Cross Talk; a Pro-Act newsletter sponsored by
HQ Air Force Ctr. for Env. Excellence
CROSS TALK
Edition 17 - September/October 1995
ODS WAIVER APPROVAL FOR AIR FORCE LABORATORIES
Headquarters United States Air Force, Civil Engineering, issued
the following information in an all MAJCOM memorandum, "Ozone
Depleting Substance Waiver Approval in Support of Air Force
Laboratory Testing Programs," 20 September 1995.
A class waiver was approved for all Class I Ozone Depleting
Substances (ODS) for in-house or contractor support of Air Force
Laboratory Testing Programs for the life of the requirement.
This waiver is approved to purchase and use Class I ODSs to
support Air Force-wide sampling and analysis for air, water,
soil, solid waste, industrial waste, and hazardous material/waste
in accordance with Environmental Protection Agency (EPA)
requirements, State and local laws, and Air Force policy.
Additionally, this memorandum approves purchases of ODSs to
calibrate laboratory equipment as required by Air Force
Specifications and Technical Orders.
"Beginning 1 January 1996, a global essential use exemption to
the Montreal Protocol Treaty covering laboratory testing programs
will be in effect. This exemption allows users with Senior
Acquisition Official approval to purchase ODS products directly
from manufacturers (reference Section 326 of Public Law 102-484).
However, purchases from the Defense Logistics Agency Defense
Reserve are not authorized to support laboratory testing programs
that are covered by the exemption. For the remainder of calendar
year 1995, Class I ODSs may be purchased from any vendor, since
the production ban does not go into effect until 31 December
1995."
"Laboratories are responsible for reporting all purchases of ODSs
under the exemption to the EPA. A Complete listing of reporting
requirements is contained in the 10 May 1995 Federal Register,
page 24970."
Since HQ USAF/CE has received numerous requests from laboratories
around the Air Force asking for new waivers to continue to comply
with the EPA testing protocols, this waiver approval is intended
to incorporate all requests dealing with laboratory uses.
The Air Force Appropriate Technical Representative for sampling
and analysis, Colonel (Select) Robert Wallett, Director of the
Environment, Office of the Civil Engineer, has determined there
is no technically feasible suitable substitute for the Class I
ODSs used during laboratory testing. Class I ODSs are required
by the EPA through either SW 846 or EPA Sampling and Analysis
protocols promulgated under 40 CFR 260, 261, 262, 264, 265, 268,
and 270. Until such time as the EPA promulgates alternative
sampling and analysis procedures, laboratories are required to
continue using Class I ODSs in their methods.
For a copy of the above memorandum contact PRO-ACT, DSN 240-4214.
For further information contact Major Keith Smith, HQ USAf/CEV,
DSN 227-2550.
DEHP-CONTAINING LIGHT BALLASTS
Di(2-ethylhexyl) phthalate (DEHP) was used as a substitute for
polychlorinated biphenyls (PCBs) in certain ballast capacitors
beginning in 1979. DEHP in its pure form is listed as a
hazardous waste (U028) under the Resource Conservation and
Recovery Act (RCRA). However, once it has been used in a
lighting ballast, it is no longer hazardous as defined by RCRA
(40 CFR Part 261.33, 40 CFR Part 261 Appendix VII; 40 CFR 268.34,
and 40 CFR 268.43).
DEHP is also regulated under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), with a
Reportable Quantity (RQ) of 100 pounds (40 CFR, Part 302.4). If
100 pounds (approximately 1600 ballasts) or more are disposed of
in a subtitle D municipal landfill in a 24-hour period, it must
be reported to the National Response Center (NRC), (800) 424-
8802.
DEHP has been found in ballasts designed for the following
lighting fixtures: four foot florescent fixtures manufactured
between 1979 and 1985; eight foot fluorescent fixtures
manufactured between 1979 and 1991. Some ballasts manufactured
during these periods may contain dry capacitors or substances
other than DEHP. To ensure your ballasts do not contain DEHP,
contact the manufacturer or send the capacitor to a laboratory
for testing.
Above information extracted from "Lighting Waste Disposal -
Lighting Upgrade Manual," EPA Green Lights Program, March 1995.
