I.
Executive Summary II.
Background III.
Data Summary IV.
Progress report: V. Plan
for the next 3 months VI.
Benefits VII.
Comment VIII.
Summation
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Initial data from the Supercritical Fluid Extraction, SFE, process did not give us positive verification of our original Theory, (i.e. the data did not prove that the PCBs used in paints, plastics, and foam rubbers had participated directly in the polymerization process and, as such, would have been converted into new unregulated and inextricably bound materials.) Puget Sound Naval Shipyard is working with experts in the fields of polymer and analytical chemistry in order to determine the next logical step. Region X of the EPA has forwarded a draft letter of acceptance for the Shipyards R&D permit along with some required additions to the Shipyards R&D permit applications. The Shipyard is evaluating these additions and will have a revised R&D permit application to Region X by the first week in April.
Puget Sound Naval Shipyard' s ELP proposal was to map' the process that a company would have to follow to work with the regulatory community to evaluate current regulations that seem to have a net negative effect, i.e. situations where compliance with a regulation has an apparent net negative effect on human health and/or the environment. In order to explore this, the Shipyard chose to evaluate the extraction and disposal procedures for solid materials that were formulated with PCBs as plastisizers. If we are successful the Shipyard will be able to recycle 2500 tons of steel annually that is currently being buried in TSCA landfills, and eliminate 7 tons of methylene chloride from our annual air emissions.
The Shipyard took 16 samples of foam rubber and 16 samples of paints from 6 different submarines covering a twenty year construction period. These samples represented the four types of paint and two types of foam rubber that have been identified as having been originally formulated with PCBs . These materials will not leach PCBs when subjected to EPA's Toxic Characteristics Leaching Procedure, (method No. 1311), and do not swipe' positive for PCBs when subjected to the EPA swipe test, (method No. 560). Each of these samples was extracted using both the EPA approved method for extraction of PCB's in solids, ( EPA method 8080), and the Supercritical Fluid Extraction method. The extracts from these two methods were then analyzed for PCBs by EPA method 8080. The data showed nearly identical levels of PCBs in both types of extracts. Results are summarized in encl. (1). Evaluation of the SFE method used indicate that the elevated extraction chamber temperature, 5100 F, may have decomposed the samples and allowed extraction of the more thermally stable PCBs. Experts in polymer and analytical chemistry are working with the Shipyard to evaluate other methods to further evaluate our hypothesis.
| Tasks | Status | Date |
| Issue MOA | Complete | 7/28/95 |
| Identify and list the organizations required to be involved in the process. | Complete | 7/28/95 |
| Establish a list of responsibilities for the participating parties. | Complete | 7/28/95 |
| Set up contract with Portsmouth Naval Shipyard to perform Super Critical Fluid Extraction. | Complete | 8/15/95 |
| Meet with all parties to discuss responsibilities and assign actions. | Complete | 8/17/95 |
| Provide copies of ELP related audits. | Complete | 8/28/95 |
| Collect Samples and Ship to Portsmouth Naval Shipyard for extraction. | Complete | 9/12/95 |
| Perform Baseline Audit of ELP related area. | Complete | 8/28/95 |
| Apply for R and D permit from Region 10 for Final revision PCB incineration. | due by 5 April 1996 | |
| Submit 3 month status report | Complete | 10/28/95 |
| Set up a contract for dioxin/furan analysis of PCB incineration by-products. | Complete | 11/15/95 |
| Perform Super Critical Extraction on paints and foam rubber samples | Complete | 10/15/95 |
| Perform R & D of by-products from plastic and rubber incineration. | Awaiting EPA approval | |
| Provide final report summarizing the results of all example investigations and the map' of how these investigations are conducted for use by other facilities | Due August 31, 1996 |
To date, the Shipyard has realized two benefits as a direct result of our involvement in the ELP. As anticipated this project has helped us develop a better relationship and understanding with the regulatory community. Beyond that, our work with Super Critical Fluid Extraction indicated that this method could save the Shipyard as much as 250,000 dollars annually over the current approved method while effectively eliminating 7 tons of chlorinated solvents from our yearly air emissions and up to two tons of a combination of methylene chloride and concentrated sulfuric acid from the Shipyard's hazardous waste stream, a real time pollution prevention opportunity . See Encl. (2) for a summary of potential savings associated with Super Critical Fluid Extraction.
The Environmental Leadership Program appears to have been born of EPA's recognition that the command and control philosophy of the past may have reached the point of diminishing returns with many large forward thinking industries. This program was designed to determine if mutually beneficial partnerships can be formed between the EPA and companies that have clearly embraced environmental excellence as corporate policy. If a system for identifying "Environmental Leaders" can be combined with a viable self regulation program the EPA would be able to focus their diminishing resources on the areas or facilities that have the biggest adverse environmental effects. The participating companies would benefit by being allowed to "step out of the box" and use some creativity to affect a measurable improvement to the environment. This is a great idea! However since "stepping out of the box" often requires stepping over regulatory lines controlled by different agencies, and/or branches within agencies , anything less than complete consensus and support by the regulatory community will lead this program towards, at best, disappointing results. Our experience with the R&D permit application indicates to us that "buy-in" and coordination is lacking within the EPA Regions and Headquarters.
To date Puget Sound Naval Shipyard is running somewhat behind our projected schedule mostly due to delays associated with the R&D permit application. We have spent approximately $36,000 dollars gathering and analyzing samples in addition to the approximately 0 .7 man days per day of time spent by our environmental and legal divisions on this project. Due to the time constraints associated with the ELP pilot, the Shipyard has opted to submit its proposed second project through Envest. Foam rubber and paint samples from 8 different submarines representing approximately 20 years of submarine building tested negatively for PCBs when swiped' per EPA method 8080 [Ed. note: probably meant to say method No. 560]. Samples tested positive when extracted by EPA method 8080 for PCBs in solids. Analysis results using Super Critical Fluid Extraction were nearly identical to those obtained using the conventional 8080 extraction.