hwtr - Washington4 The typical industrial processes found in this sector and what pollution prevention opportunities are available 4 Conclusions and recommendations for this sector

For additional copies of this document, please contact:

Department of EcologyPublications Distribution Center

P.O. Box 47600Olympia, WA 98504-7600

Please include your street address for UPS delivery.

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The Department of Ecology is an equal opportunity agency and does not discriminate on thebasis of race, creed, color, disability, age, religion, national origin, sex, marital status, disabledveteran’s status, Vietnam Era veteran’s status or sexual orientation.

If you have special accommodation needs or require this document in alternative format, pleasecontact the Hazardous Waste and Toxics Reduction Program at (360) 407-6700 (voice) or (360) 407-6006 (TDD). Regional TDD numbers are:

CRO (TDD) (509) 454-7673 NWRO (TDD) (425) 649-4259ERO (TDD) (509) 458-2055 SWRO (TDD) (360) 407-6306

Environmental Managementat Washington State

National Security Facilities

Table of Contents

I. Executive Summary 1

II. Overview 2

III. Compliance Strategies 4

IV. Innovative Environmental Programs 5

V. Pollution Prevention Progress 7

VI. Conclusions and Recommendations 9

Appendix A � 1998 Waste Graphs 10

Appendix B � Pollution Prevention Opportunites 13

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ENVIRONMENTAL MANAGEMENT AT WASHINGTON STATE NATIONAL SECURITY FACILITIES 1

I. ExI. ExI. ExI. ExI. Executivecutivecutivecutivecutive Summarye Summarye Summarye Summarye Summary

From 1997 to 1999 the Washington State Department of Ecology�s Hazardous Wasteand Toxics Reduction Program conducted an evaluation of the 22 national security facilitieslocated in Washington State. This evaluation was an effort to provide a summary of theenvironmental programs, challenges and accomplishments of these facilities as a sector. Thissector includes the federal Departments of the Army, Navy, and Air Force, as well as thestate-led Washington Army National Guard and Washington Air National Guard.

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4 General information about the sector4 National security facilities history of compliance in environmental matters4 The typical industrial processes found in this sector and what pollution prevention

opportunities are available4 Conclusions and recommendations for this sector and Ecology staff

(Note: This report focuses on pollution prevention and hazardous waste managementactivities and does not specifically address all air, water and clean-up operations.)

All of the facilities assessed in this report continually improved their approaches toreducing detrimental impacts to the environment. For example, facilities have displayedremarkable reduction in waste generation - results displayed in Section V indicate over a50% reduction in the generation of Dangerous Waste from 1990 to 1999. Extremely hazard-ous waste was reduced by over 90% during the same time period.

Pollution Prevention Plans indicate that the national security facilities continue toimplement new ways of reducing waste every year. In addition, the use of hazardous sub-stances has decreased dramatically through the use of Authorized Use Lists and strictinventory management procedures

As a result of the evaluation, Ecology staff developed the following recommendationswhich may continue to benefit these national security facilities as they strive to meet theirenvironmental goals:

4 Continue to develop their Environmental Management Systems

4 Continue to communicate regularly with Department of Ecology staff

4 Continue to regionalize environmental activities

4 Focus on reducing waste streams with largest potential environmental impact

4 Continue to put a high priority on environmental programs

2 WASHINGTON STATE DEPARTMENT OF ECOLOGY

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The National Security Sector includes the Departments of the Army, Navy and AirForce and the other associated defense agencies, as well as the Washington Army NationalGuard and the Washington Air National Guard. There are almost two dozen installations inthe State of Washington (see following table), and thousands of installations across the U.S.

National Security Facility County

US Air Force - Fairchild Air Force Base SpokaneUS Air Force - McChord Air Force Base Pierce

US Army - HQ I Corps & Fort Lewis PierceUS Army - HQ Vancouver Barracks ClarkUS Army - Yakima Training Center Yakima

US Navy - US Naval Radio Station, Jim Creek SnohomishUS Navy - US Naval Station, Everett SnohomishUS Navy - Bangor Submarine Base KitsapUS Navy - NUWC Division, Keyport KitsapUS Navy - Naval Air Station, Whidbey Island Ault Field IslandUS Navy - Naval Air Station, Whidbey Island Seaplane Base IslandUS Navy - Naval Ordnance Center, Port Hadlock Detachment JeffersonUS Navy - Puget Sound Naval Shipyard Kitsap

