E AP Project Summary

United States

Environmental Protection

Agency

Pollution Prevention Opportunity

Assessment, U.S. Coast Guard

Aviation Training Center, Mobile

Alabama

Bill Burch and Al Memon

Risk Reduction

Engineering Laboratory

Cincinnati, OH 45268

Research and Development

An assessment of pollution prevention opportunities at the U.S. Coast

Guard Aviation Training Center in Mobile, AL, identified waste reduction opportunities in five major processing

areas: flight simulator operation, aircraft maintenance, aircraft fueling, aircraft washing, and general operations.

The assessment team observed evidence of a concerted effort to reduce

wastes at the facility. This publication

summarizes additional opportunities for

waste reduction.

This Project Summary was developed

by EPA’s Risk Reduction Engineering

Laboratory, Cincinnati, OH, to announce

findings of the research project that is

fully documented in a separate report

of the same title (see Project Report

ordering information at back).

Introduction

A pollution prevention (P2) opportunity

assessment of the U.S. Coast Guard

(USCG) Aviation Training Center (ATC) in

Mobile was conducted under the purview

of the Risk Reduction Engineering

Laboratory’s Waste Reduction Evaluations

at Federal Sites Program. The program

supports P2 research through joint assessments at selected federal sites. The

study was conducted using the EPA

manual Facility Pollution Prevention Guide

(EPA/600/R-92/088), which outlines a process for collecting and analyzing information using detailed worksheets to

characterize waste streams and waste reduction alternatives.

The USCG ATC is located at Bates

Field adjacent to the Mobile, AL, Municipal Airport. The training center was commissioned in 1966 to provide centralized

comprehensive training to Coast Guard

personnel in the operation of fixed-wing

and rotary-wing aircraft. The facility also

has fixed-wing search and rescue responsibilities. Five hundred employees operate the facility on a 24-hr basis. Three

types of aircraft are maintained in operation: the Dauphin Helicopter (HH-65), the

Jayhawk Helicopter (HH-60), and the Falcon Jet (HU-25). Duties include cleaning,

maintenance, and repair of structural, mechanical, and electrical components, and

rescue and survival gear. The aircraft are

also fueled onsite. Approximately 20 aircraft are operated at this facility.

The assessment team observed evidence of a concerted effort to reduce

wastes at the facility. Opportunities for

further progress in waste reduction were

identified in each major process area: flight

simulators, aircraft maintenance, aircraft

washing, aircraft fueling, and general operations.

Flight Simulators

The ATC houses three flight simulators,

all of which use hydraulic equipment. Hydraulic fluid spills account for the major

portion of the waste generated from the

simulators. Recovered hydraulic fluid is

sold to a recycling facility for $0.03/gal

while spent hydraulic fluid filters and spill

absorbents are disposed of as hazardous

wastes. A recommended option was to

perform preventive maintenance on hydraulic pumps and pipe joints, thus reducing the leaks and subsequent cleanups.

Additionally, a wringer can be used to

EPA/600/SR-94/156 September 1994
2

recover the fluid from the absorbents, and

the absorbent material can be reused with

an average of 75% absorption capacity.

Overall, these options have economic

advantages: a reduction in waste disposal

costs and a savings in the purchase of

raw materials.

Aircraft Maintenance

Several activities in the aircraft maintenance area account for pollution generated at the ATC. As an example, the three

airframe shops and the engine shop each

have their own material lockers. Many of

the materials used in the shops are alike

or similar. A P2 option is to combine the

four lockers and establish a centralized

control point for management of maintenance materials. Management responsibilities would include tracking the material

shelf life extensions. This option would

reduce material usage and losses at little

or no increase in personnel costs.

Alternative cleaning agents were identified to replace the numerous cleaning

materials containing organic solvents which

are collected and disposed of as hazardous waste, or which evaporate. As an

example, instead of toluene to clean rubber surfaces, alternatives such as acetone,

isopropyl alcohol, or terpene-based cleaners could be used.

Currently, preventive maintenance on

the airframe engines in the Dauphin Helicopter and Falcon Jet require replacing

the engine oil every 150 hr of operation

and gearbox oil every 450 hr of operation.