Asphalt Recycling
Approximately 98% of the roads in the United States are covered
with asphalt, a petroleum-based material consisting of rock
aggregate and asphalt cement. Asphalt and waste asphalt are not
considered hazardous materials. However, the disposal of waste
asphalt resulting from construction, renovation and/or demolition
projects presents economic and environmental concerns. The U.S.
Environmental Protection (EPA) estimates construction and
demolition debris, which includes waste asphalt, accounts for
approximately 24 percent of the waste disposed of in our nation's
landfills. An alternative disposal option, asphalt recycling,
presents a way to bypass increasing landfilling costs and the use
of landfill space.
Asphalt recycling eliminates disposal of waste asphalt in
landfills, decreases road repair and construction costs through
use of recycled materials, and increases the surface life of
pavement by using it in place of new material.
During asphalt recycling, the waste asphalt is pulverized, sorted
and mixed with recycling agents or additional aggregate. The
rejuvenated pavement is then applied to the road. There are five
recognized methods of asphalt recycling: cold planing, hot
recycling, hot in-place recycling, cold in-place recycling and
full depth reclamation:
* Cold Planing: In cold planing, asphalt pavement is
automatically removed to a desired depth and width using a
self-propelled rotary drum cold planing machine. The
removed material can then be used as feedstock either at the
site or at the mixing plant. This method allows immediate
use by regular traffic after planing and the planed surface
can be left as textured surface or resurfaced at a later
time.
* Hot Recycling: This in-plant process combines removed
pavement with new aggregate and an asphalt cement or
recycling agent to produce hot mix asphalt which is then
hauled to a work site for use. This procedure requires
minor modifications to existing hot mix plant equipment.
* Hot In-Place Recycling: Pavement is removed, heated and
mixed with recycling agents or additional aggregate and then
applied to the road in either single or multiple passes.
This process re-uses existing asphalt material and
eliminates the cost of hauling waste asphalt between the
site and asphalt plant.
* Cold In-Place Recycling: Pavement is removed, pulverized,
and the road resurfaced with the rejuvenated asphalt. This
process eliminates some of the hauling costs for materials
(except for additives) and has a high recycling production
rate (up to 500 tons per hour). Further, one lane of
traffic can be maintained throughout the project at all
times.
* Full Depth Reclamation: The full pavement and a
predetermined portion of the underlying materials are
uniformly crushed, pulverized, or blended with additives,
resulting in a stabilized base course when replaced. This
is the most economical solution for increasing load-carrying
capacity of pavement. Further, this process eliminates
potential cracking of new overlays, may be accomplished in-
place, allows for maintenance or adjustment of roadway
cross-sections, and traffic can usually continue to use
roadway during resurfacing.
DEFENSE GENERAL SUPPLY CENTER PRODUCTS MAY BE ORDERED VIA THE
INTERNET WORLD WIDE WEB
Defense Logistics Agency (DLA), Defense General Supply Center
(DGSC) product information, catalogs, and requisition forms are
now available via the internet World Wide Web. Military and
civilian agency customers with internet access may log onto
DGSC's home page on the World Wide Web (http://www.dgsc.dla.mil)
and order items directly on line by inputting a MILSTRIP or
FEDSTRIP requisition. Procedures for submitting these
requisitions are available from your supply personnel. DGSC
manages various commodities including chemicals, pesticides,
refrigerants, batteries, food service equipment, packaged
petroleum, oils, and lubricants (POL), and film. Further, the
"Environmentally Preferred Products" and "Energy Efficient
Lighting" catalogs are available for browsing. More catalogs are
planned in the future.
Additional information on the DGSC Web site may be obtained from
Jerry Petet, DSN 695-6082, (804) 279-6082, or Jackie Covolo, DSN
695-3100, (804) 279-3100.