Washington Air National Guard - Camp Murray PierceWashington Air National Guard - Everett 215th EIS SnohomishWashington Air National Guard - Seattle King

Washington Army National Guard - Camp Murray PierceWashington Army National Guard - Mobil Training Equipment YakimaWashington Army National Guard - OMS #4 LewisWashington Army National Guard - OMS #9 SpokaneWashington Army National Guard - Unit Training Equipment Site PierceWashington Army National Guard - Army Aviation Support Facility #1 Pierce

Installations range in size from a fewacres to thousands of square miles. Many ofthese installations are the equivalent ofsmall, and sometimes not so small, cities. Asa result they often have the entire infrastruc-ture of a city including hospitals, sewagetreatment plants, roads and airports.

Each national security facility ischarged with defending the interests of theUnited States. Their missions range fromlogistics and training, to manufacturing and

rebuilding aircraft and ships. These facilitiesprovide the necessary infrastructure tosupport the armed services to meet theirmissions.

Much of the support activity associatedwith national security facilities is industrialin nature. As a result, facility installationsconfront a variety of environmental issues,including air and water pollution and thegeneration of solid and hazardous waste.

Table 1: National Security Facilities in Washington State


Examples of commercial and industrial activities commonly conducted at nationalsecurity facilities include:

The major hazardous wastes generated by national security facilities in WashingtonState in 1999 were:

4 Wastewater4 Petroleum wastes4 Electroplating wastes4 Equipment retired from service that designates as a hazardous waste4 Paint Wastes

To help determine areas where Ecology staff could best provide pollution preventionassistance, staff compiled waste generation data on these major wastestreams from eachfacility. The results of the analysis can be found in Appendix A which begins on page 10.

4 Maintenance of vehicles, vessels andaircraft (including painting and partscleaning)

4 Fuel storage and refueling4 Electroplating4 Printing and photoprocessing4 Wastewater treatment4 Hospital operations

4 Laboratory research4 Office operations4 Explosives manufacturing, storage,

and disposal4 Electronics facility maintenance4 Ship building4 Land management4 Warehousing


III. Compliance StrIII. Compliance StrIII. Compliance StrIII. Compliance StrIII. Compliance StraaaaatetetetetegiesgiesgiesgiesgiesAll federal facilities, including

national security facilities, are required tocomply with various statutes, regulations,and executive orders administered by theEnvironmental Protection Agency (EPA).These executive orders direct the environ-mental management approaches taken bythe national security facilities. Executiveorders issued for federal facilities man-date:

4 Cleanup of contaminated federalproperty

4 Creating and implementing effectiveenvironmental strategies thatemphasize compliance, risk manage-ment, pollution prevention, andsustainable development

4 Acquiring resources for developingand improving environmentalmanagement systems (e.g. adequatebudget, human resources, informa-tion management systems, andtechnology)

4 Addressing issues related to envi-ronmental justice

4 Addressing the need for preserva-tion of land and ecosystems

Recognizing the unique nature of thenational facilities sector, EPA and Wash-ington State have joined together to createcoordinated federal facility enforcementand compliance assurance requirements,and currently provide assistance tofacilities as they follow those require-ments.

The Federal Facilities MultimediaEnforcement Compliance Program(FMECP) is a national program designedto use multimedia inspections to assess thecompliance of federal facilities withenvironmental laws. Under the program,each of EPA�s ten regional offices con-ducts a series of multimedia team inspec-tions, in concert with the appropriate stateofficials.

Between 1990 and the present,FMECP inspections conducted at a numberof high-risk national security facilitiesthroughout the State of Washington resultedin few enforcement actions being issued.The actions that were taken ranged fromwarning letters to formal administrativeorders that included penalties.

Enforcement of a statute or regulationinvolves whatever judicial and administra-tive actions (both civil and criminal) areavailable to the state or federal governmentwhen a facility is not in compliance, suchas orders and/or penalties.

Although assessment of penaltiessends an important and strong deterrentmessage to the regulated community,penalties are not the only means of enforc-ing environmental goals.

Supplemental Environmental Projects(SEPs) are environmental projects andother measures which can reduce assessedpenalties. Negotiated with WashingtonState and/or EPA, the size of a penalty canbe reduced in exchange for agreements bythe facility to complete environmentallybeneficial projects. These agreements areenforced and must go beyond the injunctiverelief EPA or Washington State couldotherwise order.

