EPA/600/R-96/110
September 1996
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
UNITED STATES POSTAL INSPECTION SERVICE
FORENSIC AND TECHNICAL SERVICES DIVISION
NATIONAL FORENSIC LABORATORY
DULLES, VA
by
Carole O. Bell, Mary Hoel, John Nuckels, John Conrick
Science Applications International Corporation
Newport, RI 02840
,
1 SAlCProject?N6,!6i-6^:i4-67-if li-QiOi '
' : w'i< '' '- ''-' '''" " "
Project Officers
James S. Bridges
;and
'-' ; ; l '''bi'tri''T:
National Risk Management Research Laboratory
Cincinnati, OH 45268
This study,Was c'oniducted in cooperation with, the
:! : - * ' *'.,. ' ;:'.;.'t' ,! !' ,;, >," i 'J ^ ! ; ''," ,V i .-..' ''
United States Postal Service ' ' .
NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
u.s. ENVIRONMENTAL: PROTECTION AGENCY
CINCINNATI, OH 45268
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DISCLAIMER
The information in this document has been funded wholly or in part by the United States
Environmental Protection Agency under EPA Contract No. 68-C2-0148 WA 2-10 to Science
Applications International Corporation. It has been subjected to peer and administrative review
and it has been approved for publication as an EPA document. Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.
n
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CONTACT
James Bridges and N. Theresa Hoagland are the EPA contacts for this report. They are presently
with the newly organized National Risk Management Research Laboratory's Sustainable
Technology Division in Cincinnati, OH (formerly the Risk Reduction Engineering Laboratory).
The National Risk Management Research Laboratory is headquartered in Cincmhati, OH, and is
now responsible for research conducted by the Sustainable Technology Division in Cincinnati.
m
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FOREWORD
The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency
strives to formulate and implement actions leading to a compatible balance between human
activities and the ability of natural systems to support and nurture life. To meet this mandate,
EPA's research program is providing data and technical support for solving environmental
problems today and building a science knowledge base necessary to manage our ecological
resources wisely, understand how pollutants affect our health, and prevent or reduce
environmental risks in the future.
The National Risk Management Research Laboratory is the Agency's center for investigation of
technological and management approaches for reducing risks from threats to human health and
the environment. The focus of the Laboratory's research program is on methods for the
prevention and control of pollution to air, land, water, and subsurface resources; protection of
water quality in public water systems; remediation of contaminated sites and ground water; and
prevention and control of indoor air pollution. The goal of this research effort is to catalyze
development and implementation of innovative, cost-effective environmental technologies;
develop scientific and engineering information needed by EPA to support regulatory and policy
decisions; and provide technical support and information transfer to ensure effective
implementation of environmental regulations and strategies.
This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office of Research and Development to assist the
user community and to link researchers with their clients.
E. Timothy Oppelt, Director
National Risk Management Research Laboratory
IV
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ABSTRACT
The United States Postal Service (USPS) in cooperation with EPA's National Risk
Management Research Laboratory (NRMRL) is engaged in an effort to integrate waste
prevention and recycling activities into the waste management programs at Postal facilities. This
report describes the findings of the Pollution Prevention Opportunity Assessment of the United
States Postal Inspection Service, Forensic and Technical Services Division's National Forensic
Laboratory in Dulles, VA. The assessment was conducted during the week of November 14
1994.
The mission of each of the functional areas of the Forensic Laboratory including
operations performed, processes and materials employed and the wastes and emissions generated
is described. The Assessment Team makes recommendations concerning the procurement of
hazardous materials; management of hazardous materials; purchase of chemicals on USEPA's
33/50 list; regeneration of carbon filters, improvement of source separation and recycling of
paper and paper products, metals, and plastics; management of unwanted equipment; and other
recommendations that can lead to the elimination, reduction or improved management of the
facility's solid and hazardous waste streams and emissions to air and water.
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TABLE OF CONTENTS
DISCLAIMER ii
CONTACT iii
FOREWORD iv
ABSTRACT v
ACKNOWLEDGMENTS ix
1.0 INTRODUCTION 1
2.0 NATIONAL FORENSIC LABORATORY - - 2
2.1 FACILITY DESCRIPTION 2
3.0 SOLID WASTE 4
3.1 WASTE STREAM DESCRIPTION 4
3.2 SOLID WASTE DISPOSAL 5
4.0 AIRISSUES 7
4.1 HVAC SYSTEM 7
4.2 CHEMISTRYLAB 10
4.3 PHYSICAL EVIDENCE SECTION 10
4.4 LATENT FINGERPRINT SECTION 11
4.5 TECHNICAL SERVICES SECTION 11
5.0 WATERISSUES .12
5.1 LIMESTONE PH ADJUSTMENT PITS 12
5.2 CHEMISTRYLAB 12
5.3 PHOTOPROCESSING 12
5.4 PHYSICAL EVIDENCE SECTION 13
5.5 LATENT FINGERPRINTS SECTION 13
6.0 HAZARDOUS WASTE 14
7.0 FACILITY-WIDE POLLUTION PREVENTION OPPORTUNITIES 16
7.1 PROCUREMENT OF CHEMICALS AND LABORATORY SUPPLIES 17
7.2 LABELING 18
7.3 CHEMICAL STORAGE 18
7.4 OZONE DEPLETING SUBSTANCES 19
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7.5 CARBON FILTERS 20
7.6 CHEMICAL EVAPORATION 24
7.7 HEPA FILTERS 25
7.8 MONITORING PH ADJUSTMENT PIT 27
7.9 MAINTENANCE OF MECHANICAL SYSTEMS 28
7.10 RECYCLING CONTRACT 28
7.11 PAPER, PAPER PRODUCTS AND CORRUGATED CARDBOARD 30
7.12 CONTAMINATION OF RECYCLABLES 32
7.13 CUSTODIAL SERVICES '...'.' ','.'.33
7.14 UNWANTED EQUIPMENT '.. 34
7.15 AFFIRMATIVE PROCUREMENT 34
7.16 ENERGY 38
8.0 OPPORTUNITIES FOR FUNCTIONAL AREAS OF THE FORENSIC LAB 40
8.1 CHEMISTRY SECTION 40
8.2 FORENSIC PHOTOGRAPHY 41
8.3 TECHNICAL SERVICES 46
8.4 PHYSICAL EVIDENCE SECTION 48
8.5 LATENT FINGERPRINT SECTION 49
8.6 QUESTIONED DOCUMENT SECTION 50
9.0 CONCLUSIONS AND RECOMMENDATIONS 51
REFERENCES 52
APPENDICES 53
EPA 33/50 PROGRAM '.'.'.'.'.'.'.'.'.'.'. 54
OZONE DEPLETING SUBSTANCES 55
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EXHIBITS
2.1 NATIONAL FORENSIC LABORATORY FUNCTIONAL AREAS 2
3.1 FORENSIC LABORATORY SOLID WASTE STREAM 4
3.2 ESTIMATED ANNUAL SOLID WASTE VOLUME 5
3.3 COST OF SOLID WASTE COLLECTION 6
4.1 LAB VENTILATION FILTERS 8
4.2 VENTILATION SYSTEMS 9
6.1 HAZARDOUS WASTE DISPOSAL 14
7.1 POLLUTION PREVENTION OPPORTUNITIES 16
7.2 VENDOR LIST FOR ORGANIC ANALYZERS 21
7.3 CARBON FILTER OPTIONS 25
7.4 LOCAL RECYCLERS 29
7.5 REGIONAL PAPER MILLS : 31
7.6 EPA ESTABLISHED MINIMUM RECOVERED CONTENT LEVELS 37
8.1 PROCESS FLOW OF NEGATIVE AND PRINT DEVELOPMENT 41
8.2 PHOTOGRAPHY LAB MATERIALS 42
8.3 WASTES AND QUANTITIES PROCESSED IN ELECTROLYTIC SYSTEMS 43
8.4 PHOTOPROCESSING CHEMICALS RELEASED TO WASTEWATER ...44
8.5 WATER USAGE IN PHOTO LAB 45
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ACKNOWLEDGMENTS
Funding for this project was provided by the United State Postal Service under an interagency
agreement. Jim Bridges and Terri Hoagland of the EPA Office of Research and Development,
National Risk Management Research Laboratory managed the project and participated in the
opportunity assessments. Special thanks are extended to Charlie Bravo and Bernie Denno of the
USPS Office of Environmental Management Policy and the staff of the USPS Forensic
Laboratory.
IX
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SECTION 1.0 INTRODUCTION
The United States Environmental Protection Agency (EPA) is actively supporting the
development of pollution prevention program plans for Federal facilities. Since 1988, the EPA
has managed a technical support effort known as the Waste Reduction Evaluations at Federal
Sites (WREAFS) Program. WREAFS was established to provide pollution prevention solutions
to environmental issues through research, development and demonstration of pollution
prevention techniques and technologies, and transferring lessons learned within the Federal
community and related private sector support industries. WREAFS has conducted more than 37
separate RD&D efforts under funding from both EPA and nine other Federal departments and
agencies via interagency agreements.
The United States Postal Service (USPS) in cooperation with EPA's National Risk
Management Research Laboratory (NRMRL) is engaged in an effort to integrate pollution
prevention and recycling activities into the waste management programs at Postal facilities. Ilie
purpose of this project is to perform pollution prevention opportunity assessments (PPOAs) for
several types of USPS facilities, representing a cross-section of the USPS total inventory, to
identify the pollution prevention opportunities for those facilities, to recommend implementation
strategies and to develop facility guidance that can be incorporated into a revision of the USPS
Waste Reduction Guide.
This report describes the findings of the PPOA conducted for the United States Postal Inspection
Service, Forensic and Technical Services Division's National Forensic Laboratory in Dulles, VA.
The assessment was conducted during the week of November 14,1994. The report begins with a
brief description of the facility. This is followed by descriptions of the wastes and emissions and
recommendations that may lead to the elimination, reduction, or improved management of the
facility's waste streams.
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SECTION 2.0 NATIONAL FORENSIC LABORATORY
2.1 FACILITY DESCRIPTION
The mission of the National Forensic Laboratory is to confirm, through a meticulous
scientific investigation, the connection between a suspect and the evidence in a crime involving
Postal Service facilities or operations. This process includes:
collection of evidence,
careful evidence preservation,
detailed scientific analysis, and
effective courtroom presentation.
The National Forensic Laboratory in Dulles, VA is the only Postal Inspection Service
crime laboratory that examines physical evidence and performs chemical analyses. Exhibit 2.1
lists the functional areas within this laboratory. The Chemistry Section examines controlled
substances submitted by Postal Inspectors; Forensic Photography provides photographic support
to all the sections; the Physical Evidence Section examines explosive devices, firearms and
toolmarks; the Latent Fingerprint Section processes evidence to develop latent fingerprints;
Questioned Document Section identifies handwriting and establishes document authenticity; and
Technical Services supports a national communications network.
EXfflBIT 2.1 NATIONAL FORENSIC LABORATORY FUNCTIONAL AREAS
i^^ .
i i iaas
<> Chemistry Lab
Forensic Photography
ป Physical Evidence
ป Latent Fingerprints
ป Questioned Documents
ป Technical Services
The Postal Inspection Service operates four additional regional laboratories, responsible
for questioned documents, photography, and fingerprint identification.
