significant progress has been made to develop less hazardous products for the following MIL-SPEC materials:

Table 7.5.1: Selected Specialty Coatings from the Aerospace NESHAP

Adhesives RACT VOC Limit Comments
Commercial Interior Adhesives 6.34 lb./gal,
760 g/l
Materials used in the bonding of passenger cabin interior components. These materials must meet FAA fire worthiness requirements.
Cyanoacrylate Adhesive 8.51 lb./gal,
1020 g/l
A fast setting, single component adhesive that cures at room temperature. Also known as "super glue".
Fuel Tank Adhesive 5.71 lb./gal, 620 g/l Materials used in the bonding of passenger cabin interior components. These materials must meet FAA fire worthiness requirements.
Non-structural Adhesive 3.00 lb./gal, 360 g/l A material that bonds non-load bearing aerospace components and is not covered in any other specialty adhesive category.
Rocket Motor Bonding Adhesive 7.43 lb./gal,
890 g/l
Quick setting contact cements that provide a strong, yet flexible bond between two mating surfaces that may be of dissimilar materials.
Rubber Based Adhesive 5.84 lb./gal,
700 g/l
Quick setting contact cements that provide a strong, yet flexible bond between two mating surfaces that may be of dissimilar materials.
Structural Autoclavable Adhesive 0.50 lb./gal,
60 g/l
An adhesive used to bond load carrying aerospace components and is cured by heat and pressure in an autoclave.
Structural Non-autoclavable Adhesive 7.09 lb./gal,
850 g/l
A material that bonds non-load bearing aerospace components and is not covered in any other specialty adhesive category.
Sealants RACT VOC Limit Comments
Extrudable/
Rollable Sealants
1.66 lb./gal,
200 g/l
A material used to prevent the intrusion of water, fuel, air or other liquids or solvents from certain areas of aerospace vehicles or components.
Brushable Sealants 2.00 lb./gal,
240 g/l
Sprayable Sealants 5.01 lb./gal,
600 g/l

Waste Minimization Techniques for Adhesives and Sealants

Segregation of Nonhazardous Waste: Currently, 90+% of the sealants used at Northrop Grumman's St. Augustine facility are nonchromated sealants. Recently the company initiated a program to segregate the nonchromated sealants from the hazardous waste stream. This resulted in a 75% reduction in the quantity of sealants disposed of as hazardous waste.

Another Northrop Grumman facility has initiated a similar program where non-hazardous sealants are identified at the point of issue to allow disposal as a nonregulated waste. Hazardous sealants are now being packaged in colored containers. Each container color corresponds to a specific disposal procedure for the unused material. These simple measures have significantly reduced the volume of hazardous waste from sealant usage.

Minimize Material Usage: Controlling the volume of adhesive/sealant prepared for an application is another way to reduce waste. Proportional dispensing allows the technician to catalyze/mix only the amount required to perform the required task. This technique is currently used at Boeing Aerospace for several paste adhesive applications with a reported higher productivity and huge cost savings. Northrop Grumman is currently investigating a similar technique for dispensing of sealants.

One system being considered is Mixpac® from ConProTec, a hand held mixing/dispensing system. A two part adhesive/sealant system is placed in cartridges (cartridges are sized to provide a variety of mix ratios) which are squeezed by the mixing gun. The two parts are then mixed in a static mixing tube and dispensed in the amount needed. The only waste is the residual adhesive/sealant remaining in the mix tube, which after hardening will be disposed of in the appropriate waste stream.

Source: McGinnis, Karen and Gary Benham, "Hand Held Dispensing Equipment Reduces Waste and Saves Cost", Adhesive Age, October 1991

Minimize Issue Quantity: Where possible, reduce the size of the issued product to the minimum quantity needed to accomplish a given task. For example, Northrop Grumman used an eight ounce frozen premixed sealant for protecting rivets and fasteners. Typically, 40-80% of the sealant would not be used and would be disposed of as waste since once thawed, it had a limited pot life. The supplier was asked to provide the product in one ounce tubes. Minimizing the issue quantity resulted in a 60% drop in waste produced.