Under Executive Order 12873, allfederal agencies have been ordered toestablish or strengthen existing recyclingprograms. Some local success storiesinclude:l McChord Air Force Base which has

captured an estimated 40 percent of itswaste through its paper, aluminum,and glass recycling program.

l Whidbey Island Naval Air Station-Ault Field, Bangor Submarine Baseand Puget Sound Naval Shipyardwere recipients of the Secretary ofDefense Environmental SecurityRecycling Award


A Puget Sound Naval Shipyard (PSNS)employee, Bill Boucher, was recognized as aNavy Individual Environmental AchievementAward winner in 1998 for his efforts toeliminate oil spills from both the Navy Fleetand from PSNS. There have been numerousspills of petroleum products by naval vesselsin Washington state waters from 1993 to thepresent. In order to minimize the potentialfor spills from aircraft carriers about toundergo maintenance work, PSNS decidedto educate crewmembers prior to enteringWashington State waters. Since PSNSimplemented this preventative approach, thenumber and volume of the spills fromaircraft carriers have been reduced dramati-cally.

In addition to the prevention of vesselspills, the number of reportable oil spillsfrom PSNS shore-based operations hasdecreased from 26 spills in 1995 to fourspills in 1998. The total gallons of oil spilledhave also decreased markedly, from 2,600gallons in 1995 to 37 gallons in 1998.

The following is an example of a Supplemental Environmental Project carried out bythe Navy:

In 1997 a $30,000 penalty was issued to Puget Sound Naval Shipyard (PSNS) forillegal disposal of lead-bearing waste in a landfill. In lieu of part of the penalty, PSNSrequested that they be allowed to perform a shoreline enhancement project to rehabilitatebeach spawning beds for salmonids and smelt at the Navy Manchester Fuel Depot. Thepenalty was renegotiated to allow $24,000 to be used for the project and a payment of$6,000 was made to the regulatory agency. Field work for the project was completed inJune, 1999.

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National security facilities are involvedin numerous innovative environmentalprograms and have formed several success-ful environmental partnerships with EPA.Environmental programs underway atnational security facilities include:

4 Fast-Track Cleanup Program to speedthe cleanup process at military basesslated for closure

4 Development and adoption of pollu-tion prevention strategies

4 Revision of all material specificationsand standards with their environmentaleffects in mind

4 Evaluation of the environmentaleffects of all major systems beingacquired

4 Continuous reductions in hazardouswaste generation

4 Environmental Technology Programsto coordinate and integrate environ-mental research and development

4 Implementation of EnvironmentalManagement Systems in accordancewith ISO 14000


GoGoGoGoGovvvvvernment Wide Initiaernment Wide Initiaernment Wide Initiaernment Wide Initiaernment Wide Initiativtivtivtivtiveseseseses

As a result of executive orders andother directives, many federal agencies haveintroduced significant changes in their dailyoperations. These changes address goals suchas reducing emissions from fossil fuels,purchasing environmentally preferableproducts, and implementing environmentaljustice strategies. A few of the programs andinitiatives underway that involve the nationalsecurity sector are described below.

Strategic Environmental Research andDevelopment Program

The Strategic Environmental Researchand Development Program (SERDP) is amulti-agency effort which involves theDepartment of Defense (DOD), Departmentof Energy (DOE) and EPA�s science andtechnology program. The aim of SERDP is toenhance technology transfer with the privatesector. More than 35 percent of the projectsconducted under SERDP involve partner-ships with industry.

Federal Agency EnvironmentalRoundtable

Fifty federal agencies are representedon the Federal Agency EnvironmentalRoundtable. The Roundtable exchangesinformation on policy, strategy, standards,and regulations. Topics of discussion includethe hazardous waste docket, proposed EPAstrategies for national programs, technicalinformation systems, and military baseclosures.

Federal Facilities EnvironmentalRestoration Dialogue Committee

The Federal Facilities EnvironmentalRestoration Dialogue Committee is anadvisory committee under the FederalAdvisory Committee Act. Its purpose is toprovide a forum to identify and refine issuesrelated to environmental restoration activitiesat federal facilities. Its members include:

4 Several federal agencies includingEPA, DOD, National Oceanic andAtmospheric Administration (NOAA),and the Agency for Toxic Substancesand Disease Registry (ATSDR)

4 National and local environmental,citizen, and labor organizations

4 Tribal governments and NativeAmerican organizations

4 State government agencies and stategovernment associations

Environmental JusticeIn 1994, President Clinton issued

Executive Order 12898 entitled �FederalActions to Address Environmental Justice inMinority Populations and Low-IncomePopulations�. The concept of environmentaljustice means that all people have an oppor-tunity to live in a healthy environment,breathe clean air, drink clean water, andconsume uncontaminated foods.