The National Forensic Laboratory is situated in a rural industrial park several miles from
Dulles International Airport. Three other Postal Service facilities are located at this site: a Stamp
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SECTION 2.0 NATIONAL FORENSIC LABORATORY
2.1 FACILITY DESCRIPTION
The mission of the National Forensic Laboratory is to confirm, through a meticulous
scientific investigation, the connection between a suspect and the evidence in a crime involving
Postal Service facilities or operations. This process includes:
collection of evidence,
careful evidence preservation,
detailed scientific analysis, and
effective courtroom presentation.
The National Forensic Laboratory in Dulles, VA is the only Postal Inspection Service
crime laboratory that examines physical evidence and performs chemical analyses. Exhibit 2.1
lists the functional areas within this laboratory. The Chemistry Section examines controlled
substances submitted by Postal Inspectors; Forensic Photography provides photographic support
to all the sections; the Physical Evidence Section examines explosive devices, firearms and
toolmarks; the Latent Fingerprint Section processes evidence to develop latent fingerprints;
Questioned Document Section identifies handwriting and establishes document authenticity; and
Technical Services supports a national communications network.
EXHIBIT 2.1 NATIONAL FORENSIC LABORATORY FUNCTIONAL AREAS
Chemistry Lab
Forensic Photography
Physical Evidence
Latent Fingerprints
Questioned Documents
Technical Services
The Postal Inspection Service operates four additional regional laboratories, responsible
for questioned documents, photography, and fingerprint identification.
The National Forensic Laboratory is situated in a rural industrial park several miles from
Dulles International Airport. Three other Postal Service facilities are located at this site: a Stamp
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Distribution Network, a Vehicle Maintenance Facility and a Processing and Distribution Center.
The Forensic Laboratory is a two story building of approximately 44,000 square feet. The
facility employs 43 individuals: 20 forensic scientists, two photographers, 12 technicians, four
managers and five administrative support personnel.
Scientists from the Dulles laboratory respond to bombings and other crime scenes
nationwide. In addition, Postal Inspectors forward evidence to the laboratory. When evidence is
received, an evidence technician accepts delivery, dates the receipts, enters the information into
the computer records, and marks the evidence containers. The evidence is then directed to the
appropriate laboratory sections for analysis. The evidence and the packaging in which it is
received is part of the ongoing court case. Therefore, it is retained within the judicial system and
does not enter the waste stream.
The Assessment Team performed a multi-media assessment including solid waste
management; emissions to air, primarily from solvents that are allowed to evaporate; wastewater
emissions; hazardous material storage and hazardous waste disposal. The nature and volume of
the workload at the Forensic Laboratory is unpredictable, since it depends on the criminal cases
in which the Postal Inspection Service is involved. This inconsistent workload contributes to a
level of uncertainty relative to procurement of materials, waste disposal, and emissions
quantities. Material purchases and quantities of waste disposed or released to air and water may
vary considerably from month-to-month and year-to-year.
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SECTION 3.0
SOLID WASTE
This section describes the content and management of the solid waste stream generated
by activities of the Forensic Lab.
3.1 WASTE STREAM DESCRIPTION
The Forensic Laboratory's solid waste stream consists of paper and paper products,
metals, glass, plastics, wood, food and food contaminated paper. Exhibit 3.1 provides a
breakdown of the materials contributing to the solid waste generated by the Forensic Lab.
EXHIBIT 3.1 FORENSIC LABORATORY SOLID WASTE STREAM
Waste
Paper
Food
Metal
Glass
Plastic
Wood
Other
Waste Components
Mixed office paper, computer printout, corrugated cardboard, paperboard packaging, paper
towels
Food scraps, food contaminated paper products
Food and beverage containers, aerosol cans, paint cans, electronic equipment, wire
Containers from laboratory and photoprocessing chemicals, food and beverage containers,
broken laboratory glass
Containers from photoprocessing chemicals, food and beverage containers, gloves,
shrink/stretch wrap, bubble wrap, packaging peanuts
Pallets, cable spools
Toner cartridges, circuit boards, communication equipment, computer equipment, HEPA
filters, batteries
While the total volumes of materials will vary depending on the work load, Exhibit 3.2
represents the estimated annual volume of solid waste and recyclables, based on current hauling
records and observation of the waste stream during the assessment. The waste hauler could not
provide weights since solid waste from this facility is combined with waste from other facilities.
The hauler also could not provide weight or volume information for recyclables.
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EXHIBIT 3.2 ESTIMATED ANNUAL SOLID WASTE VOLUME
Paper 60.0%
Other 1.0%
Wood 2.0%
Lab Glass 7.0%
Mixed Containers 30.0%
Based on best professional judgment, the Assessment Team estimates that 22 cubic yards
of waste and recyclables are collected from the Forensic Lab annually. Volume to weight
conversion of the percentages of different materials in the waste, suggests that the annual weight
of materials collected is 63,000 pounds or more than 31 tons.
3.2 SOLID WASTE DISPOSAL
The Forensic Laboratory has contracted with Browning-Ferris Industries (BFI) to remove
and dispose of solid waste and biohazardous materials. This two year contract was signed in
February 1993. BFI provides one four-cubic yard container for solid waste. The container is
pulled on an on-call basis, typically once a month. The charge for each pull of this container is
$68.00. There are no additional transportation or disposal charges.
The Lab modified its contract with BFI on April 13,1994 to initiate a recycling program.
BFI provides weekly pick-up of the recyclable materials (Thursdays) from two dedicated
containers:, a four-cubic yard container for paper and paper products and a 90-gallon toter for
mixed food and beverage containers including aluminum, plastic and glass. BFI charges the Lab
$90.00 per week to collect the recyclables ($60.00 for the mixed office paper and cardboard and
$30.00 for the commingled materials). In addition, BFI charges a combined container rental fee
of $10.00 per month.
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All of the waste collection containers are located behind the laboratory, next to the
loading dock. At the time of the assessment, the materials in the solid waste container and the
materials in the paper recycling container were identical. Both containers were half-filled with
corrugated cardboard boxes and clear plastic bags containing mixed waste, primarily mixed
office paper and computer printout, aluminum cans, aerosol cans, and polystyrene cups. The 90-
gallon toter contained mixed food and beverage containers, as well as several 1-gallon brown
glass chemical containers and mylar sheets from the photo lab. A 3-cubic foot cardboard box
containing broken laboratory glass was wrapped in clear plastic and placed next to the toter.
Batteries are boxed and mailed to INMETCO in PA for destruction. The Postal
Inspection Service pays $0.28 per pound for management of Multiplier batteries; Motorola
batteries are accepted at no charge (see Section 8.3).
There has been only one event requiring disposal of biohazardous materials (see section
6.0).
Exhibit 3.3 provides a breakdown of the costs associated with solid waste collection at
the Lab.
EXHIBIT 3.3 COST OF SOLID WASTE COLLECTION
Solid waste including
laboratory glass
Paper and paper products
(corrugated cardboard)
Mixed food and beverage
containers
4-cu. yd.
4-cu. yd.
90-gallon
Frequency of
Collection
on call/typically once
per month
weekly
weekly
20 lbs./shipment
Cost
$68/pull
$240/mo. plus $5 rental fee*
$120/mo. plus $5 rental fee*
$.28/Multiolier battery
POTENTIAL >$438/MONTH
SOLID WASTE
COSTS:
* One half the container rental fee
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SECTION 4.0 AIR ISSUES
Air emissions from laboratory operations were a principal focus of this assessment. The
Assessment Team reviewed the heating, ventilating and cooling (HVAC) systems as well as the
activities of the individual sections of the Forensic Laboratory to determine the sources and
causes of air emissions. The Assessment Team found that air emissions are minimal, because of
low chemical use. The carbon filter system is more than adequate to capture the emissions.
4.1 HVAC SYSTEM
The HVAC system for the Forensic Lab is a sophisticated, integrated computer-
controlled system which regulates the temperature and humidity to maintain proper comfort
levels and provide safe ventilation of areas where harmful chemical vapors and fumes may be
present. The HVAC system can be divided into two basic components. The main component
contains the air handling units which heat and cool the building. The second component of the
system includes the laboratory ventilation systems and fume hoods.
4.1.1 Ventilation System
The ventilation system is divided into separate systems, each of which controls the
emissions from a specific area of the Forensic Laboratory. There are seven ventilation systems
that remove fumes or particulate matter from the functional areas. Each is equipped with high
efficiency particulate and carbon adsorption filters. Exhibit 4.1 provides a diagram of the filters
for the laboratory ventilation system. Three other systems are used for ventilation of the
bathrooms; however, the bathroom vents do not have particulate or carbon filters.
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EXHIBIT 4.1 LAB VENTILATION FILTERS.
From Fume
Hoods
The ventilation systems for the specific areas and laboratories consist of fume hoods with
outside makeup air and variable dampers, particulate and carbon filters, a variable speed fan, and
a stack exhaust on the roof. Each fume hood has a damper system which allows positioning for
specific types of chemicals and fumes. The dampers have settings for lighter than air fumes,
heavy gases, and high flow situations. Each ventilation system has a separate stack on the roof
which exhausts to the atmosphere. The ventilation systems within the Lab are integrated into the
overall heating and cooling system for the building. Fan speeds and dampers are automatically
varied by a computer control system to compensate for various users of the fume hoods in
specific areas. Makeup air, from either return air or outside air, is regulated to balance the entire
HVAC system.
A health hazard evaluation was performed by the USPS hi July 1993. As part of the
evaluation, the chemical fume hoods were evaluated. The evaluation found that the fume hoods,
in the laboratory areas, had adequate air flow and that air monitors indicated no concentrations of
solvents or chemicals exceeding acceptable limits.
4.1.2 Filters
1. Carbon Filters
Each of the laboratory ventilation systems is equipped with a carbon filter array. This
filter system is used to remove organic vapors and fumes from the exhausts of the fume
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hoods. The filter system is set up in an array of individual filters placed side by side and on top
of each other to form a matrix. Each carbon filter is constructed of six two-inch beds of carbon
placed in a fanfold design. Stainless steel grids hold the carbon beds and are attached to a
stainless steel frame. The filter arrays vary in size depending upon the amount of filters placed in
the system and the amount of flow exhausted through each system. Exhibit 4.2 lists the
components of the filter system. See Section 7.5 for a discussion of carbon filter management.
EXHIBIT 4.2 VENTILATION SYSTEMS
ro#
EF-l
EF-3
EF-4
EF-5
EF-6
EF-7
EF-8
EF-9
EF-10
EF-12
AHU-1
AHU-2
Description
Bathrooms
Bathrooms
Lab (Laser)
Instrument Room (Questioned Docs)
Lab (Fingerprint)
Superglue Hood
Chemistry Lab
Hoods (Physical Evidence)
Firing Range
Bathrooms
1st Floor AHU
2nd Floor AHU
# of Filters
None
None
1
1
6
2
9
2
1
None
8
16 (4 small)
2. High efficiency participate air filters (HEPA)
HEPA filters are used for both the ventilation systems and the air handling units. The
particulate filters for the ventilation system precede the carbon filters to prevent clogging of the
carbon beds with dust and particulates (see Exhibit 4.1). There are the same number of
particulate filters as carbon filters. The particulate filters are constructed of several layers of
various materials and meshes which are fitted into a wooden frame. These filters are placed hi a
similar array in each ventilation system.
Filters for the air handling units are placed so that return room air and/or outside air is
filtered before being chilled/heated and returned to the rooms. The filters for the air handling
units consist of cloth bags, attached to metal frames, placed in an array similar to the lab
ventilation particulate filters.
Approximately 48 HEPA filters are discarded into the solid waste stream each year.