Current Research Efforts

Society of Aerospace Engineering (SAE) Committee: The G9 Sealant committee is working in the following areas: Polythioether fuel tank sealant (Draft G 989BT), integral fuel tank sealing compound (ams 3276), high strength polysulfide sealant (ams 3269), access door sealant (ams 3374a), silicone fire wall sealant (ams 3374a), windshield sealant (draft g 990ae), electrically conductive corrosion inhibiting sealant (draft g 992ah), and low density (specific gravity of 1.3) sealant (draft g 993ba).

Tinker Air Force Base's 1995 Study to Consolidate Adhesive-Sealant-Coating (Paint) Systems: Tinker AFB contracted with Battelle to produce a prototype expert system to identify and select alternative/superior adhesive-sealant-coating (ACS) systems. The system is designed to address the following: (1) identify materials with environmental and/or health concerns, (2) minimize the number of products in-stock by consolidating similar systems and (3) identify substitutes for out-of-stock products called out in documentation.

The project was performed in three phases. The first phase included collection/categorization of information pertaining to adhesives, sealants and coating systems. In Phase II, Battelle created a database for the selected materials including physical properties and performance characteristics. Using this database, a search engine was used to compare ACS systems and make recommendations for alternative products. These recommendations were then verified by experimentation. The final phase of the project was optimization of system performance to improve the reliability of the recommended replacements.

Sealant Manufacturer’s Initiatives: Sealant manufacturers are busy reformulating a number of products that are undergoing evaluation by the aerospace industry. Two efforts to note are those of Courtaulds Aerospace and Douglas Aircraft.

Courtaulds Aerospace has published a list of less hazardous replacements for several of their products. See Table 7.5.2. Douglas Aircraft has reported the results of qualification tests of non-chromated MIL-S-8802 and MIL-S-81733 products. Douglas identified the MIL-S-8802 approved product as Courtaulds PR1422 (chromated). Non-chromated candidates evaluated include: Morton MC237, Flamemaster CS5540, Fiber Resin PS2082, and Morton MC730. Douglas also reported the currently approved MIL-S-81733 products are Morton 665 (contains strontium chromate) and Proseal 870 (contains manganese chromate). A non-chromated alternative, Morton MC730, was reported to have failed the dissimilar metal test. For the results of these tests please contact Leyland Bruce at Douglas Aircraft Company.

Table 7.5.2: Courtaulds Aerospace - Product Substitution Reference

PRODUCT CHEMICAL SYSTEM REPLACES APPLICATION BENEFITS MIL SPEC OEM SPEC
PR-1428 MANGANESE DIOXIDE CURED POLYSULFIDE PR-1321, P/S 706, PR-1403G FUEL TANK ACCESS DOOR (FORM-IN-PLACE) GASKET CHROMATE FREE, WORKER/ENVIRONMENTALLY FRIENDLY, FAST CURE, HIGH REMOVABILITY MIL-S-8784  
PR-1429 MANGANESE DIOXIDE CURED PERMAPOLEâ P-5 PR-1223, PR-1224, PR-1227 AIRCRAFT INTERIOR FLOOR BOARD GAP/DEPRESSION FILLING & SMOOTHING APPLICATIONS LEAD FREE, LOW SPECIFIC GRAVITY, HIGH TEMPERATURE CAPABILITY, EXCELLENT REMOVABILITY & REPAIRABILIY    
PR-1758 MANGANESE DIOXIDE CURED PERMAPOLEâ P-5 P/S 899, PR-1750 AUTOCLAVE COMPATIBLE, BRUSHABLE FAYING SURFACE SEALANT HIGH SOLID (NVM 99%), HIGH TEMPERATURE RESISTANT (182 C), LOW VISCOSITY
(50 PA - S)
   