DOVER AFB INSTALLS SPILL CONTROL DEVICE
Dover Air Force Base recently installed a device called "Stream
Saver TM" in a storm water outlet downstream of their Bulk fuels
Storage Area. The device, manufactured by ILC Dover
Incorporated, Frederica, Delaware, (302) 335-3911, uses a
hydrostat (a balloon-like component), which inflates upon
activation. When deployed, the hydrostat inflates in 7 to 35
seconds, seals the outlet or culvert, thereby preventing the
movement of contaminants downstream. Options for activation
include remote switch location, manual fire alarm or upstream
sensors/monitoring station. The system may also be centrally
monitored by a control box. The hydrostat stays inflated for 48
hours, can withstand up to a 23 foot head capacity and can
completely stop flows of 2.5 feet per second. Stream Saver TM is
constructed of chemical resistant materials such as polyurethane
and teflon. For pipes measuring 8 to 21 inches wide, the
hydrostat is installed outside the pipe. For larger outfalls (24
to 42 inches) the hydrostat is installed inside the pipe, but
only obstructs 5 percent of the space and does not obstruct
normal flow.
Other potential installation areas include:
* hazardous material storage, distribution, or transport
areas;
* loading docks; or
* hazardous waste storage areas.
Also, in the event of a fire, the device can be used to prevent
fire suppression agents from entering nearby streams.
The anticipated benefits of this device are rapid deployment,
constant preparedness, and containment of spilled material. This
device is currently under evaluation by Dover AFB personnel. At
present, this evaluation is limited to weekly inspections of the
deployment switch and tracking any maintenance costs incurred.
Additional information on this program may be obtained from: Mr.
Steve Seip, Dover AFB, DSN 445-6820 or (302) 677-6820/6843; Mr.
Robert J. Demidowicz, ILC Dover, Incorporated, (302) 335-3911 or
(800) 631-9567; or PRO-ACT.
REGULATORY ALERT! MEDICAL WASTE INCINERATORS
The Environmental Protection Agency (EPA) proposed new standards
on new and existing medical waste incinerators in the 27 February
1995 Federal Register (60 FR 10654). Under the new guidelines,
EPA predicts 80 percent of on-site incinerators will be shutdown
and alternative methods of disposal will be sought. The most
common alternative methods include transportation of medical
waste to large incinerators and on-site autoclaving.
Under the proposed rule, existing incinerators must meet the
following emission standards:
Particulate Matter 30 mg/dscm 12-hour average
Opacity 5 percent 6 minute average
Carbon Monoxide 50 ppmv 12-hour
Dioxins/Furans 80 ng/dscm total 12-hour average
CDD/CDF or 1.9 ng/dscm TEQ
Hydrogen Chloride 42 ppmv
Sulfur Dioxide 45 ppmv 12-hour average
Nitrogen Oxides 210 ppmv 12-hour average
Lead 0.10 mg/dscm 12-hour average
Cadmium 0.05 mg/dscm 12-hour average
Mercury 0.47 mg/dscm 12-hour average
ng = nanogram
CDD = chlorinated di-benzo dioxin
dscm = dry standard cubic meter
CDF = chlorinated de-benzo furans
mg = milligram
TEQ = toxic equivalency
ppmv = parts per million volume
INTEGRATED PEST MANAGEMENT
PRO-ACT has received several requests for information on pest
management to include: development of an Integrated Pest
Management (PIM) Program; pesticide disposal; and identification
of environmentally friendly pesticides.
Many of these questions may be answered by reviewing the all
MAJCOM memorandum, "Integrated Pest Management - Pollution
Prevention Initiative," Headquarters Air Force Civil Engineering
Support Agency (HQ AFCESA), 15 May 1995.
IPM uses regular monitoring to determine if and when pesticide
treatments are needed. Adequate pest control is accomplished
through physical, mechanical, cultural, biological, and
educational approaches. The least toxic pesticide will only be
applied as a last resort.
The IPM program has three major elements or "Measures of Merit":
1 Installation Pest Management Plans - By the end of FY 97,
all DoD installations will have pest management plans
prepared, reviewed, and updated annually;
2 Annual Amount of Pesticide Applied - By the end of FY 2000,
the amount of pesticide applied annually on DoD
installations will be reduced by 50 percent from the FY 93
baseline in pounds of active ingredient; and
3 Installation Pesticide Applicator Certification - By the end
of FY 98, 100 percent of all DoD installation pesticide
applicators will be certified within two years of
employment.
To meet the pollution prevention goal of 50 percent reduction in
pesticide application, integrated pest management must replace
traditional pest control tactics. The IPM approach utilized
prevention, customer education, inspections, and denial of pest
entry. The end result is less pesticide use, reduced waste, and
implementation of more environmentally friendly pest control
approaches.