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4.2 CHEMISTRY LAB
The Chemistry Lab, where instrumental analyses are conducted on drugs and other
substances, is located in the center of the south wing of the building. Each chemist has a
personal work station with an individual fume hood. Nine fume hoods are located on the outside
walls of the room. The instruments used in the lab include Gas Chromatographs (GCs) and High
Performance Liquid Chromatographs (HPLCs), as well as normal lab equipment, such as
analytical balances.
The room ventilation is fully automatic and is controlled by sensors placed hi the ducts.
The sensors are linked to a computer that regulates the flow parameters according to a pre-set
program. The fume hoods operate on normal ventilation air provided to the room, but the
exhaust is ducted to a filter and separate stack. There are no individual control switches on the
fume hoods; two of the hoods operate continuously. There is a flow control meter on each hood,
which indicates whether the flow rate is within specifications. If the flow falls outside the
specification range, staff must notify the building engineer who will initiate the corrective action.
Each work station is equipped with a small stock of regularly used chemicals, such as
solvents. These are stored hi the cabinets under the hoods and are separated according to
reactivity. Typical volume stored under each hood was less than four liters.
The bench chemicals used by each chemist were in very small quantities (approximately
25 mis) which reflects the type of chemical testing taking plaqe in the laboratory. Initial micro-
scale testing is performed before instrumental analysis. The normal testing is typically
presumptive color and spot tests which give the chemists an indication of the class of compounds
with which they are dealing. Air emissions created by this type of testing are limited to solvents
used in the preparation of the reagents. Annual quantities used are probably no more than 100
mis per chemist.
Additional air emissions are generated from the disposal of some chemicals used hi the
chemistry lab. Standard practice for most chemical disposal is to allow the materials to
evaporate under the hoods. The emissions are subsequently captured in the carbon filter beds of
the ventilation system.
4.3 PHYSICAL EVIDENCE SECTION
The Physical Evidence Section performs investigations of explosive devices. Since the
physical evidence analysts typically deal with fragmentary evidence, the preliminary
investigation, prior to instrumental analysis, is on the micro scale.
The instrumentation available to the physical evidence technicians represents state-of-the-
art equipment. The type of analyses conducted with the instrumentation typically utilize non-
toxic gases and liquids. Again, the size of the samples presented to the instrument for analysis is
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such that there is only a few milliliters of liquid present. The types of gases used in equipment,
such as GCs, include high-purity nitrogen and helium with hydrogen and air used for detector
fuel, if flame-based detectors are used. With the use of capillary columns in GCs, the flow rate
of gases is in the range of 1 ml/min, unless make up gas is utilized to maximize the sensitivity of
the detector. Since the gas effluent from the column and any flame detectors is of minimal
volume and non-toxic, it is vented directly to the room exhaust system.
During the maintenance of the instrumentation larger volumes of air emissions may be
created. However, hi the Forensic Laboratory, maintenance of modern instrumentation is limited
to technical service calls and does not generate air emissions. For instruments, such as the Mass
Spectrometer, there is the occasional cleaning of the ion source which can generate, a few liters of
solvents. Since this operation is conducted within a fume hood, the solvents typically are
allowed to evaporate and are subsequently captured hi the carbon filter beds. See Section 7.5 for
a discussion of management of the carbon filters.
4A LATENT FINGERPRINT SECTION
Another section that uses chemicals that contribute to the air emissions from the facility
is the fingerprint section. The examiners hi this section develop and identify fingerprint
impressions left on items or at crime scenes. The two main techniques used to develop the prints
are the cyanoacrylate or Superglue process and the ninhydrin spray process. In the glue process,
drops of Superglue are heated hi an enclosed case so that the solvent fumes from the glue make
the fingerprints visible. This work is performed hi a chamber in a fume hood and all vapors are
exhausted through the hood exhaust system and are captured by the in-line carbon filter.
The ninhydrin process uses a solution of ninnydrin hi a solvent carrier, mainly to develop
fingerprints on paper items. Again, this process is completed in a fume hood with the emissions
captured in the carbon filter. The use of these chemicals is very limited and does not represent a
major source of emissions.
4.5 TECHNICAL SERVICES SECTION
Air emissions from the Technical Services section are generated principally from aerosol
solvents and degreasers used in the repair and maintenance of electronic equipment. Some
brands currently in use, Formula 111 and Gold Guard, for example, contain 1,1,1-
trichloroethane, which is a Class I ozone depleting substance and is included on USEPA's 33/50
list of 17 hazardous chemicals targeted for reduction.. See the appendices for additional
information on Ozone Depleting Substances and the 33/50 Program. Postal Service policy
encourages replacement of ODS if an alternative product that meets performance specifications
is available. The Assessment Team was unable to determine the quantity of these products
purchased annually. Procurement records are maintained by distributor. The Technical Services
staff could not readily determine which distributor was the source of these products, the
quantities purchased or, the amount currently in stock.
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SECTION 5.0 WATER ISSUES
Wastewater generated from laboratory operations was another focus of this assessment.
The Assessment Team reviewed the internal drainage system of the facility, the acid
neutralization pits and the activities of the individual sections of the Forensic Laboratory to
determine sources of waste water. Team members also spoke with the Loudon County
Sanitation Authority concerning local POTW requirements.
5.1 LIMESTONE PH ADJUSTMENT PITS
The Laboratory staff generate acid wastes and dispose of them in lab sinks. The wastes
are routed through the acid waste drainage system to limestone pH adjustment pits. There are
two limestone pits: one principally serves the chemistry lab, while the other serves the
photographic section. The two separate pits provide a margin of safety for the building by
ensuring that incompatible chemicals are not inadvertently mixed before they are neutralized in
the limestone pits. The photography section uses a significant amount of oxidizers that could
present a potential problem if the streams were not segregated.
Each of the limestone pits has a volume of one cubic meter, with the inlet pipe entering
beneath a bed of packed coarse limestone. The outlet is located above the limestone bed so mat
the neutralized effluent flows into the sewer system when the level reaches this discharge point.
The projected lifetime for each pit is three to five years.
5.2 CHEMISTRY LAB
The volume of chemicals utilized by the chemists is usually a drop or two per test;
therefore, the residue is discarded into the acid drain. Also, niinimal volumes of liquid are
generated by the HPLC system and discharged directly to the sewer system.
5.3 PHOTOPROCESSING
Employees in other sections of the laboratory also use chemicals hi their normal daily
work. The most significant of these users is the Photography Section, which generates a
significant volume of chemicals hi the development of photographs. All of the chemicals used in
the photography lab are specially purchased for the purpose of photographic development and are
suitable for sewer discharge following use and neutralization by the pH adjustment pit. Any
material that contains silver salts is passed through an on-site silver recovery unit before draining
to the neutralization pit. Most of the developing processes are now automatic with little operator
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intervention. The automatic nature of the equipment limits further efforts to minimize use of the
chemicals and any associated emissions.
5.4 PHYSICAL EVIDENCE SECTION
The Physical Evidence Section operates a small firing range on the lower level of the
Forensic Laboratory. Weapons may be fired into targets in front of a complex of rubber strips or
into a 450-gallon tank of chlorinated water. Bullets are recovered for analysis and comparison
with bullets from criminal investigations. The water is filtered to recover small lead particles and
other firing residues. While Physical Evidence staff could not quantify the amount of lead
generated, they indicated that the amount was minimal. When the tank is drained, the water
flows directly to the sanitary sewer.
5.5 LATENT FINGERPRINTS SECTION
The Latent Fingerprint Section occasionally uses a laser system to identify fingerprints on
non-porous surfaces. The laser equipment requires a constant flow of water to maintain the
temperature of the apparatus. The water passes through the machine and is discharged directly to
the sanitary sewer.
13
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SECTION 6.0
HAZARDOUS WASTE
Hazardous waste generation is minimal, since most hazardous materials are utilized in
very small quantities. The Forensic Laboratory has had occasion to dispose of hazardous waste
only once in the past three years. The waste consisted primarily of expired chemicals.
Environmental Management Services, Inc. in Rockville, MD collected and disposed of the waste
for $1,983.50. Exhibit 6.1 lists the kinds and quantities of materials disposed. In addition, there
has been one event involving disposal of biohazardous materials resulting from a bombing
incident. These materials were handled by BFI at a one-time cost of $39.
EXHIBIT 6.1 HAZARDOUS WASTE DISPOSAL
Chemical
Approximate Quantity
Aluminum chloride
3/4Ib.x2
Aluminum sulphate
4 oz.
4-Aminoantipyrine
25J..
S-Amino-2,3-dihydro-l,4-phthalazinedione
25 g.
3-Aminophthalhydrazide
10 g.
Aniline Brown C.I. 606
2oz.
Aniline Blue C.I. 707
10 g.
Aniline Blue C.I. 707
2oz.
2-Aminothiophenol
Aniline sulfate
4oz.
Antimony thichloride
1/4 Ib.
Arsenic trioxide
4 oz.
Cadmium iodide
4 oz. x 2
Cadmium sulfate
4oz.
beta-Carbonaphthoxycholine iodide
250 mg.
Congo Red C.I. 370
50 g.
Copper oxide
1 oz.
2,5-CyclohexadienAl,a'-dimalononitrile
Dibenzyl phthalate
25^
Dihydroxydiphenyl sulfone
lib.
4,S-dihydroxy-2,7-naphthalenedisulfonicacid
3.3'-dimethoxybenzidine
Ib.
Diphenylbenzidine
JJL
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EXHIBIT 6.1 HAZARDOUS WASTE DISPOSAL
Chemical
Dimethyl glyoxime
Diphenylamine
Ferric nitrate
Fuchsin-Basic
Iron ferrocyanide
Giemsa Blood Stain
Iodine
Indoxyl acetate
Lead, acetate
Lead, arsenate
Lithium hydroxide
Magnesium acetate
Magnesium oxide
Mercuric nitrate
Mercuric potassium thiocyanate
Mercuric oxide
beta-Naphthyl acetate
l,2-Naphthoquinone-4-sulfonic acid sodium salt
Nigrosin alcohol soluble
Nickelous chloride
Nickelous sulfate
Phenolphthalein
Phloroglucin
Phenylhydrazine hydrochloride
Potassium ferrocyanide
Potassium ferricyanide
Potassium iodate
Potassium thiocyanate
Potassium oxalate
Sodium cyanide-
Thioacetamide
Toluene sulfonic acid monohydrate
Thycdene (iodimetry indicator)
Approximate Quantity
1 oz.
21b.
1/4 Ib.
50 g.
1 Ib.
4oz.
1/4 Ib.
lg.
lib.
'/2g.
4oz.
lib.
J4 Ib.
1 oz.
4oz.
4oz.
5g.
10g. + 25g.
100 g.
1/4 Ib.
1/4 Ib.
1 oz.
1 oz.
1/4 Ib.
Ilb.x4
1 Ib.
4 oz.
lib.
lib.
4 oz.
1/4 Ib.
'/2 Ib.
lg.
15
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SECTION 7.0
FACILITY-WIDE POLLUTION PREVENTION OPPORTUNITIES
This section describes pollution prevention opportunities that have the potential to affect
waste generation and waste disposal quantities and costs at multiple operations within the
Forensic Laboratory. Exhibit 7.1 presents the site-wide waste generation issues and potential
pollution prevention opportunities.
