Complying with Executive Order 12856 at USCG Base South Portland
Intern: Carey Fillmann
(207) 363-5160
Project: South Portland Coast Guard Base
Contact: Gerald Tipton
Environmental & Safety Manager
259 High Street
South Portland, Me. 04106
(207) 767-0325
Executive Summary
Executive order 12856 requires that all federal agencies comply with the
Community Right-to-Know-Act and Pollution Prevention Requirements. UNH,
US EPA, and US Coast Guard formed a partnership to aid in compliance with
EO 12856. The Coast Guard base is South Portland Maine was chosen as a
test site to find working solutions in the field. Since October 1994 many steps
have been taken to develop a working model that other federal facilities can use.
This paper describes the steps taken from the planning stage to implementation
of the solution.
Background
On August 3, 1993 President Clinton signed Executive Order 12856
requiring all federal facilities to comply with Right-to-Know Laws and Pollution
Prevention Requirements. This act requires all Federal Facilities to comply with
Emergency Planning and Community Right to Know Act (EPCRA) and the
Pollution Prevention Act. A voluntary goal of 50% reduction in waste generation
and toxic releases was set to be achieved by 1999.
A partnership was formed between University of New Hampshire, EPA
New England, and the US Coast Guard in order to develop a plan that other
federal facilities could follow to comply with EO 12856. The South Portland
Coast Guard Base was selected as a test site because it is a medium sized
facility at which actual field problems could be worked out. The methods
developed during this project would be used as a model to benefit other federal
facilities.
Approach / Methodology
In complying with EO 12856 the EPA recommends the development of a
baseline. A comprehensive picture of the material usage and disposal patterns
must be developed. To begin with a material balance of the entire base was
conducted to determine all chemicals entering and exiting the base. (Results are
in graphical form in Appendix. ) In November 1994 an inventory was completed
to take a “snapshot” of what materials were currently being stored on the base.
From the initial inventory a chemical inventory database was created.
This provided a quick easy way to target pollution prevention opportunities. To
reduce pollution and minimize waste the storage location and use of all
chemicals must be known. The chemical inventory provided a way to maintain
and track all chemicals.
By looking at the chemical inventory database several opportunities were
presented. Material management needed to be standardized on the base.
Some type of control of existing material as well as control of the acquisition of
new material was needed. An authorized use list needed to be developed to
identify environmentally sound product substitutions. Information on waste
streams and cost of disposal was also needed.
In January 1995 the Coast Guard base developed a four character code
that standardized the material management system. The first two characters
identified the material use and type, and the second two characters identified the
material within the code series. (See appendix for code identification). The
code also linked each material with its material safety data sheet. This provided
a fast easy way to gather information during an incident.
In following the original approach the internal coding process helped gain
control of material acquisition. To order a material a purchasing chit must be
approved by the environmental office. To gain approval the sheet must be
coded and submitted with the MSDS. To order a new chemical the MSDS must
be submitted for approval. It is only approved if the material is not regulated or it
is an environmentally safe product substitution. The chemical inventory
becomes an authorized use list because if the material has a code it can be
purchased.
The chemical inventory also gained control of stored materials. Optimizing
purchases and inventory maintenance methods by purchasing materials in
useable quantities is a major source of pollution prevention. Just in time ordering
prevents disposal of material that has exceeded the shelf life. It also reduces the
amount of materials stored on the base. An upper and lower storage limit was
determined for each material by talking with personnel that use that particular
material.
As part of EPCRA a plan for emergency response must be given to the
local emergency response committee. The LERC is usually made up of the local
fire department and other community members. Many of the local fire
departments are using a computer program called CAMEO: Computer Aided
Management of Emergency Operations. This software was created by the
USEPA and NOAA to allow for quick information regarding a spill or chemical
fire. There are thousands of chemicals in the CAMEO database, this database
can be linked to the chemical inventory database. CAMEO also has the siteplan
for the base that shows where the EHS chemicals are stored. This allows the
LERC to locate the area of the incident quickly and determine the immediate
strategy.