This executive order directs all federalagencies to develop environmental justicestrategies to identify and address dispropor-tionately high and adverse human health orenvironmental effects of their programs,policies, and activities on minority popula-tions and low-income populations. The orderalso established an Interagency WorkingGroup on Environmental Justice, which ischaired by EPA. Member agencies of theworking group include DOD, US Depart-ment of Housing and Urban Development(HUD), United States Department of Agri-culture (USDA), and several civilian agen-cies, including the Council on Environmen-tal Quality and National Aeronautics andSpace Administration (NASA).


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The following graph depicts the reduction in Dangerous Waste that has occurredbetween 1990 and 1999 at each of the larger national security facilities in Washington State.

DangDangDangDangDangerererererous Wous Wous Wous Wous Wasteasteasteasteaste

Note: 1990 totals are an estimate based on available information. 1996 and 1999 totalshve been verified, and do not include non-recurrent wastes, TSCA wastes or wastewatertreated on-site.

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

Puget SoundNaval Shipyard

McChord AirForce Base

U.S. ArmyFt. Lewis

NavalSubmarine

Base Bangor

NAS WhidbeyIsland

Ault Field

1990

1996

1999

6,000,000

po

un

ds


ExtrExtrExtrExtrExtremely Hazaremely Hazaremely Hazaremely Hazaremely Hazardous Wdous Wdous Wdous Wdous Wasteasteasteasteaste

Extremely hazardous waste generated at these facilities during this same time has alsobeen substantially reduced between 1990 and 1999 as depicted in the following graph.

Note: 1990 totals are an estimate based on available information. 1996and 1999 totals have been verified.

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

900,000

1,000,000

Puget SoundNaval Shipyard

McChord AirForce Base

U.S. ArmyFort Lewis

NavalSubmarine

Base Bangor

NAS WhidbeyIsland

Ault Field

1990

1996

1999

4,000,000

5,000,000

poun

ds


provided the regulatory and facilitypersonnel with increased insight andawareness to assist in accomplishingtheir environmental goals.

l Continue to regionalizeenvironmental activitiesSome of the environmental require-ments of the Department of Ecologyand EPA may be more efficientlymanaged from a centralized location.Regionalization allows the facilities toshare expertise, improve auditingfunctions, provide for more favorablecontract administration, conductvarious types of training and results inan improved overall effectiveness inmeeting environmental goals.

l Focus on reducing waste streamswith the largest potentialenvironmental impactSeveral very large waste streams arerecurrent among national securityfacilities. It would be in everyone�sbest interest to address these wastestreams and develop suitable reductiongoals. (See Appendix B for PollutionPrevention Opportunities.)

l Continue to put a high priorityon environmental programsWhile the national security facilities inWashington have had numeroussuccessful pollution preventionimplementation projects and theirenvironmental programs are continu-ing to improve, the momentum needsto continue. The challenge to improveis an arduous one. It will requireinnovation, commitment and re-sources.

VI. ConcVI. ConcVI. ConcVI. ConcVI. Conclusions and Rlusions and Rlusions and Rlusions and Rlusions and RecommendaecommendaecommendaecommendaecommendationstionstionstionstionsThe national security facilities have

made major progress in the area of environ-mental management. This is evident throughtheir dedication to compliance with environ-mental laws and regulations, their implemen-tation of Executive Orders, and their overallenvironmental performance. All of thefacilities assessed in this report continuallyimprove their position in regards to environ-mental impact. For example, they havedisplayed remarkable reductions in theirwaste generation. The results displayed inthe graphs in Chapter VI indicate over a 50%reduction in the generation of DangerousWaste from 1990 to 1999. Extremely hazard-ous waste was reduced by over 90% duringthe same time period.

An analysis of Pollution PreventionPlans indicates that the facilities continue toimplement new opportunities to reduce wasteand the use of hazardous substance everyyear.

The following recommendations maybe of benefit to these facilities as theycontinue to strive to meet their environmen-tal goals:

l Enhance development ofEnvironmental ManagementSystemsAn Environmental ManagementSystem approach to pollution preven-tion planning and environmentalcompliance in general allows each ofthe facilities to apply limited resourcesto the most beneficial projects.

l Continue to communicateregularly with Department ofEcology staffSome of the larger installations havebeen having bi-monthly meetings withstaff from the Department of Ecology.This level of communication has


The following graphs depict the amounts and types of the major wastes generated in1999 by Washington�s larger Navy, Army and Air Force installations.