For the Jayhawk Helicopter, however, replacement is based on the condition of

the oil. A P2 option is to establish that

same practice for the Dauphin Helicopter

and Falcon Jet. A benefit would be the

extended life of the oil. A 10% increase in

oil life would reduce oil consumption by

an estimated 200 to 300 gal/yr at the

ATC. Implementation costs would include

periodic analyses to track the condition of

the oil.

Aircraft Fueling

Several easily implemented options

would significantly reduce pollution resulting from aircraft fueling. These include the

following: using spill absorbents to recover

spilled fuel; squeezing the absorbent to

recover additional fuel, and reusing the

absorbent; eliminating rainwater entry to

the bowser where waste is stored; and

segregating bowser wastes for later recovery. Bowser waste can be sold at

$0.03/gal, but since $0.50/gal of water is

deducted from the price, it is economically

beneficial to eliminate the water. All that is

needed to implement this option is to ensure that the inlet and funnel are not left

unattended during waste transfer to the

bowser.

Most spills from fuel transfer activities

are the result of unsupervised or unattended transfer, especially at the fuel farm.

In addition, failure of automatic shut-off

valves results in overflow spills. Installation, careful inspection, and periodic testing of overfill protection systems in all fuel

transfer facilities and equipment will significantly reduce this source of pollution.

Another option is to limit the amount of

fuel used to satisfy the requirement for

visual testing of fuels. One pint is the

minimum required, but often two or three

times that amount is used. Adherence to

the minimum requirement is all that is

needed to reduce pollution from waste

fuel by two to three times.

Aircraft Washing

Considering future environmental requirements, a P2 option is to use alternative washing soaps. The ATC currently

uses Aircraft Soap Types 1, 2, 4 and 5,

which contain the following compounds:

* Mention of trade names or commercial products does

not constitute endorsement or recommendation for

use.

Type 1 — Dipropylene Glycol Methyl

Ether, Hexylene Glycol,

Morpholine

Type 2 — Dipropylene Glycol Methyl

Ether

Type 4 — Mineral Spirits, 2-Butoxyethanol, Hexylene Glycol

Type 5 — Naphtha, 2-Butoxyethanol,

Hexylene Glycol

These compounds are currently within

the requirements of the rinsate discharge

permit, but they may be regulated in the

future. Nonhazardous alternatives used by

the Air Force, such as AVIAWASH 4000*

and Turboclean, should be investigated to

determine if they meet the aircraft washing needs of the ATC.

General Operations

Several alternatives were identified that

could communicate ways that P2 relates

to specific job requirements. These include the following: issuing a written P2

management policy, tailoring training material specifically to USCG aviation activities, incorporating P2 practices into

operating procedures, measuring P2

progress, conducting staff briefings on the

progress made, and recognizing P2 efforts and progress.

Conclusion

The assessment team observed evidence of a concerted effort to reduce

wastes at the facility. Opportunities for

further progress in waste reduction were

identified in each major process area. The

P2 options identified for the ATC require

minimum effort and expense and could be

easily implemented.

The full report was submitted in fulfillment of Contract 68-D2-0181, WA 1/011,

by the TRC Environmental Corporation,

under Subcontract No. 1-645-999-222-004

to Pacific Environmental Services, Inc.,

under the sponsorship of the U.S. Environmental Protection Agency.
3

Bill Burch, and Al Memon are with Pacific Environmental Services, Inc. (under

Subcontract to TRC Environmental Corporation), Herndon, VA 22070.

James S. Bridges is the EPA Project Officer (see below).

The complete report, entitled "Pollution Prevention Opportunity Assessment,

U.S. Coast Guard Aviation Training Center, Mobile, Alabama," (Order No.

PB95-100020; Cost: $27.00, subject to change) will be available only

from:

National Technical Information Service

5285 Port Royal Road

Springfield, VA 22161

Telephone: 703-487-4650

The EPA Project Officer can be contacted at:

Risk Reduction Engineering Laboratory

U.S. Environmental Protection Agency

Cincinnati, OH 45268

Telephone: 513-569-7683

BULK RATE

POSTAGE & FEES PAID

EPA

PERMIT No. G-35

United States

Environmental Protection Agency

Center for Environmental Research Information

Cincinnati, OH 45268

Official Business

Penalty for Private Use

$300

EPA/600/SR-94/156