Project Results
Several goals were set to be completed during the ten week period this
summer. Complete the coding of all material in the database, request any
missing MSDSs, enter chemical abstract service (CAS) numbers into the
database, link the database to CAMEO, gather information on a bar-code
scanner, and to transfer information on this project to other federal facilities. It
was discovered that a second intern student would be needed in order to
complete all the goals that were set.
Completion of the database took the first few week of the summer. Over
half of the material had to be coded. Material that was incorrectly coded had to
be recoded. CAS numbers were entered into the database from the MSDS.
Less than half of the materials in the inventory had an MSDS. Jennifer,
the second intern, started with this project. She spent over a week printing
MSDSs from a CD ROM. There are still about 200 materials without an MSDS.
She spent the rest of the summer adding the corresponding code to each MSDS
and alphabetizing the master MSDS books. Jennifer also photocopied and
coded the MSDSs for the chemicals in each building.
In July plans were made to organize a conference to allow other facilities
to benefit from the work done in South Portland. The conference was held on
August 23 and 24. Coast Guard members from Virginia, New York,
Connecticut, and Headquarters in DC attended. As well as state and federal
environmental officials. Overall the conference was a success and word of this
project is getting out.
In preparation for the conference several goals were met. First EPA New
England came to South Portland to assist in linking the database to CAMEO.
Thirty-six chemicals were linked to CAMEO and to the siteplan within the
CAMEO program. This was done as a demo for the conference. Several
decisions have to be made before the entire database is linked to CAMEO.
Information about a bar-code reader was also found for the conference.
Computerease, a Portland based company, demonstrated a bar-code scanner
and software to easily download inventory into the database.
Pollution Prevention Benefits
The biggest waste stream is bilge waste from the boats. This is mixture
of mostly water contaminated with oil and grease. An oily water separator is
being looked at as an alternative to paying by the pound to dispose of it.
The second biggest waste stream is oil. Over 2000 pounds of oil is
disposed of each year due to frequent oil changes on the boats. One way to
solve this problem is to recycle the oil, as well as recycle the antifreeze. This
closes the circle so that oil and antifreeze are no longer wastes. The problem is
that the engine manufacturer won’t warranty the engines when recycled fluids
are used. Talks are being initiated to see if something can be worked out.
Safety Klean, the degreaser used for parts washing, was also a major
waste stream. The machine was rented from the company and the cost of
disposal was included in this cost. In order to reduce this waste stream an
aqueous degreaser was purchased this summer. Personnel using this machine
are pleased with the results.
The next step in pollution prevention is looking at waste paint. Paint is the
most abundant chemical on the base. Several low voc substitutions have
already been made. Water based paints are one solution that is being looked
into. One problem with the paints is that the Coast Guard boats must meet
certain specs. The substituted paint must meet this.
The Future
This project is scheduled to continue until December. There are several
tasks that need to be accomplished. In the compliance timeline facilities need to
submit an annual progress report by October 1. Implementing the bar code
reader and updating the inventory list. Write a manual that is specific to the
chemical inventory database. Continue to develop pollution prevention plans
and research alternative products. To communicate with the rest of the Coast
Guard to keep this project going after December.
Phases Developed to Approach Project
Phase I:
Phase II:
Phase III:
Phase IV:
Phase V:
Phase VI:
Phase VII:
Phase VIII:
Survey and code the existing hazardous materials on the
base.
Create a chemical inventory database using DbaseIII+.
Inputting a four character code developed by the Coast
Guard into the chemical inventory database.
CAMEO and ALOHA training completed by UNH and the
Coast Guard.
Consolidate like items in the chemical inventory database
and print results.
Survey material data safety sheet file, request missing
MSDSs and distribute.
Analyze MSDS sheets to identify material that requires 302,
303, 304, 311, 313 consideration.
Load data into CAMEO and ALOHA and provide to Local
Emergency Planning Committee (LERC).