About FASTT

08 - HAZWASTE/HAZMAT Management (BMP)

Aerosol Can Puncturer

Empty aerosol cans are being sent to Public Works Center as hazardous waste. The cans could be punctured and then recycled as scrap metal. This action would reduce the waste stream and bring dollars back to the activity.

Batteries-Management

FASTT found 8 opportunities for better battery management practices. 4 examples follow:

Security alarm repair shop maintains systems with battery back-up power. MRC require a monthly load check and replacement every four years. The batteries (gel-filled) have been proven to have a 8 to 10 year lifespan. The batteries (700 at this site) cost $150 each. FASTT Team recommends replacing them every 8 years instead of every 4 years.

Battery Shop charges, replenishes and disposes of lead acid batteries used in the Support Equipment division. The shop personnel handle battery acid during electrolyte addition and removal prior to disposal. The DRMO draining requirement subjects shop personnel to needless exposure to acid, expends additional man hours (.5 per battery) and requires additional space for drainage stands. DRMOs at most other activities accept lead acid batteries with the electrolyte still in them. Activity shop attempt to modify DRMO contract or consider outside contractors.

The outer casing of batteries are cleaned with water. After cleaning, the water is disposed of as a weak acid solution. This waste stream could be eliminated or reduced by pH neutralization. The wastewater stream can be neutralized by cleaning batteries with a mixture of water and baking soda. Batteries would be washed, rinsed and allowed to air dry over a vat which collects dripping water. The water in the vat is separated from the sludge and disposed of to the sewer. The sludge is disposed of as lead waste.

All lithium batteries now disposed of as HW. New push button type batteries are not HW. Determination of fact could reduce waste stream by eliminating disposal of lithium batteries.

Best Management Practices

Shop collects and disposes of various expended Cartridge Activated Devices (CADs). Prior to recycling, residual black powder pellets must be removed and treated as explosive hazardous waste. A suitable 90+ satellite storage station must be established. Explosive material disposal training must be provided. Currently the CHRIMP is not set up to handle this waste. FASTT will research this problem.

Electronic units maintained/reworked using hand tools and soldering equipment. Units have potential to contain PCB's. Systems shop uses 1987 NAVSEA memorandum as a guide to flag components, however the memo is incomplete. The shop frequently encounters items containing PCBs that are not listed in the memorandum. Shop needs a more complete reference guide and would also like a database listing radioactive tubes in radar equipment.

Dry Filter Paint Booth Systems/Chemco Design

Automotive/vehicle repair shop employs an exhaust ventilation system with disposable filters which collect paint overspray and sanding/grinding dust. Filters are disposed of as hazardous waste. Surface vacuuming with a HEPA cleaner would extend the life of the filters. And a TCLP test may allow for some filters to be disposed of as general waste. There are also Chemco high particulate filtering systems available for paint booth operations.

Filter Systems/BMP

Gun range filtration system includes 18 HEPA filters which are changed every 6 months. The last set of waste filters passed the TCLP for lead. This indicates that either the filters still had service life or that the ventilation system is not functioning properly. It is proposed that a manometer (DP gage) and sensors be installed to check ventilation flow. Action may reduce frequency of filter replacement.

Filtering System - Chemco

Aircraft paint booth operations employ an exhaust ventilation system equipped with replaceable /disposable filters. The filters are disposed of as hazardous waste on a monthly cycle. Shop should conduct TCLP tests. Satisfactory results would allow for the filters to be disposed of as non-hazardous. Current filtering system should also be modified to accommodate Chemco filtering system (a high particulate medium currently being used at other DOD facilities).

Hach Kit

The present method used for testing boiler feedwater uses mercuric nitrate, which is disposed of as a hazardous waste after the test is completed. Use of a Hach Kit will eliminate generation of hazardous waste. Hach Kits provide pre-measured packets which prevents excess use of chemicals. FASTT will provide information on the appropriate test kit.

HM Management/BMP

A one day supply of hazardous materials from Hazmart Central is allowed to be stored on the Delta pier. A satellite Hazmart Central located on the Delta pier would provide faster access to hazardous materials. Ship personnel would also have access to the materials along with the shops.

Personnel procure 9250 gallons of oil for use in shipboard engines. The oil is tested for iron before it is installed. Oil out of specification is disposed of as hazardous waste. The activity should not be liable for oil that is out of specification. Personnel should return the out of specification oil to FISC.