Additional information on the Integrated Pest Management Program
can be obtained from Mr. Wayne Fordham, HQ AFCESA/CESM, DSN 523-
6465 or PRO-ACT.
Additionally, work is in progress to develop a Model Shop program
report for Pest Management shops. This report is scheduled to be
complete and available to the field in the summer of 1996.
Contact Mr. Mike Clawson, Pollution Prevention Directorate,
Headquarters Air Force Center for Environmental Excellence (HQ
AFCEE/EP), DSN 240-3517, for more information.
GUIDANCE ON IDENTIFICATION OF LEAD-BASED PAINT HAZARDS
The EPA Office of Pollution Prevention and Toxics recently
published in Volume 60 of the Federal Register, page 47248,
guidelines to assist in identification of lead-based paint (LBP)
hazards. This guidance is provided as an interim response to
Title X of the Housing and Community Development Act of 1992
which requires the EPA to promulgate regulations which identify
LBP hazards, lead-contaminated dust, and lead-contaminated soil.
An EPA regulation containing the guidance is anticipated to be
promulgated by October 1997.
This interim guidance was published due to the increasing number
of requests for advice on residential LBP hazards, including
hazards from lead-contaminated dust and soil in and around homes.
Lead levels and other conditions contained in the guidance are
designed to be used by decision makers (i.e., risk assessors,
risk managers) to identify LBP hazards, sources of lead exposure,
and the need to control actions in residential environments where
children may be present.
This guidance is not to be applied in addressing potential
threats from lead at CERCLA Response Actions and RCRA Corrective
Action sites. Guidance developed by the EPA Office of Solid
Waste and Emergency Response is the appropriate tool for
addressing Corrective Action sites.
A copy of the Federal Register notice is available through PRO-
ACT.
TECHNICAL INQUIRIES
PRO-ACT has received several requests regarding product
substitutes, training requirements, and regulatory issues. The
following are summaries of recently completed technical inquiries
(TI) you may find interesting:
R-12 Refrigerator Substitute, TI 6753: According to Mr. Scott
Custer, Automotive Refrigerant Engineer, WR-ALC/LVR-1, DSN 468-
2927, R-406A is an approved substitute for R-12 refrigerant and
is available for USAF use, in stationary air conditioning units.
R-406A is a blend of hydrofluorocarbon (HCFC) 22, HCFC 142b, and
isobutane, and is considered a transitional alternative because
both HCFC 22 and 142b are Class II ozone depleting substances
(ODS) scheduled for phase-out beginning in 2010.
HAZWOPER Training Requirements, TI 6604: Additional guidance is
available on hazardous waste operations and emergency response
(HAZWOPER) training requirements. "Hazardous Material and
Hazardous Waste Training Policy Letter," HQ USAF/CEVC, 14 July
1995, addresses HAZWOPER training requirements and includes
additional guidance on training for: accumulations point; first
responder; treatment, storage, and disposal facility; and clean-
up team personnel.
Trichloroethylene Ban, TI 6554: Periodically, PRO-ACT receives a
request regarding an alleged ban of trichloroethylene (TCE). To
date, PRO-ACT has been unable to locate any documents banning the
use of TCE. In fact, the July 1995 edition of the Federal
Logistics Data on Compact Disk lists the USAF as an active user
of several National Stock Numbers for technical grade TCE. TCE
has not been banned, however its use is limited and must be
carefully controlled due to environmental and occupational health
(including carcinogenicity) concerns.
Propane-1,2-diol-Based Deicer, TI 6870: PRO-ACT has learned a
new deicer based on propane-1,2-diol is being considered for use
by some installations. While this may appear to be a new deicer,
propane-1,2-diol is another name for propylene glycol (Chemical
Abstract Number 57-55-6).
PMB Recycling, TI 6759: As a result of recent articles
concerning recycling of plastic media bead (PMB) blast material,
PRO-ACT has received numerous requests for clarification on the
applicable regulatory requirements. Simply stated, spent PMB
scheduled for recycling does not require management as a
hazardous waste providing it is recycled by a method which
excludes it from being a solid waste and it is not reclaimed.
This is true regardless of whether the spent material would
exhibit any of the characteristics of a hazardous waste.
