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Environmental Program Branch
Waste Management Proposal For
Inorganic Zinc Paint Waste
December 2005
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OUTLINE
● PROBLEM STATEMENT
● BACKGROUND
● NASA/USA WASTE MANAGEMENT PROPOSAL
● PROPOSED WASTE MANAGEMENT PROCESS
(VISUALS)
● CONCLUSIONS
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PROBLEM STATEMENT● Inorganic Zinc Paint
– Generation of Waste Stream
♦ Caused by delays and work stoppages due to inclement weather conditions
♦ Produces 80% of IO zinc waste volumes
● Off-gassing
♦ Releases VOCs, hydrogen gas and CO2 as by-products of mixture
♦ Uncured materials cause bulging of waste drums when closed
♦ Occurs in solid AND liquid waste streams (if residual solids are present)
♦ Paint Manufacturer’s guidance specifically address bulging and off-gassing associated with personnel safety concerns
● Regulatory Requirements
♦ Under RCRA, waste containers are to be closed -- opened only to add or remove waste
♦ Subpart CC and CAA rules for VOC emissions conflict with MSDS guidelines and accepted safety rules
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BACKGROUND
● CURING PROCESS
– Once mixed, off-gassing continues until fully cured
– A 1-gallon IO zinc kit can take weeks or longer to cure in original
container
– Without a vent, drum bulging occurs within a few hours
– 55-gallon drums (with vents) could take months to fully cure
♦ Thick layers and smaller surface areas take much longer to cure
– Larger surface areas (in thin layers) allow overnight curing
– Containers must remain open to allow for complete curing
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Inorganic Zinc Paint Plan
USA’s K6-1896 (Construction Management) 90 day Hazardous Waste Site
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CURRENT PRACTICES
● Solid materials collected as a hazardous waste in drums with
relief valves installed
– Zinc is very heavy, drums are filled half-full due to container weight
limitations
● Liquid waste stream, after proper decantation, is collected &
managed as a hazardous waste, with relief valves installed
– Relief valves must be removed prior to shipping to KSC’s TSDF
● JBOSC also installs pressure relief valves and gauges at the
TSDF
– While in storage, this requires TSDF personnel to monitor waste
containers after 90-day limit
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NASA/USA WASTE MANAGEMENT PROPOSAL
● Submittal of permit letter requesting a Title V Air Permit Insignificant List (activity # 6) language change, amending
as follows:
replace “Mixing/Coating Operations, including the emissions
from the air drying of empty cans and excess two-part epoxy
paints prior to their disposal”
with “Mixing/Coating Operations, including the emissions
from the air drying of empty cans and excess two-part
convertible coatings prior to their disposal”
● This would allow the inclusion of inorganic zinc coatings
● Maximum VOCs from IO Zinc operations: 3.348 TPY
–Refer to calculation sheet for additional data
● If approved, USA operations will segregate and cure paint at field worksites, or (occasionally) at the K6-1896 hazardous waste facility
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NASA/USA WASTE MANAGEMENT PROPOSAL
● Liquids will be decanted to allow for the in-process segregation of
liquids and solids
–Segregation of liquids and solids will generally be completed overnight,
using loosely covered containers, in a controlled, weather protected area
designated by USA
–Liquids will be separated (decanted) and managed as hazardous waste
and removed to the K6-1896 hazardous waste site NLT COB daily
● If approved, ALL mixed unused inorganic zinc solids/slurry will be
allowed to cure, as follows
–Placed in a loosely covered container, in a controlled, weather protected area designated by USA. Trays, with larger surface areas, are preferred over 5 gallon containers, as shown in the photos.
–Thin layers cure overnight, and will be removed the next business day, and managed in accordance with PWQ/TRP guidance
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NASA/USA WASTE MANAGEMENT PROPOSAL
● Cured material will be placed in approved containers for off-site
disposal, or as directed, in containers for recycling or landfill
disposal
● USA environmental will immediately provide specific training and
guidance to involved USA and subcontractor personnel
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PROPOSED WASTE PROCESS
Covered, Lined Cure Pan
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PROPOSED WASTE PROCESS
Pouring Waste IO Zinc Paint Into Lined Cure Pan
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PROPOSED WASTE PROCESS
Solid, Partially Cured IO Zinc Added To Cure Pan…
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PROPOSED WASTE PROCESS
…Must Still Be Broken Into Smaller Pieces To Finish Curing
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PROPOSED WASTE PROCESS
Placing Cured IO Zinc In Container For Disposal
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PROPOSED WASTE PROCESS
Preparing Cure Pan For Reuse and
A Container Of Cured IO Zinc Paint
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• KSC/USA is one of largest users of IO zinc paint in Florida
• KSC and its contractors strive to minimize the generation of excess
material through weather forecast monitoring, limiting pot sizes, and
managing scheduled work times• Price/gallon of IO zinc paint: $28 to $32
• Currently, USA is continuing corrosion control operations in the safest manner possible
• NASA/USA request timely consideration and response, in light of the safety and environmental compliance issues involved
• Approval of this proposal will substantially reduce or eliminate the risks to personnel, and will protect life, property, and the environment
CONCLUSIONS
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Inorganic Zinc Paint Plan