EXHIBIT 7.1 POLLUTION PREVENTION OPPORTUNITIES
Waste or Waste Source
Procurement
Carbon Filters
HEPA Filters
Paper waste reduction
Recycling
Energy
Pollution Prevention Opportunities
Centralize procurement
Establish material tracking system
Reduce credit card purchases
Purchase products containing recycled content
Eliminate purchase of products with EPA 33/50 chemicals
Measure filter breakthrough
Convert to commercial grade carbon
Establish a filter change-out schedule
Regenerate the carbon
Avoid evaporating solvents in the fume hoods
Change filters based on drop in pressure
Perform duplex copying
Use electronic mail
Limit distribution lists
Reuse envelopes, paper and packing materials
Recycle paper and paper products
Establish a multi-facility recycling contract
Train staff and custodians in source separation
Establish lights out policy
Purchase energy efficient lighting
Procure Energy Star compliant computer equipment
16
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7.1 PROCUREMENT OF CHEMICALS AND LABORATORY SUPPLIES
Current Conditions l .
The facility currently employs a decentralized chemical ordering system that devolves the
responsibility for ordering chemicals and other laboratory supplies to the department heads for
each of the sections. Each section head has a separate annual budget as well as a credit card for
individual purchases up to $2,000. The section head is solely responsible for purchasing for the
section. This system has, on occasion, led to chemical overstocking towards the end of the
financial year when the supply budget may still show a surplus. Such bulk purchasing creates
the potential for excess chemicals to be stored beyond their useful life or expiration date. These
chemicals would then be disposed as hazardous waste, at substantially increased cost for the
facility. The cost of this disposal could outweigh any budgetary advantage accrued by
overstocking. Forensic Lab personnel do not consider this a significant concern.
Pollution Prevention Opportunities
1. Laboratory management personnel indicated that there is a computer program already
available on the facility computer system for chemical inventory tracking. It is not in use at the
present time. This system, or some other equivalent system, should be utilized to track all of the
current and future chemical inventory and optimize the ordering and stock rotation to avoid the
need to dispose of expired chemicals.
To accomplish such a task efficiently and effectively, ordering and stock/inventory
control should be centralized at the laboratory director level. This includes the budgeting for
supplies. The administration of this system could be delegated to support personnel who would
deal with ordering, receipt, tracking, and invoice payment for all chemicals and other laboratory
supplies.
There is a specifically designed chemical storage room near the Chemistry Section where
the chemical inventory could be stored easily. The quantities of supplies on hand should be
audited at regular intervals (three to six months) to confirm ordering and use patterns created by
the centralized control system. Such a system would eliminate over-ordering arul excessive
inventory and would promote more efficient use of resources. Removing technical management
personnel from this type of administrative duty and transferring the responsibilities to support:
personnel would maximize available expertise for technical projects. The implementation of this
type of inventory system will reduce future chemical disposal and initiate greater control within
the laboratory system.
Since micro-scale chemical analysis and testing is practiced, a hazardous material
pharmacy operation, in which unused chemicals are returned to a central point of distribution, is
probably not necessary.
17
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7.2 LABELING
Current Conditions
The lack of consistent receipt labeling and inventory control practices is also a concern
relative to procurement. Some sections label the chemical containers with the date the material
was received and an expiration date, while other sections do not label any of their chemical
containers. This leads to a situation where there is no reliable means of deteraiining whether a
chemical is being held beyond the expiration date or not. For a forensic laboratory, this situation
has particular significance because questions concerning the suitability of particular chemicals
for use in a particular analysis may be raised in .a court of law.
Pollution Prevention Opportunities
1. Establish a single point of responsibility for receipt and labeling of chemicals. This
individual would be responsible for placing date received and appropriate expiration date labels
on all items in the inventory prior to then: storage in one central inventory location or distribution
to individual laboratories. The quantity of material appears too small to make the use of bar
codes feasible.
2. Label all chemicals with date received and expiration date (if applicable) to eliminate any
potential for questions to be raised concerning the possible unsuitability of chemicals used.
7.3 CHEMICAL STORAGE
Current Conditions
One situation noticed during the assessment of the laboratories that may be of concern
was storage of incompatible chemicals. This situation was confined to small quantities in non-
chemistry sections of the facility. In one instance, a strong acid was stored next to a strong base,
creating a potential hazard. In another section, a bottle of glacial acetic acid was stored next to a
strong oxidizer.
Pollution Prevention Opportunities
1. Although the storage of chemicals was excellent overall, oversight of the chemical
storage cabinets and under-hood locations by a safety chemist would prevent any possibility of a
future problem.
2. An in-house safety inspection should be conducted on a regular basis (possibly every
three to six months), hi conjunction with the chemical inventory, to eliminate any conditions that
may pose a risk to the facility.
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3. Representative staff should be sent to Hazardous Waste Operations and Emergency
Response (HAZWOPER) training to familiarize them with basic hazardous waste regulations
and safety, handling and labeling requirements appropriate to their facility.
4. Hold a staff seminar on hazardous material storage and hazardous waste storage and
disposal to promote a safe working environment.
7.4 OZONE DEPLETING SUBSTANCES
Current Conditions
The Technical Services section currently uses solvents and degreasers for repair and
maintenance of small components for electronic equipment. Several of these aerosol products
contain a Class I ozone depleting substance. Purchasing orders for these products are filed by the
name of the distributor, rather than the manufacturer. Thus, the Forensic Laboratory was unable
to determine when these products were last purchased, what quantity was in stock, or the cost per
container. ;
Pollution Prevention Opportunities
1. Facility managers should change the purchasing specifications to require a substitute
product that does not contain an ODS. Once current stock is exhausted, substitutes should be
purchased. Executive Order 12843, Procurement Requirements and Policies for Federal
Agencies for Ozone-Depleting Substances; signed in 1993, requires Federal agencies to comply
with Title VI of the Clean Air Act Amendments dealing with stratospheric ozone protection, to
maxirnize the use of safe alternatives to ozone-depleting substances, and to revise procurement
practices to eliminate the requirement for ozone-depleting substances.
One federal supply list of alternative products is the Defense General Supply Center (DGSC) List
of Environmentally Preferred Products (October, 1994). DGSC lists Enviro Klean, Formula
1000 manufactured by Allied Enterprises, Inc. as a possible replacement for 1,1,1
trichloroethane. This is a low VOC, non-CFC aerosol spray for degreasing various industrial
parts sand equipment. This product comes in a 16-ounce can for $4.00; the National Stock
Number (NSN) is 6850-01-061-5493. DGSC also publishes bi-monthly Hazardous Technical
Information Series Bulletins on new environmentally-preferable products. To be placed on the
mailing list, write to Defense General Supply Center, DGSC-SHS/HTIS, 8000 Jefferson Davis
Highway, Richmond, VA 23297-5670.
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7.5 CARBON FILTERS
Cu rrent Conditions
The Forensic Lab has 22 Flanders Model T-2V-N63-F16, GG-16, V-Bed Carbon
Adsorber Cells. These adsorber cells are located within 7 individual ventilation systems, the
largest of which includes nine cells. The carbon filters have an estimated life expectancy of three
years. Since the building is less than three years old, the carbon filters have not been changed;
however, they are due to be changed within the next year. The Forensic Laboratory proposes to
replace all 22 carbon filters at an approximate cost of $1,830 each for a total cost to the Forensic
Lab of $40,260.
Pollution Prevention Opportunities
1. The Forensic Lab should initiate a program to measure filter breakthrough.
Due to the varied use of the fume hoods, some of the carbon filter systems may have a much
longer life than the projected three years. Conversely, ventilation systems exposed to large
amounts of organic vapors might already be saturated. When saturation occurs, the vapors
"breakthrough" the filter media without being collected because the carbon can no longer adsorb
any organics.
To determine the most efficient changeout tune for the inline carbon filters, a method of
measuring filter breakthrough is needed. The duct chemical concentration can be measured and
tracked over a period of time so that the most efficient filter reactivation or replacement time can
be determined, preventing unnecessary expense. Breakthrough on carbon filters can be a sudden
event, so a consistent monitoring program should be implemented and a baseline removal
efficiency established. This program should monitor both the concentration entering the filter
and the concentration exiting the filter, so the removal efficiency can be determined. Monitoring
should be performed under a normal operating load. This may be difficult to define, since some
hoods may be used more than others. If normal load is not definable, then the Forensic Lab
could test a standard chemical load that is likely to exceed the normal operating load.
Some chemicals are adsorbed more effectively on carbon than others. In general, the
more polar the molecule, the less it is adsorbed by the carbon. Specifically, ketones tend to be
adsorbed less effectively than alcohols and chlorinated chemicals. As a result, the breakthrough
of ketones may signal the need for replacement of a filter.
The Forensic Laboratory can purchase an organics analyzer to determine breakthrough of
the carbon filters. This would require sampling of the exhaust stack of each of the ventilation
systems periodically to determine when breakthrough might occur.
There are several types of organic compound monitors available.
20
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Portable, non-specific electronic VOC analyzer The theory of operation is based on
either Photo lonization Detection (PID) or Flame lonization Detection (FID). Sensitivity
varies, depending on the compounds being detected, but the FID instruments have the
most universal response. Some organic solvents do not react to PID instruments. A
quantitative readout is usually available, although some units are qualitative in nature.
One sensor operates like a geiger counter for organics, providing readout in clicks per
second. This unit operates on rechargeable batteries.
Specific gas detector tube apparatus One of the most widely available ambient
analysis techniques is the gas detector tube system. This system uses a hand pump to
pass a known volume of air through a sorbent-filled glass tube. Each tube is specific for a
particular compound-or class of compounds and has a concentration scale printed on the
side. If the compound is present in the sampled air stream, a color reaction takes place
and the result can be read on the scale. While multiple tubes would be required, the tubes
are inexpensive and easy to operate. They are, however, single use disposables and
would have to be replaced for each reading.
Exhibit 7.2 provides a list of vendors and approximate costs of a variety of organics
analyzers.
EXHIBIT 7.2 VENDOR LIST FOR ORGANIC ANALYZERS
Company
Thermo Environmental Instruments
Sensidyne
Photo Vac
Aldrich
Location
MA
FL
NJ
MO
Detector
FID
PID
FID
FID
Detector Tubes
Cost
$7,300
$4,600
$4,990
$4,300
$450
2. The Forensic Lab should convert to commercial grade carbon. The Lab's filters currently
contain nuclear grade carbon. This finer carbon is designed to capture specific nuclear
particulates and is significantly more expensive than activated carbon. Activated carbon costs
$1.50 per pound; nuclear grade carbon costs $3.75 per pound. In addition, the nuclear grade
carbon must be certified at a cost of $1,000. It is unclear why the Forensic Laboratory is using
this particular grade of carbon. The carbon adsorption filters will work efficiently with activated
carbon and the Forensic Lab does not conduct any research that requires the use of radioactive
isotopes. The nuclear grade carbon currently in use makes carbon regeneration difficult for two
reasons:
companies are hesitant to accept nuclear grade carbon for regeneration because of fear
that it may contain radioactive isotopes
21
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regenerating nuclear grade carbon may damage the commercial carbon regeneration
process.
For these reasons, the nuclear grade carbon currently in use cannot be recycled and must
be sent to a suitable landfill. To reduce purchase and management costs and facilitate the
regeneration process in the future, the Forensic Lab should convert from nuclear grade to
commercial grade carbon.
3. A method to reduce the cost and disruption of replacing all of the carbon filters, which
could be used alone or in conjunction with a breakthrough detection system, is to reuse the filters
by regenerating the carbon within each filter.
The first consideration in a reuse program is to establish a rotating filter change-out
schedule. Instead of changing all the filters at once, the Lab could replace a few at time. To
establish this system, the Lab would need to purchase spare carbon adsorber cells that can be
placed into service while the spent carbon cells are being regenerated. This would enable the
Lab to avoid having to shut down a system while the filters are being regenerated.