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APPENDIX A: RECURRENT DANGEROUS AND EXTREMELY HAZARDOUS WASTES 11

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APPENDIX B: POLLUTION PREVENTION OPPORTUNITIES 13

Catalytic Convertorsl Recycle to recover precious metals.

Cleaning Operationsl Develop closed-loop systems for wash

waters.l Use wash waters from the final phase

of cleaning in the initial phase.

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Equipment Modificationsl Add peripheral condensing coils above

the condenser coils to increase thethickness of the cold air blanket andprevent emissions from open-top vaporcleaners.

l Replace water in the freeboard con-denser coils with a more efficientrefrigerant.

l Add a water-cooled tank jacket toprevent convection of solvent vaporsup the hot walls of the cleaning unit.

l Add a gravity solvent-water separatoror a canister of desiccant to prevent ordelay breakdown of the solvent,corrosion of degreasing equipment,and elevated emissions caused byaccumulation of moisture.

l Ensure that the cover is manageableand tight-fitting so that it will be usedregularly and be effective in prevent-ing emissions.

Process Modificationsl To cause fewer emissions, use me-

chanical or ultrasonic cleaning. Theeffectiveness of ultrasonic cleaning isimproved when solvents are heated tospecific appropriate temperatures.

Appendix B: PAppendix B: PAppendix B: PAppendix B: PAppendix B: Pollution Prollution Prollution Prollution Prollution Preeeeevvvvvention Opporention Opporention Opporention Opporention Opportunitiestunitiestunitiestunitiestunities

This appendix provides examples ofpollution prevention opportunities pertinentto each of the major operations present innational security facilities. Many nationalsecurity facilities have already begun imple-menting these and other pollution preventionmeasures. The opportunities identified hererepresent a synthesis of the literature andinclude recycling and waste minimization inaddition to pollution prevention.

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Used Oill Prevent spills through good house-

keeping.l Install special �oil extender� filters in

vehicles.

Waste Antifreezel Substitute propylene glycol for ethyl-

ene glycol.l Install on-site recycling equipment for

waste antifreeze.

Air Conditioning Refrigerantsl Use on-site chlorofluorocarbon (CFC)

recycling equipment.

Old Batteriesl Recycle.l Maintain batteries according to

operating direction.

Miscellaneous Wastes (tires, enginecomponents, brakes, and gasoline)l Recycle old tires.l Use reformulated products (rebuilt

components such as carburetors, andwater pumps).

l Filter and reuse waste fluids.


Material Substitutionsl Use aqueous cleaners, with or without

added saponifiers, surfactants, deter-gents, agitation, pressure, alkalinity orheat.

l Use semi-aqueous cleaners (alsoknown as emulsion cleaners) thatincorporate hydrocarbon solvents andwater into the cleaning and rinsingprocess.

l Use aliphatic hydrocarbon solvents,such as mineral spirits, naphtha,kerosene, and synthetic paraffinichydrocarbons (especially appropriatein processes when contact with watermust be avoided).

l Use miscellaneous organic solventssuch as alcohols, ketones, and veg-etable oils, that are less toxic solvents.

l Use catalytic wet oxidizers to provideoxidation of organic contaminants inthe presence of water.

l Use absorbent medium cleaners, suchas cleaning wipes composed of spe-cialty fibers designed to remove oiland other contaminants.

Operational Modificationsl To reduce emissions caused by drag-

out, withdraw parts from the degreaserwhen they stop dripping; hold parts inthe freeboard zone until all parts arecompletely dry.

l To hold parts, use fixtures that pro-mote better draining.

l Keep an idling degreaser covered.l Slow the speed at which parts are

moved; keep large cross-sections ofparts 50 percent smaller than thecorresponding degreaser section; anduse sliding covers to reduce drafts andturbulence.

l Minimize the use of sprays; whennecessary, use high pressure lowvolume spray heads; keep the spraynozzle below the cooling coils; and useshort bursts of spray.

l Consider superheating the vapor toallow parts to dry quickly.

l Extend life of solvents through filter-ing and settling.

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Surface Preparationl Minimize use of stripper.l Use spent stripper as a rough pre-

stripper on the next item.l Consider the use of the following

methods of stripping paint: dry icepellets, abrasive media, plastic mediabead-blasting, cryogenic, thermal,wheat starch media, and laser or flashlamp.