PFI-1758-G MANGANESE DIOXIDE CURED PERMAPOLEâ P-5 P/S 870, PR-1436G, PR-1422G AUTOCLAVE COMPATIBLE, CORROSION INHIBITIVE, BRUSHABLE FAYING SURFACE SEALANT CORROSION INHIBITIVE, HIGH SOLID (NVM 97%+), LOW VISCOSITY, HIGH TEMPERATURE RESISTANT (182 C)   FMS 3055
PR-1764 MANGANESE DIOXIDE CURED PERMAPOLEâ P-3 P/S 872 EMI/RFI SHIELDING, CORROSION INHIBITIVE APPLICATIONS CORROSION INHIBITIVE, HIGH TEMPERATURE RESISTANT (204 C), INSULATION RESISTANT, FUEL RESISTANT AMS 3266  
PR-1765 MANGANESE DIOXIDE CURED PERMAPOLEâ P-5   LIGHTNING STRIKE ADVANCED COMPOSITE APPLICATIONS EXCELLENT ELECTRICAL CONDUCTIVITY, HIGH STRENGTH, FUEL RESISTANT   DAN-1273
PR-1766 MANGANESE DIOXIDE CURED PERMAPOLEâ P-2   EMI/RFI SHIELDING, CORROSION INHIBITIVE APPLICATIONS CORROSION INHIBITIVE, GOOD PHYSICAL PROPERTIES, FUEL RESISTANT    
PR-1768 SILICONE ELASTOMERS   EMI/RFI SHIELDING, CORROSION INHIBITIVE APPLICATIONS CORROSION INHIBITIVE, EXCELLENT RESILIENCE AND COMPRESSION SET (22%)   RAY-THEON G472295, MIS-461 75
PR-1770 MANGANESE DIOXIDE CURED PERMAPOLEâ P-5 P/S 899, PR-1750 HIGH TEMPERATURE, HIGH STRENGTH, INTEGRAL FUEL TANK SEALANT HIGH TEMPERATURE RESISTANT (204 C), HIGH SOLID, EXCELLENT TENSILE/PEEL STRENGTH PROPERTIES AMS G9-90AG MS 426
PR-L775 MANGANESE- DIOXIDE CURED PERMAPOLEâ P-5 P/S 870, PR-1436G NON-CHROMATE CORROSION INHIBITIVE APPLICATIONS NON-CHROMATE CORROSION INHIBITIVE ADDITIVE, CRACK-GROWTH INHIBITION, WORKER/ENVIRONMENTALLY FRIENDLY, ENHANCED PHYSICAL PROPERTIES, HIGH TEMPERATURE RESISTANT AMS G9-9OBC  
PR-1776 MANGANESE DIOXIDE CURED PERMAPOLEâ P-5 P/S 890, P/S 899, PR-1440, PR-1750 WEIGHT SAVING, INTEGRAL FUEL TANK SEALANT WEIGHT SAVING (SP. GR.: 1. 30), HIGH STRENGTH PROPERTIES, EXCELLENT FUEL RESISTANCE   BMS 5-45
PR-1778 MANGANESE DIOXIDE CURED PERMAPOLEâ P-5 PR-1425, PR-380, PR-383 NON-CRAZING WINDSHIELD SEALANT HIGH SOLID, HIGH STRENGTH, HIGH TEMPERATURE RESISTANT (182 C, 80 HOURS) MIL-S-11031  
PR-1825 EPOXY CURED PERMAPOLEâ P-3 PR-1426, P/S 860 QUICK REPAIR OF INTEGRAL FUEL TANK; MILITARY AIRCRAFT BATTLE DAMAGE REPAIR APPLICATIONS ULTRA-FAST CURE, UNAFFECTED BY RELATIVE HUMIDITY, FAST LOW-TEMPERATURE CURE (12 HOURS @ 4 C; 3 HOURS @ 25 C),    
PR-1826 EPOXY CURED PERMAPOLEâ P-3 P/S 890, P/S 899, PR-1440, PR-1750, PR-1422 FAST CURE INTEGRAL FUEL TANK SEALANT; CABIN PRESSURE SEALING APPLICATIONS; AVAILABLE IN BRUSH (CL A) AND FILLET (CL B) GRADES TAST CURE (CURED IN 3 HOURS), HIGH TEMPERATURE RESISTANT (204 C, 10 HOURS), BROADER SERVICE TEMPERATURE RANGE (42 C TO 149 C) MIL-S-29574 TYPE I MS 404, FMS 3064, BAC 5504
PR-1826-G EPOXY CURED PERMAPOLEâ P-3 PR-1422-GB, PR-1436-GB, P/S 870 B RAPID CURE, CORROSION INHIBITIVE, FILLET SEALING APPLICATIONS FAST CURE (TACK FREE IN 1 HOUR), CORROSION INHIBITIVE, LOW TEMPERATURE CURABLE (-51 DEG C)    
PR-1828 EPOXY CURED PERMAPOLEâ P-3 P/S 890, P/S 899, PR-1440, PR-1750, PR-1422 PRIMERLESS, HIGH TEMPERATURE RESISTANT, QUICK REPAIR, LOW TEMPERATURE APPLICATIONS SELT-ADHERES TO WIDE RANGE OF SUBSTRATES, FAST CURE (TACK FREE 1 HOUR), HIGH TEMPERATURE RESISTANT (204 C, 10 HOURS), LOW TEMPERATURE CURABLE (-51 C) MIL-S-29574 TYPE II FMS 3064 TYPE II
PR-1829 EPOXY CURED PERMAPOLEâ P-3 PR-1425, PR-1725 NON-CRAZING, UV RESISTANT, WINDSHIELD/CANOPY SEALANT FAST CURE (TACK FREE IN ONE HOUR @ 25 C), HIGH STRENGTH, LOW TEMPERATURE CURABLE (-40 C), WILL NOT DISCOLOR SUBSTRATES AMS G9-89BT  
PR-1959 SILICONE ELASTOMERS   NON-CRAZING WINDSHIELD/CANOPY SEALANT HIGH SOLID CONTENT, NO SHRINKAGE, HIGH TEMPERATURE RESISTANT, EXCELLENT UV RESISTANCE, FLEXIBLE    
PR-1991 SILICONE ELASTOMERS   PRIMERLESS HIGH TEMPERATURE FIREWALL SEALANT; REPAIR OVER AGED FIREWALL SEALANTS FLAME RESISTANT (TO 1650 C), SKYDROL RESISTANT, PRIMERLESS ADHESION, POLYSULFIDE COMPATIBLE, EXCELLENT REPARABILITY, HIGH SERVICE TEMPERATURE (TO 260 C)   DMS 1799
P/S 875 MANGANESE DIOXIDE CURED PERMAPOLEâ P-5 P/S 870B, PR-1422G, PR-1436-GB CORROSION INHIBITIVE, WEIGHT SAVING FILLET SEALANT LOW SPECIFIC GRAVITY (1.01), CORROSION INHIBITIVE   BMS 5-142, STM 40-107