The Lab could purchase at least nine spare adsorber cells to accommodate the largest
system (Chemistry Lab). To ensure the shelf life of the carbon, the cells must be kept in a air
conditioned space to minimize contact with moisture and dust. It is not absolutely necessary to
purchase these spare adsorber cells; however, if they are not available, each system would have
to be shut down for a period of time while the carbon is being regenerated.
Several carbon filter suppliers in the area provided information about then: regeneration
programs and cost estimates.
Filtrex Filtrex is the area distributor for Flanders filters and provides a carbon regeneration
service. Filtrex's service includes picking up the spent cells from the site and taking them to their
shop for processing. Because of housekeeping concerns, Filtrex recommends that the carbon
cells be removed from the site, emptied, cleaned, refilled with regenerated carbon, and then
returned to the site for placement in the system.
One-time purchase of nine spare filters
Nine Flanders Filters Model T-2V-C63-F16, GG-16, V-Bed Carbon Adsorber Cells.
Each adsorber is complete with an initial charge of commercial grade carbon. The price for the
nine spare filters is $13,846.00.
One-time cost of disposing of nuclear grade carbon
Filtrex has not been able to identify a company to recycle the nuclear grade carbon.
Therefore, this cost estimate is based on the removal of the nuclear grade carbon, placing it in
22
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drums, and disposal in a suitable landfill. Prior to disposal, the carbon must be tested to confirm
that it has not been exposed to any radiation contamination. The laboratory charge is $425 for
the testing of the carbon. If the nuclear grade carbon is found to have been exposed to
radioactive contaminants, the carbon will be returned to the USPS for disposal. A $250.00
delivery charge would be invoiced to the USPS, should the nuclear grade carbon be sent back to
the USPS.
Regenerating the carbon cells
Filtrex would pick up the spent cells from the loading dock at the Forensic Lab, bring
them to their shop for processing, i.e., removing the spent carbon, cleaning and refilling with a
recycled, activated carbon. Filtrex would then return the cells to the Lab for storage. The turn-
around time for regenerating the carbon cells ranges from four to five weeks for unscheduled
change-outs to one week for a scheduled change-out. If Filtrex processed nine adsorber cells at a
time, the total cost for regenerating 22 adsorber cells will be $6,172.00.
Cameron Carbon Inc.- Cameron Carbon is located hi Baltimore, Maryland. They are a major
carbon supplier and the carbon source for Filtrex and other carbon filter service companies.
One-time purchase of nine spare filters
Nine Flanders Filters Model T-2V-C63-F16, GG-16, V-Bed Carbon Adsorber Cells with
an initial charge of commercial grade carbon. Each filter costs $1,205. There is a freight charge
of $750 for the lot, for a total price of $ 11,595.00.
One-time cost of disposing of nuclear grade carbon
Cameron Carbon quoted a cost of $0.40 per pound for disposal of spent nuclear grade
carbon that was not contaminated with radioactive isotopes. Each filter contains 90 pounds of
carbon; 1,980 pounds at $0.40 per pound would total $792.
Regenerating the carbon cells
Cameron Carbon will pick up the spent cells from the loading dock at the Forensic Lab,
empty and refill with new carbon and ship the recharged cells back to the Forensic Lab. The per
cell cost is $108; for 22 cells the cost is $2,376. In addition, Cameron will charge a $950 freight
fee for each group of nine cells for a total cost of $4,726.
Complete Air Filter Company-- Complete Air Filter Company presently manages the HEPA
filters for the Forensic Laboratory. Complete Air Filter can also supply and regenerate the
carbon in the carbon adsorber cells.
23
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One-time purchase of nine spare filters
Nine Flanders Filters Model T-2V-C63-F16, GG-16, V-Bed Carbon Adsorber Cells with
an initial charge of commercial grade carbon. Each filter costs $1,600, including freight, for a
total price of $14,400.00.
One-time cost of disposing of nuclear grade carbon
Complete Air Filter Company is also having difficulty in identifying a source to recycle
the nuclear grade carbon. The carbon must be tested first to confirm that it has not been exposed
to any radiation contamination. The laboratory charge is $600 for the carbon testing.
Regenerating the carbon cells
Complete Air Filter Company will pick up the spent cells from the loading dock at the
Forensic Lab, bring them to their shop for processing, and then return the cells to the Lab. The
cells must be kept hi a conditioned space to minimize the contact with moisture and dust to
ensure the shelf life of the carbon. The total cost for regenerating 22 adsorber cells is $8,800.00.
The nuclear grade carbon installed in the filter system is expensive and difficult to
dispose. If the Postal Service plans to build additional forensic laboratories, future planning
should assess the types of work and materials that will be used. If work requiring radioactive
isotopes is planned, their use should be restricted to one location with a filter array specifically
fitted with nuclear grade carbon. Other filters could use commercial grade carbon to limit costs
and disposal problems. The system installed at the Dulles Forensic Lab is state-of-the-art;
however, it appears to be more sophisticated than necessary for the work performed.
Exhibit 7.3 below summarizes the options available for management of the carbon filters.
7.6 CHEMICAL EVAPORATION
Current Conditions
The Forensic Laboratory uses only small quantities of most chemicals. The Chemistry
Lab, Physical Evidence Section and Latent Fingerprint Section rely on evaporation of chemicals
under the fume hood as a disposal mechanism. This practice is based on the understanding that
the emissions are captured in the carbon filter beds of the ventilation system and are not released
to the atmosphere.
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Pollution Prevention Opportunities
1. The regulatory structure for air discharges is clearly advantageous for laboratories,
providing no clear incentive to reduce or eliminate air emissions. However, the cost of
regenerating the carbon filters indicates that the Forensic Laboratory should avoid the practice of
evaporating solvents in the fume hoods.
7.7 HEPA FILTERS
Current Conditions
Currently, particulate filters are changed quarterly. This quarterly schedule does not
directly correlate with use of the filters or the amount of dust accumulated during the operating
period. Particulate filters should be changed when the filters become clogged with dust and
particulate matter because clogged filters force the fans to work harder to distribute air through
the system.
EXHIBIT 7.3 CARBON FILTER OPTIONS
Option 1
Replace and dispose of 22 spent adsorber cells
Purchase costs
22 Flanders Filters Model T-2V-C63-F16, GG-16, V-Bed Carbon $32,150.00
Adsorber Cells from Flander's regional distributor, Filtrex. Each adsorber
is complete with an initial charge of commercial grade carbon.
Testing costs
The Forensic Lab is required to test the carbon before disposal to $230.00
determine whether the carbon is a hazardous waste.
Disposal costs
22 spent Flanders Filters at an estimated weight of 2,200 Ibs. as $1,760.00
nonhazardous waste.* Disposed by Environmental Management Services
at $80 per filter.**
22 spent Flanders Filters at an estimated weight of 2,200 as hazardous $2,860.00
waste. Disposed by Environmental Management Services at $130 per
filter.**
* The steel may have a recovery value for recycling
**
TOTAL
COST OF NONHAZARDOUS DISPOSAL $34,140.00
COST OF HAZARDOUS DISPOSAL $35,240.00
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Option 2a
Regenerate carbon in the filters with Filtrex
Purchase costs
One time purchase of nine spare Flanders Filters Model T-2V-C63-F16,
GG-16, V-Bed Carbon Adsorber Cells. Each adsorber complete with an
initial charge of commercial grade carbon.
Disposal costs
One time cost to test spent nuclear grade carbon.
Regeneration costs
Regeneration of 22 Flanders Filters Carbon Adsorber Cells. (This cost
estimate is based on processing nine adsorber cells at a time.)
TOTAL
START UP COSTS
RECURRING COSTS
Option 2b
Regenerate carbon in the filters with Cameron Carbon
Purchase costs
One time purchase of 9 spare Flanders Filters Model T-2V-C63-F16, GG-
16, V-Bed Carbon Adsorber Cells. Each adsorber is complete with an
initial charge of commercial grade carbon.
Disposal costs
One tune cost to dispose of spent nuclear grade carbon.
Regeneration costs
Regeneration of 22 Flanders Filters Carbon Adsorber Cells. (This cost
estimate is based on processing 9 adsorber cells at a time.)
TOTAL
START UP COSTS
RECURRING COSTS
Option 2c
Regenerate carbon in the filters with Complete Air Filter Company
Purchase costs
One time purchase of 9 spare Flanders Filters Model T-2V-C63-F16, GG-
16, V-Bed Carbon Adsorber Cells. Each adsorber is complete with an
initial charge of commercial grade carbon.
Disposal costs
One time cost to test spent nuclear grade carbon.
Regeneration costs
Regeneration of 22 Flanders Filters Carbon Adsorber Cells. (This cost
estimate is based on processing 9 adsorber cells at a .time.)
TOTAL
START UP COSTS
RECURRING COSTS
$13,846.00
$425.00
$6,172.00
$14,271.00
$6,172^00
$11,595
$792
$4,726
$12,387,40
$4,726
$14,400.00
$600.00
$8,800.00
$15,000.00
$8,800.00
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Pollution Prevention Opportunities
1. Conduct regular pressure drop checks to determine when the filters must be changed.
This method involves measuring the pressure buildup in front of the particulate filter. The
buildup is also known as the pressure drop across the filter. When the pressure drop reaches a
specific value, the filters are clogged and should be changed. The filter systems are currently
equipped with instrumentation that would allow pressure drops to be read across each filter bank
from the computer console in the engineer's office located on the first floor. Using this system to
check pressure drops might increase the lifetime for some of the particulate filters and show
which filter systems become clogged before the anticipated three month change-out interval.
2. Identify trends to develop a schedule to change the filters. The Building Engineer,
currently responsible for the maintenance of the mechanical systems, might not have the tune to
check the pressure drops on a regular basis. Along with the upkeep of the HVAC system, the
engineer also is assigned to off-site projects and installations. The current use of scheduled
changeouts of the particulate filters allows the engineer to plan for future activities and
assignments. An alternative method to monitor the particulate filters and to allow for a
predictable schedule would be to use the current software equipped on the engineer's computer to
track trends for the pressure drop across the filter systems. This would allow the engineer to use
these trends to set up a schedule for the changeout of the filters. These trends would use actual
data as the basis for the change-out and allow the engineer the freedom to schedule field work
and off-site trips.
7.8 MONITORING PH ADJUSTMENT PIT
Current Conditions
The two pH adjustment pits are located behind the Forensic Laboratory. One is next to
the loading dock and the other is near the antenna. Each is accessible through a manhole cover
allowing easy visual examination.
Pollution Prevention Opportunities
1. Forensic Lab staff should inspect the pH adjustment pits to ensure that they are operating
properly. This will prevent discharge to the POTW of acid waste that has not been neutralized.
2. The Building Engineer should perform annual examinations of the pits to determine the
operating efficiency of the system.
3. An alternative process would be a periodic pH measurement of the effluent as it flows to
the sewer system. If the effluent is outside the pH range set by pretreatment standards, this
indicates that the limestone should be replaced.
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7.9 MAINTENANCE OF MECHANICAL SYSTEMS
Current Conditions
The Building Engineer has responsibility for oversight and maintenance of all mechanical
systems. If, for example, the flow control meter on a laboratory hood indicates that the flow rate
is not within specifications, staff must notify the building engineer who will initiate any
corrective action. He is responsible for all equipment and for the quality of discharges to the air
and water. The Building Engineer has other responsibilities that take him off-site on a regular
basis, leaving these systems unsupervised.
Pollution Prevention Opportunities
Train one or more technicians in the operation and maintenance of these mechanical
systems. This will provide back-up support to the Building Engineer and ensure that the
Forensic Laboratory maintains a high level of responsibility in its discharges to air and water.