Operational Modificationsl Train spray gun operators in proper

spray techniques to minimize genera-tion of waste coating.

l Pre-inspect parts to ensure it is dry,clean and dust-free, and to preventpainting of obvious rejects.

l Schedule coatings to minimize colorchanges, or paint with lighter colorsbefore darker colors to minimize theneed for equipment cleanouts.

l Mix only as much coating as is neededfor a job. Train employees to estimateamounts and mix paints correctly.

l Save off-color paint for other jobs.l Apply extra coats to use excess paint.l Avoid the need for re-coating by first

inspecting the area to be painted.

Waste Segregationl Segregate nonhazardous paint solids

from hazardous paint solvents andthinner.

l Segregate solvent waste streams andavoid dilution with water.

l Separate solvents and foreign sub-stances for recycling and reuse.

l Separate thinners from paint sludgesby gravity separation and reuse them.


Material Substitutionsl Use powder coatings to eliminate VOC

emissions and obtain high transferefficiency.

l Use water-based coating to reducesolvent emissions.

Equipment Modificationsl Modify the spray booth to allow

recovery and reuse of overspray solids.l Size the paint cup on spray guns

appropriately.l Automate spray and dip operations

when possible.l Isolate spray booths for solvent-based

coatings from spray booths for water-based coatings.

l Keep solvent soak tanks away fromheat sources.

l Use high volume low pressure (HVLP)spray apparatus to increase transferefficiency.

Equipment Cleaningl Train employees to use only small

amounts of solvents for cleaning.l Flush equipment first with dirty solvent

before final cleaning with virginsolvent, or pre-clean items with ragsbefore cleaning with solvents.

l Use virgin solvents for final equipmentcleaning, then reuse it as paint thinner.

l Consolidate solvent cleaning opera-tions and use a multipurpose solvent.

l Reuse cleaning solvents for a resinsystem by allowing solids to settle outof solution.

l Use pressurized air mixed with a mistof solvent to clean equipment.

l Keep the washoff tank covered when itis not in use.

l Minimize dripping by tilting or rotatingparts to drain as much solvent aspossible and by allowing sufficient drytime.

l Use rags rather than disposable wipeswhenever possible. Launder the ragsin-house or locate a commerciallaundry in the area that can provide theservice.

l If disposable wipes are used, removeas much solvent from them as possiblebefore disposing of them. Keep theused wipes and the spent solvent inseparate containers.

l Use low-volume water cleaningsystems.

l If possible, return coatings withexpired shelf life to the manufacturer,sell them or use them as primer.

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Material Substitutionsl Substitute JP-8 jet fuel for JP-4.

Operational Modificationsl Sell fuels no longer useable under

military specifications to civilianusers.

l Maintain covers of above groundstorage tanks to minimize infiltrationby rainwater.

l Use non-lead based paints to paintabove-ground storage tanks.

l Use high pressure low volume spraysfor tank cleanout work.

Process Modificationsl Install recycling systems in environ-

mental and runoff controls to removewaste fuel from wastewaters.


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Material Substitutionsl Use water treated by deionization,

distillation, or reverse osmosis insteadof tap water.

l Consider hexavalent chromiumalternatives and use of nonchelatedprocess chemicals.

l Switch to noncyanide plating solution.

Process Modificationsl Extend the bath life through filtration,

replenishment, electrolytic dumping,precipitation, monitoring, housekeep-ing, reduction of drag-in, pureranodes, and bags and ventilation andexhaust systems.

l Reduce process chemical drag-out by:minimizing concentrations of bathchemicals by maintaining chemistry atthe lower end of the operating range;maximizing operating temperature ofthe baths to reduce viscosity; usingsetting agents to reduce surfacetension of solution; maintainingracking orientations to maximizedraining; withdrawing work pieces atslower rates to allow draining beforerinsing; using air knives above processtanks; avoiding plating bath contami-nation of the plating bath; using drainboards between process and rinsetanks to route dripping fluids toprocess tanks; and using drag-outtanks to recover chemicals for reuse.

l Improve rinse efficiency of the rinseprocess through use of spray rinsesand agitation of the rinse water,increased contact time; and counter-current rinse systems, or flow con-trols. Reduce drag-in through betterrinsing.

l Reuse bath or rinse water from oneprocess in another, if compatible.

l Consider using spent process baths aspH adjusters.