POC: Hill AFB Mr. John Vidic, (801) 777-2050

7.6 Potential to Emit Criteria and HAP Emissions

Many source definitions and compliance requirements of the CAA are based on thresholds of potential emissions. Potential to emit (PTE) is defined by the CAA as "the maximum capacity of the stationary source to emit a pollutant under its physical and operational design." Any physical or operational limitation on the capacity of the stationary source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or effect it would have on emissions is Federally enforceable."

Potential to emit is drastically different than many other types of environmental regulations and can be confusing. Traditionally P2 is focused on reducing actual emissions. For most practical purposes this is the correct strategy, but if an installation is trying to reduce its PTE, avoid restrictive permits, and achieve minor source status then it is necessary to reduce potential emissions.

P2 Option: Federally Enforceable Limits

Success: The bases under the Air Combat Command (ACC) implemented many Federally enforceable limitations on their surface coating, incineration, external combustion, and woodworking operations to maintain their potential HAP emissions below the 25 tons per year threshold. For paint booths some installations used hourly limits and others placed limits on amount of paint/primer (e.g., 25 gallons per months). This strategy exempted many bases from having to comply with the Aerospace NESHAP.
POC: Langley AFB VA Mary Ruth Senn

P2 Option: North American Industry Classification System Code Breakouts

Success: Vandenberg AFB was able to separate itself into smaller entities for regulation. The breakout of other services, Federal agencies, contractors, support units, and differing missions allowed Vandenberg AFB to become a minor source.
POC: Vandenberg AFB CA Jim Rohr DSN 276-7541