Proper maintenance of mechanical systems ensures that air emissions are minimal. It is
more cost effective to -maintain the system on a regular basis than to perform emergency repairs
to prevent uncontrolled discharges.
7.10 RECYCLING CONTRACT
Current Conditions
The Assessment Team spoke with the recycling coordinators at the adjacent USPS
Vehicle Maintenance Facility (VMF) and the Processing and Distribution Center PDC). Based
on these conversations, the team determined that each of the four Postal Service Dulles, VA
facilities has an independent waste disposal and recycling contract with BFI. In addition, the
Stamp Distribution Network (SDN) and the PDC have separate contracts with other companies
for recycling of pallets. The VMF has additional contracts for oil, metals, aerosol cans and oil
filters. On an individual basis, the Forensic Lab generates a very small quantity of recyclables,
so small that it is not economical for the Laboratory to recycle under the present system;
However, the combined recyclables generated by the four Postal Service facilities constitute a
significant quantity of materials. The PDC, for example, generates more than 1,000 cubic yards
of mixed paper and nearly 200 cubic yards of corrugated cardboard each month.
Pollution Prevention Opportunities
1. Negotiate a contract with a recycler to establish one multi-facility recycling program for
the four Postal Service operations located hi Dulles, VA. The USPS Purchasing Division has
developed a draft model solicitation package for developing recycling contracts for Postal
facilities. Such a contract might include a requirement to designate a specific collection area for
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each recyclable material. For instance, the PDC generates the largest quantities of corrugated
cardboard and mixed paper. The Forensic Lab and the other facilities could establish a program
to transport their cardboard to the PDC for collection and recycling. Such a system is already
informally in place; staff from the Forensic Laboratory currently transports pallets to the PDC for
consolidation and collection by American Erosion Control.
The multi-facility recycling program may include one contract for all materials or
separate contractors for different materials, depending on the capabilities of the local recycling
companies. Exhibit 7.4 identifies some local recycling firms that are willing to visit the Postal
Service facilities and provide cost estimates for recycling services.
By combining resources, the four facilities could increase their recycling capabilities,
potentially reduce their waste disposal costs and generate revenues from the sale of the
recyclables. Annual cost savings for the Forensic Laboratory would include $4,440 in fees for
rental and collection of recyclables. In addition, the Lab could obtain a smaller waste container
and have it collected less frequently for additional savings of up to $544. According to the
Postal Service Area Environmental Compliance Coordinator, the annual savings for the
combined facilities could be as high as $25,000 per year. In addition, by marketing dependable
quantities of quality materials, the Postal facilities increase the possibility of receiving revenues
from the sale of then" recyclables.
A regional or multi-facility contract will be required to initiate a multi-facility recycling
program. Since each facility at the Dulles complex has a separate budget and separate waste
collection and disposal contract, contract managers at the Dulles PDC indicated that USPS had
no mechanism to allow multiple facilities to simply divide the costs among multiple finance
numbers. However, the facilities at the USPS Material Distribution Center in Topeka, KS have a
single waste disposal contract with costs divided among three finance numbers. USPS
employees at the Dulles facilities are willing to coordinate combining recyclables at specific
locations, but believe that they are prevented from doing so by the specific finance numbers for
each facility. A regional contract would allow the Postal facilities to initiate a multi-facility
recycling program.
EXHIBIT 7.4 LOCAL RECYCLERS
Recycler
AAA Recycling
Urban Service Systems Corporation
Southeast Recycling
Waste Management
Address
11202 Lee Highway
Fairfax VA
212VanBurenSt.,NW
Washington, DC
9001 Brookville Rd.
Silver Spring, MD
8421 Terminal Road
Newington, VA
Materials Accepted
Cardboard, Aluminum, White
Paper, Scrap Metal
All paper and paper products,
aluminum, glass, plastics
Cardboard, newspaper,
magazines, aluminum, glass
Cardboard, newspaper,
aluminum, glass, plastics
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2. If a multi-facility program is not possible, renegotiate the current waste disposal and
recycling contract. For example, collection could be performed on-call; additional 90-gallori
toters for recyclable mixed food and beverage containers would extend the duration of the period
between pulls. This will reduce the cost of the recycling program. Further, the increasing value
of recyclable materials in the marketplace should be reflected in lower collection costs. If the
waste is properly segregated, the only large volume waste will be the laboratory glass for which
no recycling opportunity currently is available.
7.11 PAPER, PAPER PRODUCTS AND CORRUGATED CARDBOARD
Current Conditions
Paper, including corrugated cardboard, computer printout and mixed office paper is the
largest waste stream generated by the Forensic Laboratory and the other three Postal Service
facilities in the Dulles location. Sixty percent of the Forensic Laboratory's waste stream, by
volume, is paper and paper products. In addition to the items above, the PDC also generates
significant quantities of undeliverable bulk business mail (UBBM). Currently, these facilities are
paying BFI to collect paper and cardboard. The Forensic Laboratory is paying BFI $240.00 a
month to collect mixed office paper and cardboard; the PDC is paying $358 a month for
collection of cardboard. The Forensic Lab is not recycling computer printout, while the PDC is
not recycling computer paper, mixed paper, or undeliverable bulk business mail and is paying to
have these materials disposed. Currently, the PDC is charged $432.00 per week to have its 42
cubic yard compactor pulled six times a week. At least half of the waste in the compactor is
recyclable paper and paper products.
Pollution Prevention Opportunities
1. Before initiating an enhanced recycling program, the Forensic Lab and the other USPS
facility managers and staff should adopt and promote a variety of techniques to prevent or reduce
the quantity of paper generated for disposal.
Establish a duplex copying policy for all multi-page documents and provide staff with
training in the use of the double-sided function on copying equipment. As equipment is
replaced, specify easy to use, rapid, duplex capability.
In office and laboratory settings, expand and encourage the use of electronic mail rather
than paper memos and distribution copies.
Limit distribution lists. If paper copies are necessary, circulate one memo or report with
a cover sheet indicating distribution.
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Identify opportunities to reuse paper and paper products. Manila envelopes and other
packaging materials are reusable for their original function and paper can be turned over
and used as scratch paper or made into message pads.
Encourage staff to proofread on screen and save information on disks rather than file
copies.
2. Postal Service facilities generate a dependable supply of consistent-quality recyclable
paper. The Postal Service may consider contacting regional paper mills to establish a broad-
based program to collect and recycle the paper and paper products. Demand for printing and
writing paper made from recovered paper has stimulated markets for office waste paper. A
similar program is currently being established in Postal Service facilities throughout St. Louis,
MO. Under this program, Jefferson Smurfit, a local paper company, will supply containers at. the
General Mail Facility to collect cardboard and mixed paper for recycling. The St. Louis GMF is
not charged for the recycling and receives revenues from the sale of the paper.
Recycling all paper and paper products through a long-term contract with a regional paper
mill could would eliminate the cost of container rental and collection of these materials. The
contract should specify a base price plus a percentage of the current market price. The contract
should be indexed to the paper markets to provide a reliable return on the value of the paper.
Exhibit 7.5 provides the names of a few regional markets for the paper.
EXHIBIT 7.5 REGIONAL PAPER MILLS
Mill
Hagerstown, MD
Richmond, VA
Richmond, VA
Franklin, VA
Newark, DE
Fairmont, West VA
Fitchburg, MA
Operator
Hagerstown Fiber Limited
Partnership
Custom Paper Group
Richmond Paperboard
Corporation (formerly
Manchester Board and
Paper)
Union Camp Corporation
James River Corporation
American Fiber Resources
Limited .
Intercontinental Fiber
Market
Designed to accept 635 tpd postcohsumer mixed
paper from the Washington- Baltimore metro area.
Collection provided through Smurfit Recycling
Company (St. Louis, MO)
Makes virgin and recycled uncoated freesheet
papers using up to 70% recovered content
Makes a variety of board products including bristols
and cover paper
An integrated deinking facility
Manufactures recycled printing and writing paper
Accepts post consumer office paper from the Mid-
Atlantic, near Midwest and Southeast regions
Will need 600 tpd postconsumer office waste paper
from Northeast and Mid- Atlantic regions
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3. Renegotiate the contract with BFI or another recycling contractor to reduce or eliminate
charges for paper and cardboard collection and to establish a payment schedule for these
materials indexed to the paper markets. Paper mills throughout the country have been designed
to use recovered paper feedstock. Demand for consistent supplies of known quality fiber has
rapidly exceeded supply. Mills are currently paying more than $100 per ton for old corrugated
cardboard.
4. Maximize reuse of cardboard boxes, as well as the plastic bubble wrap and packaging
peanuts. The Technical Services section already reuses many of these materials; other sections
should direct reusable boxes and packaging materials to Technical Services' shipping room.
7.12 CONTAMINATION OF RECYCLABLES
Current Conditions
Throughout the Laboratory, recyclable and non-recyclable materials are mixed together hi
the collection bins. In many cases, waste baskets contained recyclable materials and recycling
bins were full of waste. In fact, the contents of the two four cubic-yard containers at the loading
dock were identical. Had it not been for the external labels, the Assessment Team could not have
determined, from the contents, which bin was intended for recycling and which was for trash.
The problem of mixed waste appears to be the result of a combination of factors:
Employees interviewed do not understand which materials should be placed in recycling
containers. For example, one staff member expressed his commitment to the recycling
program and pointed out that he placed mylar sheets and film canisters in the recycling
container. He did not understand that plastic food and beverage containers are the only
plastics recycled at this facility. Thus, the staff is unwittingly contaminating the facility's
recycling program.
Staff are not consistent in their recycling practices. The Assessment Team observed that
recyclable materials are placed into waste baskets instead of recycling containers because
it is a habit to place discards into the waste basket
There are not enough clearly labeled waste baskets and recycling containers located
throughout the facility. For instance, the only recycling container for commingled
materials (i.e., metal, plastic, and glass) is in the lunch room on the ground floor! This is
a long distance to carry an aluminum can to recycle; therefore, many individuals place
food and beverage containers into the waste baskets in their offices. In addition, the
photocopy room, as well as several other rooms, have only one collection container. The
container is not marked for either recycling or trash, so both wastes and recyclables end
up in it. This reinforces the mixing of wastes and recyclables.
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Often, technicians remove their own trash and deposit the bags into the containers on the
loading dock. The technicians may not be consistent in separating the recyclables from
the trash.
Pollution Prevention Opportunities
1. Conduct a training program to educate staff concerning the types of materials that can. and
cannot be recycled at this facility.
2. Purchase additional bins for collection of commingled containers and place them in
convenient locations throughout the facility. It is recommended that a commingled food and
beverage container collection bin be placed in each office hallway.
3. Conduct a walk-through of the facility and place two containers, one for recycling and
one for trash, in each room. Each container should be clearly labeled either "Trash" or
"Recycling." The recycling containers could be labelled with a list of recyclable materials.
4. Lock the trash and recycling containers in the loading dock area to limit access. The
custodian should be responsible for the key to the containers.
5. Publicize the environmental benefits and cost-savings derived from a successful recycling
program.
7.13 CUSTODIAL SERVICES
Current Conditions
It appears that the contracted custodial staff does not understand the recycling program at
the Forensic Laboratory. When staff have separated recyclables and waste, the custodian does
not maintain this segregation during the collection of the waste. On one occasion, the
Assessment Team observed the custodian emptying the trash cans into the paper recycling
container in the photocopy room.