Equipment Modificationsl Use purer anodes.l Properly design and maintain racks.l Install a bath filter to remove impuri-

ties.l Replace cyanide-based plating solu-

tions with cyanide-free solutions.

Metals Recovery Techniquesl Evaporate rinse water by heating it

and reuse concentrated solution.l Use reverse osmosis at high pressure,

which allows water to pass through amembrane that retains metals, allow-ing return of the metal solution anduse of the water as rinse water.

l Use ion exchange to recover metalions in solution.

l Consider electrolytic recovery andelectrowinning or electrodialysis.

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Plate Makingl Use a countercurrent rinsing process

during plate making.l Reduce drag-in of contaminants and

reduce drag-out of solution by addingdripboards and extending drip time.

l Monitor pH, temperature, and thestrength of the solution frequently toextend bath life.

l Use direct-to-plate technologieswhenever possible; these allowpreparation of plates from computerimages without intermediate steps.

l Eliminate metal etching or platingprocesses by substituting non-hazard-ous alternatives such as presensitizedlithographic plates.

l Use floating lids on bleach anddeveloper tanks.

l Use washless processing systems.


Fountain Systeml Use waterless or dry printing when-

ever possible; it eliminates alcohol andfountain solutions altogether.

Ink Systeml Prepare and use the precise quantity of

ink needed for a press run.l Cover all ink reservoirs or consider

use of special non-drying aerosols thatcan be sprayed onto the ink system toprevent the ink from drying overnightor during shutdown, thus preventingthe ink from becoming unusable.

l Purchase inks in containers that can bereturned to the supplier for refilling, ororder ink in small containers to avoidstorage of large, partially-used con-tainers.

l Choose water-based inks, radiationcuring, soy-based inks, or inks thatcontain low levels of toxic metals.

l Use an automatic ink leveler.l Recycle inks, either on-site or off-site.

A common technique is the blendingof various leftover color inks toproduce black ink.

Cleaning Systeml Use a separate container of solvent for

cleaning each color unit; collect thesolvent and use it again for that color.

l Adopt a standard ink sequence; doingso will eliminate the need to clean outthe fountain solutions to change theink rotation. Schedule light colors firstto reduce equipment cleaning fre-quency.

l Clean the fountain solutions onlywhen changing colors or when the inkmay dry out between runs.

l Replace conventional hazardouscleaning solvents with less hazardousalternatives.

l Whenever possible purchase solventsfrom a company that will pick up andrecycle the spent solvent.

l Reuse press wipes as long as possible.Use a dirty wipe for the first pass anda clean one for the second pass.

l Use rags rather than disposable wipes,whenever possible. Use a commercialrag cleaning business in the area thatcan provide the service.

Photographic Processingl Extend lives of photo and film devel-

oping baths by adding replenishersand regenerators.

l Reduce the amount of waste contain-ing silver by using films that do notcontain silver.

l Reclaim and recycle silver fromphotochemical wastewater.

l Recycle photographic film and paper.

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Pollution prevention opportunities athospitals are somewhat limited by thepractice of using disposables to preventtransmission of diseases and bacteria.However, many hospitals can benefit fromthe adoption of good management practicesaimed at reducing or eliminating generationof waste. There are a number of generalpollution prevention practices for hospitals .These include the following:

l Keep individual waste streams segre-gated.

l Centralize purchasing and dispensingof drugs and other chemicals.

l Test all new materials in small quanti-ties before making bulk purchases.

l Provide spill cleanup kits and trainstaff appropriately.

l Inspect and maintain equipment toavoid leaks.

l Neutralize acid waste with basicwaste.

l Use mechanical handling aids fordrums to reduce spills.

l Use automated metering systems forlaundry chemicals.


Chemotherapyl Optimize drug container sizes when

purchasing.l Centralize chemotherapy compound-

ing in a single location.l Minimize waste from cleaning of the

compounding hood.

Formaldehydel Minimize wastes from cleaning of

dialysis machines and reverse osmosis(RO) units.

l Use reverse osmosis water treatment toreduce demands for cleaning ofdialysis.

l Capture waste formaldehyde andconsider its reuse in pathology orautopsy laboratories.

Photographic Chemicalsl Return off-specification developer to

the manufacturer.l Cover developer and fixer tanks to

reduce evaporation and oxidation.l Recover silver, waste film, and paper.l Use squeegees to reduce bath losses.l Use countercurrent washing.

Solventsl Consider solvent substitutes.l Reduce requirements for analytes.l Use premixed kits for tests involving

solvent fixation.l Use calibrated solvent dispensers for

routine tests.l Recover or reuse solvents through

distillation.