Shop is responsible for procurement, storage and issue of hazardous materials. The inventory of HMs does not reflect actual needs of the activity. Overstocking may be occurring and excess HM is returned to DRMO. The shop should reevaluate material on hand against actual usage rate.

Submarine forces routinely duplicate orders of hazardous materials to ensure they will have the quantities that they need. This results in an excess of new, unused supplies that end up being disposed of as hazardous waste. The unused materials should be collected and re-issued to other submarines. The savings in disposal costs per year is $12,000 and the estimated savings in procurement costs is $10,000 per year.

A small pesticide shop contains a wide variety of pesticides that are used around the camp compound. Many of the pesticides are highly toxic and have safer replacements. FASTT is compiling a list of all pesticides used on-site and will report on better alternatives after consultation with the Pesticide Division.

The US Coast Guard operates a small detachment at the activity where their boats store hazardous materials shoreside. This causes excessive material stores to build up since each ship keeps redundant supplies. FASTT recommends that the Coast Guard join the activity's CHRIMP program. This will lower on-site materials storage requirements and provide excess material reuse services. Past shelf life materials will be eliminated if inventories are reduced to that amount which is readily used. Purchase cost of new material is estimated to be reduced by 40%. Additionally, hazardous materials storage requirements at the Coast Guard pier will be reduced to a seven day supply, which will greatly reduce material management duties and laydown area.

AFWTF operates many facilities to provide the fleet with various products used for training, including a large quantity of hazardous materials. AFWTF shops each store their own HM. This results in more HM than is needed to perform the job has built up in several locations. FASTT recommends the AFWTF join the CHRIMP program. This will lower their on-site material storage requirements and provide excess material reuse services. CHRIMP has been shown to lower material purchase and disposal costs by 40%.

Foundry uses a sulfur dioxide gas system to manufacture cores for the molding process. Several problems exist with this system, including: storage of S02 chambers outdoors ("An accident waiting to happen"); several leaks in the alkali feed system; residue washing into the environment; and portable water feed not equipped to prevent back flow. Employees also complain of overexposure to S02 gas. FASTT has provided literature on alternate processes.

Machine Shop stores approximately four dozen aerosol paint cans for miscellaneous painting. Only about three cans are used per month. This results in many cans exceeding their shelf life. There is also potential for misuse of aerosol products. Cans should be turned in for reuse. This action will result in a one time savings.

HazMart/Reuse store has potential to minimize HMs stored and waste generated at tenant activities and ships. Current concerns of prospective customers are that the service will not be able to provide adequate quantities, and that a surcharge will be assessed to pay for HAZMIN services. Ideally HAZMIN operators would deliver material, pick-up unused material and empties, restock, and handle inventory and reporting efforts. To quell resistance to HAZMIN services, FASTT recommends that the first few years of funding be provided through Mission funds. This time could be used to assess savings and/or need for surcharge.

Sodasorb and Sonofalime are used in diving operations. According to its MSD, sodasorb is not a HM. The Environmental Office should confirm the non-hazardous status of sodasorb so that unnecessary HW disposal costs are not incurred, and a recycle program can be initiated.

HW Management/BMP

Shop disposes of dry paint debris. Debris is collected and disposed of through DRMO as hazardous waste. The nearly 75,000 pounds of paint debris (in 55-gallon drums) should undergo TCLP analysis for verification that it is a hazardous waste. If the paint is dry, it should not fail the TCLP test for characteristics and should be disposed of as a solid waste.

SIMA has several locations where HWs are awaiting disposal. No standard management procedure to daily operations exists. This is partially due to personnel turnover in the division. FASTT recommends that the Environmental Division establish written guidance for proper operation of these sites.

Foundry replaces it's furnace firebricks every 2-4 years. Foundry personnel unaware of disposal practice. Chunks of bricks currently collected in sand dumpsters. The firebricks should be tested to determine if they need to be handled as HWs. Until then, the bricks should not be stored in any dumpsters.

Lead Testing

Shop uses brown paper to cover paint booth to capture paint overspray during painting operations. The paper waste is considered hazardous, even though the current paints used do not contain hazardous materials, such as lead and chromates. FASTT is researching a simple spot kit that can test for lead in paint debris to determine if it would be suitable for use at this shop. FASTT will determine if similar test are available for chromates.