Pollution Prevention Opportunities
1. Train the custodian in proper collection procedures to support the recycling program.
This should include reinforcing the custodian's responsibility to keep recyclables separate from
waste and identifying the types of materials that can and cannot be recycled.
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2. Revisit the custodial contract to incorporate responsibility for maintaining separation of
recyclables from waste. This affects both the internal collection of waste and the containers in
the loading dock area. The custodial contract should include the following responsibilities:
keeping the recyclables and trash separate,
placing the materials in the proper containers, and
locking the containers on the loading dock and monitoring the area.
7.14 UNWANTED EQUIPMENT
Current Comditions
From time to time, the Forensic Laboratory must dispose of unwanted equipment such as
computers, old radios and circuit boards. This equipment is in good repair, but no longer meets
the needs of the Postal Service. Some of the equipment, (i.e., the radios and circuit boards) are
highly sophisticated and specially designed for Postal investigations.
Pollution Prevention Opportunities
1. The Forensic Laboratory could donate unwanted computer equipment to schools or
charities. Although the paper work to accomplish such donations is daunting, these activities
divert the equipment from disposal and generate considerable good will.
2. The Laboratory may consider donating the radios and the circuit boards to training
facilities for Postal Service Inspectors, the FBI, or the military police.
7.15 AFFIRMATIVE PROCUREMENT
Current Conditions
Purchasing records for the Forensic Laboratory Section are filed by distributor or vendor;
therefore, it is difficult to identify the source of and/or specifications used to purchase specific
materials or products. The Forensic laboratory does not make it a standard practice to purchase
items with recycled content, such as paper. Instead, most items purchased are made of virgin
material. It appears that the purchasing officials at the laboratory are unaware of USPS policy
and federal legislation requiring the purchase of materials with recovered content. The United
States Postal Service Waste Reduction Guide (AS552, February, 1992) directs Requiring offices
to "review purchase specifications to eliminate prohibitions or limitations on use of recovered
materials" and to modify specifications to encourage use of recycled products.
Section 6002 of the Resource Conservation and Recovery Act (RCRA) directs Federal
agencies to purchase "items composed of the highest percentage of recovered materials
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practicable." EPA published the Comprehensive Guideline for Procurement of Products
Containing Recovered Material (60 FR 21370, May 1, 1995) establishing minimum recovered
content levels for seven categories of products including paper and paper products, vehicular
products, construction products, transportation products, park and recreation products,
landscaping products and non-paper office products. Items of particular interest to USPS
facilities include: rerefined oil, engine coolant, tires, trash bags, toner cartridges, binders and
desktop accessories. These guidelines provide information about the recommended percentage
of recovered material, product availability and performance, and specification language.
In Executive Order 12873, October 22,1993, President Clinton directs agencies to
develop and implement affirmative procurement programs for all EPA guideline items and
ensure that these programs require that 100 percent of their purchases of products meet or exceed
the EPA guideline standards. Although the USPS is not an Executive Agency, Postal Service
policy is to comply with Executive Orders whenever feasible.
The lab was not able to document successful implementation of USEPA procurement
guidelines for products manufactured with recovered content. Purchasing officials are not sure
whether procurement specifications have been updated to include recycled content in paper
products. Current supplies of printing, duplicating and computer paper do not contain any
recovered content.
Pollution Prevention Opportunities
1. Purchase products with recycled content and train staff
The Forensic Laboratory management should establish preference programs and adopt
specifications for the purchase of products made with the percentages of recovered materials
specified in the EPA Guidelines. The GSA catalog has special sections for environmentally
sound products, such as paper with recycled content. These items are highlighted hi green
throughout the catalog. The purchasing officials should make it a standard practice to purchase
items with the highest amount of recycled content. Changes in the procurement system will
create staff training opportunities and staff will need training on Federal affirmative procurement
requirements. Exhibit 7.6 presents products for which EPA has established mmimum recovered
content levels.
EPA has developed lists of manufacturers and vendors of the items designated in
published Comprehensive Procurement Guidelines. These lists will be updated periodically as
new sources are identified and EPA becomes aware of changes in product availability. To assist
procuring agencies, the lists will be made available at no charge by calling EPA's RCRA Hotline
at (800) 424-9346
The U.S. General Services Administration (GSA) publishes an Environmental Products
Guide, which lists items available through its Federal Supply Service. This guide, formerly the
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Recycled Products Guide, has been prepared to assist Federal civilian and military agencies to
identity the environmentally-oriented products and services available to them through the supply
system of the General Services Administration's Federal Supply Service. The guide contains
information about more than 2,900 such items from GSA's supply system. In the general
category of recycled content paper products alone, there are more than 900 entries. Some of
these items contain 100% post-consumer recovered materials and all meet or exceed guideline
requirements established by the Environmental Protection Agency. This publication is available
to federal agencies at no cost from the GSA Centralized Mailing List Service in Fort Worth,
Texas 76115 or at (817) 334-5215.
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EXHIBIT 7.6 EPA ESTABLISHED MINIMUM RECOVERED CONTENT LEVELS
Paper
High grade bleached printing and writing paper
Mimeo and duplicator paper
Computer paper
Envelopes
Tissue Products
Toilet tissue
Paper towels
Paper napkins
Facial tissue
Recovered Content
20%
20%
20%
20%
20-100%
40-100%
30-100%
10-100%
Unbleached packaging
Corrugated boxes
25-50%
Vehicular Products
Lubricating Oil (re-refined oil)
Tires
25%
retread tires
Construction Products
Fiberglass (glass cullet)
Cellulose loose-fill and spray-on (postconsumer paper)
Structural fiberboards
Laminated paperboards
Cement and Concrete (coal fly ash)
Cement and Concrete (ground granulated blast furnace slag)
Polyester Carpet Face Fiber (PET resin)
Patio blocks (rubber or rubber blends)
Patio blocks (plastic or plastic blends)
Floor tiles (rubber)
Floor tiles (plastic)
20-25%
75%
80-100%
100%
0-40%
25-50%
25-100%
90-100%
90-100%
90-100%
90-100% ,
Transportation products ,
Traffic cones (PVC, LDPE, Crumb Rubber)
Traffic barricades (HOPE, LDPE, Pet Steel)
Traffic barricades (Fiberglass)
Park and Recreation Products
Playground surfaces (rubber or plastic)
Running tracks (rubber or plastic)
Landscaping Products
Paper-based hydraulic mulch (postconsumer recovered paper)
Wood-based hydraulic mulch (recovered wood and/or paper)
Non-paper Office Products
Office recycling containers and waste receptacles (plastic)
Office recycling containers and waste receptacles (steel)
Plastic desktop accessories (polystyrene)
Plastic-covered binders (plastic)
Chipboard, paperboard, pressboard binders
Plastic trash bags
50-100%
80-100%
100%
90-100%
90-100%
100%
100%
20-100%
25-100%
25-80%
25-50%
80%
10-100%
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In addition to the information provided by EPA and GSA, there are other
publicly-available sources of information about products containing recovered materials. For
example, the Official Recycled Products Guide (RPG) was established in March 1989 to provide
a broad range of information on recycled content products. Listings include product, company
name, address, contact, telephone, fax, type of company (manufacturer or distributor), and
minimum recycled content. Price information is not included. The RPG is available on a
subscription basis from American Recycling Market, Inc., (800) 267-0707.
The Defense General Supply Center in Richmond, VA also distributes the
Environmentally Preferred Products Catalog which lists hundreds of environmentally preferred
products in its supply system, ranging from aqueous degreasers to remanufactured laser printer
toner cartridges. Environmentally preferable means products and services that have less or
reduced effect on human health and the environment when compared with competing products or
services that serve the same purpose. This comparison may consider raw materials acquisition,
production, manufacturing, packaging, distribution, reuse, operation, maintenance or disposal of
the product or service. For more information about environmentally-preferred products, call or
write:
Defense General Supply Center
Attn. Marketing Office
8000 Jefferson Davis Highway
Richmond, VA 23297-5762
1-800-848-4847
7.16 ENERGY
While energy was not a part of the multi-media assessment, the Assessment Team has
several recommendations in this area.
Current Conditions
The Assessment Team observed that Forensic Laboratory staff routinely left the lights
and equipment turned on in empty offices and laboratories.
Pollution Prevention Opportunities
1. A policy of turning off lights and equipment when exiting an area may yield positive
economic and environmental results. Installation of motion sensors that automatically turn off
the lights is another alternative. Each kilowatt hour saved prevents formation of air pollutants
including of 0.68 kg of carbon dioxide, 5.8 g of sulfur dioxide and 2.5 g of nitrogen oxides.
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2. Purchase energy efficient light bulbs. In 1994, the President signed Executive Order
12902, Energy Efficiency and Water Conservation at Federal Facilities, which requires Federal
agencies to reduce energy consumption by 30 percent by the year 2005, based on the agency's
1985 energy use.
In response to these mandated requirements, the U.S. Department of Energy's Federal
Energy Management Program was established to assist Federal agencies to reduce energy costs
by advancing energy efficiency, water conservation, and the use of solar and other renewable
energy. FEMP accomplishes its mission by creating partnerships, leveraging resources,
transferring technology, and providing training and support. For information on the Federal
Energy Management Program contact the FEMP Help Desk at (800) DOE-EREC or the FEMP
Office at (202) 586-5772.
The Defense General Supply Center offers products in the Energy Saver Bulb Catalog
throughout the Federal sector. To assist government customers in selecting and ordering energy
efficient lighting products, a toll free telephone line has been established at 1-80Q-DLA-BULB.
3. The Lab could implement a program to encourage carpooling to reduce fuel use. Several
Executive Orders address energy use in Federal facilities. Executive Order 12902, Energy
Efficiency and Water Conservation at Federal Facilities recommends implementation of
outreach programs such as ride-sharing to reduce fuel usage.
4. Future purchases of computer equipment should specify equipment that is energy
efficient. The EPA ENERGY STARฎ Office Equipment program is a partnership with the
office equipment industry to promote energy-efficient personal computers, monitors, printers, fax
machines, and copiers. In 1993, an Executive Order 12845 was issued requiring all U.S. Federal
agencies to purchase ENERGY STARฎ computers, monitors and printers. For additional
information contact U.S. EPA Atmospheric Pollution Prevention Division Toll Free: (888)
STAR-YES; Fax: (202) 233-9569 or Fax-back system: (202) 233-9659.
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SECTION 8.0 OPPORTUNITIES FOR FUNCTIONAL AREAS OF THE
FORENSIC LAB
8.1 CHEMISTRY SECTION
8.1.1 Description of Section
The Chemistry Section examines chemical substances submitted by inspectors. They
determine the presence of controlled substances, quantify controlled substances, identify cutting
agents present in samples, prepare written reports of findings, and provide testimony in Court.
Controlled substances commonly analyzed are cocaine hydrochloride and base, heroin, lysergic
acid diethylamide (LSD), phencyclidine (PCP), marijuana, and steroids. In addition, the
Chemistry Section trains Postal Inspectors to recognize controlled substances and provides
instruction in packaging and custody requirements for evidence.
Current Conditions
Procurement and storage of chemicals is performed in isolation from the rest of the
facility operations. The Chemistry section generates very little waste. Chemical and mechanical
microanalyses are performed. After the evidence is processed, it is returned to the courts along
with any accompanying packaging. Drug destruction is accomplished by supervised
incineration. Sensitive documents are shredded and recycled. Computer printouts generated at
the central lab printer are discarded, although recycling containers for other paper are available.
Corrugated cardboard not associated with evidence is reused or stacked in a central location to be
transported by the contracted janitorial service to the recycling container behind the building.