Mercuryl Substitute electronic sensing devices

for devices that contain mercury.l Recycle uncontaminated mercury

wastes, using proper controls.

Waste Anesthetic Gasesl Employ low-leakage work practices.l Purchase low-leakage equipment.

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Material Managementl Establish a centralized purchasing

program.l Order reagent chemicals in conserva-

tive but realistic amounts.l Encourage suppliers of chemicals to

become responsible partners (such asby accepting return of outdatedsupplies).

l Establish an inventory control pro-gram that traces chemicals fromcradle to grave.

l Rotate chemical stock, using chemi-cals before expiration of shelf life.

l Develop a running inventory ofunused chemicals for use by otherdepartments, if possible.

l Perform routine self-audits.

Improved Laboratory Practicesl Segregate solvents and recycle them.l When cleaning with solvents, reuse

the spent solvent for the initialcleaning and use fresh solvent onlyfor the final rinsing.

l Platinum, palladium, and rhodiumcontained in catalysts can be recov-ered through chemical proceduresspecific to certain metals. Segregationof these wastes for off-site recyclingmay be preferable.

l Investigate whether unused reagentchemicals and their containers can bereturned to the manufacturer. Thesupplier may be able to resell sealedbottles of stable chemicals.

l Designate a facility or area forstorage, segregation, and treatment ofwaste.

l Increase use of segregation of wastestreams.

l Ensure that all chemicals and wasteare identified clearly on containers.


Other Suggestionsl Design pollution prevention into

proposals for research activities, andbuild in funding for proper wastemanagement.

l Contact other labs before orderingchemicals and supplies to determinelocal availability, if possible.

l Determine sample quantities neededand alternatives to sample analysis.

l Expand use of microanalytical tech-niques.

l Educate procurement personnel toidentify opportunities for materialsubstitution.

l Explore the possibility of other usesfor expired chemicals.

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Many pollution prevention techniquesfor wastewater treatment strive to reduce theamount of wastewater being discharged fromthe source. Improvement of wastewatertreatment systems can be an effectivepollution prevention opportunity that oftendoes not require significant modifications ofprocesses or equipment. Many wastewaterstreams can be treated more effectively andeconomically if they are segregated fromother streams that do not require the samedegree of treatment. Highly contaminatedwastewater streams, oily wastewaterstreams, and wastewater streams that containcontaminants that require specific treatment(e.g. removal of metals) can be segregated toreduce the volumes of wastewater undergo-ing certain treatment steps. Treatment ofwastewater also can be improved by addingstages, such as: biological treatment, chemi-cal precipitation, filtration, ion exchange,and sludge dewatering. These efforts shouldimprove the effectiveness of the system andreduce treatment costs through reduction inthe amount of sludge generated, recovery ofmetal for resale, and replacement of morecostly treatment stages.

Below is a list of some pollutionprevention options for reducing generationof wastewater:

Process Modificationsl Reuse process water, if possible.l Prevent process water from leaking

into noncontact cooling water orstormwater. Test storm sewer pipingfor leaks.

l Operate machinery at correct tempera-ture and flow levels. Consider the useof automatic control and lock-outvalves.

l Segregate wastewater streams thatrequire different levels of treatment.

Rinse Water Conservationl Install automatic flow controls or

multiple rinse tanks in a counter-current series system (the latter canreduce generation of wastewater by atleast 90 percent).

l Use drag-out recovery techniques.l Use sprays or mist to rinse off excess

process solution, and agitate the rinsebath to increase its efficiency.

Cleaning System Modificationsl Schedule the use of similar chemicals

together to reduce the need forcleaning.

l Maximize dedication of processequipment.

l Attempt to remove residue remainingin equipment to avoid the need forcleaning.

l Use process fluids to clean equipment,then recycle or blend them into theprocess stream.

l Use steam to yield a smaller volumeof wastewater, and recycle the steam.

l Filter cleaning water to removeparticulate and reuse water.

l Use compressed air to clean equip-ment or parts.


Treatment Alternativesl Use treatment technologies that do

not generate heavy metal sludges.l Use different precipitating agents that

can generate less sludge, such ascaustic soda instead of lime.

l Maximize recovery of materials fromwastewaters.

l Identify beneficial uses for sludge..

Documents

hwtr - Washington4 The typical industrial processes found in this sector and what pollution prevention opportunities are available 4 Conclusions and recommendations for this sector