Title 40 Code of Federal Regulations (CFR), Part 261.1, "Purpose
and scope," states that a material is considered reclaimed if it
is processed to recover a usable product or if it is regenerated.
40 CFR 261.2, "Definition of solid waste," states materials are
not a solid waste when recycled, providing the materials are
recycled by being:
* Used or reused as an ingredient in an industrial process to
make a product, provided they are not to be reclaimed;
* Used or reused as effective substitutes for commercial
products; or
* Returned to the original process from which they are
generated, without first being reclaimed. The material must
be returned as a substitute for raw material feedstock, and
the process must use raw materials as principal feedstock.
Water-Based Aerosol Paints, TI 6724: The Paints and Chemicals
Commodity Center, General Services Administration (GSA), has
stock-listed 52 acrylic latex enamel paints of various colors.
According to Ms. Pat Finch, Chemical Engineering, GSA, (206) 931-
7926, these paints (procured to Commercial Item Description A-A-
2787) are the most environmentally friendly paints available in
the government supply system. While environmentally compliant,
these paints still contain minimal amounts of solvents. specific
National Stock Numbers and color numbers are available in the GSA
Supply Catalog or from PRO-ACT.
AIR FORCE POLLUTION PREVENTION STRATEGY
The USAF pollution prevention strategy was recently revised to
reflect changes in environmental laws, executive orders, and new
Department of Defense policies and goals.
According to a 24 July 1995 Secretary of the Air Force letter,
"Air Force Pollution Prevention Strategy," the objectives of the
revised policy include the following:
* Permeate all mission areas with the pollution prevention
ethic through comprehensive education, training, and
awareness;
* Institutionalize pollution prevention into all phases of the
weapon system life cycle;
* Incorporate pollution prevention in all aspects of
installation operations; and
* Develop and transition innovative pollution prevention
technologies to the field.
Specific sub-objectives and definitions are also included in this
letter. For a copy of this letter or more information about the
USAF pollution prevention strategy, please contact PRO-ACT.
STRAIGHT FROM PRO-ACT...
PRO-ACT's 1,000 Technical Inquiries Club
The PRO-ACT 1,000 Club was established in July 1994 to recognize
the accomplishments of our personnel in their service to you.
When a researcher completes 1000 technical inquiries, they
receive a commemorative plaque at a luncheon with the members of
PRO-ACT and the Pollution Prevention Directorate, Headquarters
Air Force Center for Environmental excellence (HQ AFCEE/EP). To
date, the club consists of four members, Jim Lanoue, Tom Cain,
Carl Lehman, and Laurie Grams. Jim Lanoue recently received his
second plaque for achieving 2,000 Tls. Laurie Grams is the first
of the Support Staff to join the club. Congratulations ya'll!
NICKEL-CADMIUM (Ni-Cad) BATTERY RECYCLING (REVISITED)
In our CrossTalk Edition 15, 1 August 1995, we announced a
recycling service for dry Ni-Cad batteries through the
Rechargeable Battery Recycling Corporation (RBRC). RBRC requires
an indemnification clause to be signed when registering for
participation in the battery recycling program. Federal
facilities are not authorized to sign the indemnification
statement due to provisions in the Anti-Deficiency Act. However,
the recycling facility, INMETCO, Inc., used by RBRC, has waived
the requirement for signing the indemnification statement for
Federal facilities. The indemnification clause is located in the
registration application available through RBRC. A hand written
statement stating your organization is a Federal facility and not
authorized to sign, will be accepted in lieu of signature. The
registration forms should be submitted directly to INMETCO at the
address below. Registration is required prior to shipping used
batteries to the recycling facility. Additional information can
be obtained from Mr. John Liotta, INMETCO, (412) 758-2802.
Registration applications can be obtained by contacting Mr. David
Thompson, RBRC, (201) 934-4204.
INMETCO, Inc.
245 Portersville Road
Ellwood City, PA 16117
Reminder: Battery shipments must be processed and shipped in
accordance with State and Federal regulations.
The AFCEE Team - Recognized as a customer-oriented leader and the
preferred provider of environmental planning, design, and
construction services.
CrossTalk - Edition 17
SEPTEMBER/OCTOBER 1995
TI #7020
Need more information?
Call PRO-ACT
DSN 240-4214 (800)233-4356
Last Updated: November 27, 1996