Shop currently removes paint from boats using various types of sanding equipment. The paint is assumed to contain lead even though it has not been tested to confirm the presence of lead. Use of a device to test for lead in house is recommends. FASTT is researching an economical method for testing lead in paint chips.

Site is required to sample paint for lead prior to performing maintenance on vehicles. Lab analysis turn around time is 6 to 8 weeks. Commonly, no results are available, and the vehicles are treated as containing leaded paint. This requires use of PPE and generates lead paint waste. FASTT recommends using another source to test for lead. Samples could be sent to another lab that provides a faster turn around time, or a Pace Scan Anodic Stripping Voltametery device could be purchased. This device can be used on-site and provide results in one hour. Implementing this device could reduce the quantity of lead waste generated each year by 75%, reduce the disposal cost of lead waste by $265 per year, improve working conditions, and improve the accuracy of medical records.

Materials Testing/BMP

Spent or partially spent Oxygen Breathing Apparatus (OBA) canisters are currently disposed of intact, in 55-gallon drums as hazardous waste. The barium, potassium superoxide/hydroxide in the spent canisters can be removed prior to disposal through established dismantling procedures. The canister shell can then be recycled after it is decontaminated. The potassium superoxide/hydroxide can be combined with water and used as a neutralizing agent at industrial wastewater facilities. Only the barium is disposed of as hazardous waste. The amount of hazardous waste generated would be reduced by approximately 8,812 pounds, and annual savings would be $13,466. This program is currently in place at another activity, and it is recommended that the activity be contacted for help in setting up the program.

Spent Oxygen Breathing Apparatus (OBAs) canisters are generated during fire fighting training exercises and cost over $100,000 annually to dispose. FASTT recommends a procedure that utilizes the spent contents of the canister, which are considered hazardous. This procedure is already in place at another facility. The spent contents of the OBA, potassium superoxide/potassium hydroxide, are mixed with water to create a highly basis solution. This solution can be used to balance the pH of wastewater at industrial wastewater treatment plants. The quantity of hazardous waste generated would be reduced by approximately 22,000 pounds, resulting in a savings of $69,460 annually.

Spent Oxygen Breathing Apparatus (OBA) canisters are currently packaged in 55-gallon drum which are disposed of at $1.85 per canister. NFESC is completing research for treatment/disposal of OBA canisters. Disposal cost will be $2.00 per canister. This is a higher cost but the process may be applicable in other geographic areas.

Puncturer and Crushers

Shop currently disposes of spent aerosol cans by placing them in 55-gallon drums in their unaltered state with paint/propellant residue still on them. Use of an aerosol Puncturer and a can crusher would reduce the volume of waste and remove residual paint/propellant and would reduce the number of drums used for shipping by 90%. Estimated annual savings is $29,178, with a pay-back achieved in less than one year.

Recycling/BMP

Recycling operations performed at two sites (cardboard, paper, plastics and a metals site). The metal site (a dirt lot) needs utilities and buildings, the other site needs more space and weather protection for the baled cardboard. A new metal crusher is idle due to the lack of electrical utilities and some type of personnel shelter. This is a station issue which may warrant review.

Special Hull Treatment

Special Hull Treatment (SHT) tiles require de-mil operations and must be disposed of as hazardous waste. Contractor support is difficult to find and expensive. FASTT recommends investigating existing contract that another activity has with a Canadian contractor. This may be less expensive than purchasing a tile shredder. Annual savings could amount to $11,340.

Structure Repair or Modification/BMP

Transfer of hydrocarbons from truck to manufacturing process is done over a secondary containment pit. The pit should be drained when it becomes filled with water, however, a drain was never installed in the pit. It is recommended that the personnel at the asphalt plant install a drain line.

Tank Filter

Cleaning operation residues are allowed to settle to the bottom of the cleaning tank and concentrations of suspended contaminants are allowed to build up. The debris reduces the effective cleaning capacity of the tank system. The cleaning solutions are rinsed from components and collected on the floor in an enclosed sump. Sometimes the components are rinsed over the tank in an effort to recover the chemical residue. The shop was provided with a filter system designed to operate in conjunction with a rinse tank. The rinse tank location was cumbersome to the work evolution and is now being used as a hazardous material storage area. The filter was over-engineered for the application and the filter cartridge units were costly to service. Floor sweepings and general debris blown into the outdoor area are washed into the sump and are returned to the tank along with the rinse water. This adds to the total volume of contaminants in the tank. A portable filter should be installed to remove particulate matter from the tank.