Cotton gloves are collected, washed and reused. Broken laboratory glass is collected in lined
cardboard boxes specifically designated for the collection of the glass; a glass collection
container is convenient to each work area.
Pollution Prevention Opportunities
1. The Chemistry Section should participate in a facility-wide chemical procurement,
labeling, and tracking system.
2. Place a recycling container at each paper source in the Section and ensure that this paper
is properly collected and stored for recycling.
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8.2 FORENSIC PHOTOGRAPHY
8.2.1 Description of Section
The Forensic Photography section provides photographic support to all disciplines in the
National Forensic Laboratory and all outside inspectors for Postal Inspection Service
investigations. The mission of this functional area is to prepare, enhance and preserve
photographs to be used in the courtroom.
The Photography Section occupies a suite of rooms including photography area, dark
rooms, black & white and color laboratories and a supply room with refrigerated film storage.
The photography section operates automated photoprocessing machinery including black &
white negative processors, black & white print processor, color negative processor, and color
print processor. These units are enclosed systems. Exhibit 8.1 provides a simplified process
flow diagram of the negative and print development process for black & white and color film.
EXHIBIT 8.1 PROCESS FLOW OF NEGATIVE AND PRINT DEVELOPMENT
Black & White Negative Processor
negative developer - fix - wash - dry
Black & White Print Processor
developer - fix - wash - dry
Color Negative Processor
developer - bleach - fix - stabilizer (water/salt solution) - dry
Color Print Processor
developer.- bleach/fix - wash - dry
Following each process step, the negatives/prints pass through a squeegee to remove
excess liquid from the film and paper, reducing transport of chemicals from one process bath to
the next. This reduction in transport increases the life of the process baths and reduces the
quantity of chemicals used. The photoprocessing machines in the darkrooms and processing
areas have booms placed around them to protect against leaks and spills. To date, the booms
have not been used.
The work load hi the Photo lab is dependent on the cases in the Postal Inspection Service;
therefore, the volume of film processed varies considerably from month-to-month and year-to-
year. However, the average amount of film processed per month is:
Color: 20 rolls
Black & White: 300 sheets 4"x5" film and 200 sheets 8"xl 0" film
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The Photography section uses five kinds of black & white film: Contrast process ortho,
Ektapan, Commercial ortho, Tekpan and Professional copy. Kodak Gold and Pro series color
film is used. Photographs are printed on Kodak color and black & white paper and Ilford black
and white paper.
Current Conditions
Exhibit 8.2 provides a list of the material inputs and outputs for the Photo lab. These
wastes fall into two main categories: solid and aqueous.
EXHIBIT 8.2 PHOTOGRAPHY LAB MATERIALS
Material Inputs
water
photochemicals:
fixer
developer
bleach
floor cleaning products
film
corrugated cardboard
paper
paperboard
mylar sheets
Material Outputs
water
silver
photochemicals
photochemical containers
detergents
processed film
expired film
metal film spools
plastic film canisters
corrugated cardboard
paper
paperboard
mylar sheets
Solid wastes include corrugated cardboard from deliveries of materials, photographic
paper, paper and paperboard packaging, mylar sheets, excess processed film, expired unused
film, metal film spools, plastic film canisters, and glass and plastic containers from
photoproeessing chemicals. Quantities of these materials in the waste stream vary depending on
the work load.
Photo lab staff use mylar sheets to clean contaminants, such as algae, from the
photoprocessing machines. The Photo lab uses approximately 20 11" x 14" mylar sheets per
week. The used sheets are placed in the recycling bin, although they are not recyclable in the;
current program. Photo lab staff assumed that by placing all of these materials into the in-house
recycling collection containers, they were ensuring that the by-products of their operation were
recycled. For example, staff place empty glass and plastic containers from photoprocessing
chemicals into the office recycling collection containers, believing that all glass and plastics are
recycled. Lab personnel are not aware that the recycling program is for glass, plastic and metal
food and beverage containers only. Unfortunately, many of the discarded items, such as the
mylar sheets, actually contaminate the mixed container recycling.
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Aqueous wastes include rinse waters from processing equipment and waste water from
floor cleaning. The rinse water containing developer and the floor cleaning wastes are released
directly to the sanitary sewer.
Wastewaters containing fixer and bleach are subject to silver recovery prior to disposal
The Photography section employs two methods to recover silver from its photoprocessing
wastes. The first method is a copper-fiber cartridge system. In this system, the waste chemicals
are collected in a cartridge that will be sent to a silver smelter. The photoprocessing wastes
processed in this manner are:
Bleach/fixer solution from color print processor and
Fixer from (large) black & white print processor
To make this system economical, the photo lab accumulates at least three 5-gallon
cartridges of waste before sending it to smelter. Based on the current workload, Photo lab staff
believes that it will take three years to accumulate 15 gallons of waste.
The second method used to recover silver from photoprocessing wastes is an electrolytic
system. This system uses an electrical charge to plate out the silver onto cathodes. The silver
recovery unit used in the Photography section is a Rotec system. This system requires that the
wastes be tested for their silver content before operating the machine. The silver content is
measured using silver estimating test papers. In the past, the silver concentration in the wastes
has ranged from 0.0 grams per liter to 2.5 grams per liter. Once the concentration has been
determined, Photo lab staff set the unit for the specific silver concentration and the unit
automatically processes the waste. The wastes and quantities processed hi electrolytic system are
illustrated in Exhibit 8.3.
EXHIBIT 8.3 WASTES AND QUANTITIES PROCESSED IN ELECTROLYTIC
SYSTEMS
Waste
Fixer from black & white negative processor
Fixer from small black & white print processor
Bleach/fixer solution from color negative processor
" " Quantity
5.5 gallons per month
2.5 gallons per month
Following silver recovery, the bleach and fixer are piped to the underground pH adjustment
pit (see Section 5.1). Exhibit 8.4 quantifies the photoprocessing chemicals discharged to the sanitary
sewer annually.
Photoprocessing chemicals are purchased quarterly by the Forensic Photography staff.
During the site visit, it appeared that at least a one year supply of fixer, developer and bleach was
on the shelves in the supply room. Photo lab staff indicated that maintaining the current stock is
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necessary in case an exceptionally large case comes through that would require this amount of
material. The photography section does not have a formal inventory management system, but
believes that any waste from expired material is minimal. Due to the unpredictable nature of the
work load, chemicals and film sometimes are discarded because they have exceeded the shelf life
performance requirements. Polaroid film, for example, has a life expectancy of six
EXHIBIT 8.4 PHOTOPROCESSING CHEMICALS RELEASED TO WASTEWATER
Photoprocessing Chemicals Annual Quantity
B & W paper fixer
B & W paper developer
B & W film fixer
Color paper fixer
Color paper developer
Color film fixer
B&WFixAll
B & W Poly max (paper)
B & W Duraflow (film)
Color film developer
Bleach
Color film fixer
Color wash solution
Color paper developer
Color paper bleach fixer
80 gallons
96 gallons
40 gallons
180 gallons
180 gallons
18 gallons
40 gallons
45 gallons
30 gallons
10 gallons
10 gallons
10 gallons
3 gallons
35 gallons
35 gallons
months to one year. If there is no case that calls for the use of Polaroid film during that time period,
then the film may expire on the shelf. Black and white film can be used successfully for up to one
year after the expiration date, so it is unlikely to be discarded unused. Scrap film and paper from
trimmings, test strips and leader contain silver, but photoprocessing staff believes that the quantity
of these material generated is too small to make silver recovery viable.
The Photo lab maintains four processing machines that require a constant flow of water to
control the temperature of the machines and/or to serve as rinse water for negative development.
Two of the machines have water running constantly for 8.5 hours per day, five days per week.
Exhibit 8.5 illustrates the average amount of water used per day in the Photo Lab.
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EXHIBIT 8.5 WATER USAGE IN PHOTO LAB
Machine
Mini Lab Black &
White Processor
Film Processor
Processor
Processor
Setting
Off
Stand-by
Run
Off
Stand-by
Run
Off
Run
Off
Run
Water Usage
0.0 gal/min
0.3 gal/min
0.5 gal/min
0.0 gal/min
0.25 gal/min
3.0 gal/min
0.0 gal/min
2.5 gal/min
0.0 gal/min
2.5 gal/min
Hours
6.5 hrs/day
2.0 hrs/day
Total
4.5 hrs/day
4.0 hrs/day
Total
30 min/day
Total
2.0 hrs/day
Total
Total
117 gal/day
60 gal/day
177 gal/day
68 gal/day
720 gal/day
788 gal/day
75 gal/day
75 gal/day
300 gal/day
300 gal/day
PHOTO LAB
TOTAL: 1,300 GAL/DAY
As the above exhibit shows, the Photo lab consumes large quantities of water on a daily
basis. The water usage for the four processing machines averages 1,300 gallons per day. Assuming
that the machines are in operation five days per week, 52 weeks per year, the total annual water
usage for the Photo lab comes to about 348,000 gallons per year.
Pollution Prevention Opportunities
1. Consider reducing the quantity of materials stored. Review the timing and quantity of
photoprocessing chemical and film orders to determine the potential for obtaining these items on an
as-needed basis.
2. Locate a supplier who will contract to fill 24 hour rush orders quickly and reliably at no
additional cost or with an acceptable surcharge.
3. Establish a facility-wide, computerized chemical inventory management system.
4. If the workload increases and discharges to the sanitary sewer increase accordingly., the
Photo Lab may want to consider options to recover and reuse photoprocessing chemicals. Recycling
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the fixer, for example, would require collecting the material, removing the silver, distilling the
solution, and replenishing the fix. At current volumes, recovering and recycling the fix would not
be economical. ;
5. The Forensic Lab Photography Section should participate in a recycling program for film
canisters and cartridges. Kodak operates a recycling program for the following materials: 110,126,
disc and super 8 film plastic cartridges; 135 film plastic canisters and lids; and 135 steel magazines,
end caps and plastic spools. Kodak will accept these materials regardless of the manufacturer. In
addition, Kodak accepts color paper plastic core plugs and disposable cassettes from Kodak products
only. Kodak provides collection containers that can be shipped to Kodak when they are full. For
more information, contact the Information Center at 1-(800) 242-2424.
6. The Forensic Lab should initiate a discussion with the contracted recycler to determine
whether additional materials, such as the brown glass jugs, can be incorporated into the mixed
recyclables,
7. Provide staff training on the types of materials that can and cannot be recycled at this
facility.
8. Reduce water use and costs for water and electricity by shutting off machines on light work
days
9. Consider installation of a water recirculator.
10. Discontinue the practice of placing mylar sheets hi the recycling containers. This material
is a contaminant for the recycling program. Identify opportunities to reuse the mylar sheets or
donate them to schools for use in art projects.
8.3 TECHNICAL SERVICES
8.3.1 Description of Section
The Technical Services Section maintains a nationwide communication system for the Postal
Service. The Forensic Laboratory operation supports Field Technical Services, operating a depot
for maintenance of all radios in the Postal Inspection Service, as well as a national supply system
for nickel cadmium batteries. In addition, the Technical Services Section is responsible for
enhancing audio and video recordings. These recordings are evidence in criminal investigations or
ongoing surveillance operations and are retained. Support for electronic surveillance operations
includes the installation and maintenance of detection and tracking equipment, including hidden
cameras and wire taps.
The garage is being utilized as a storage facility for equipment and materials from other
USPS facilities that are no longer in operation. These items, including tool boxes, spools of liable
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and miscellaneous radio equipment, must be examined by Technical Services staff to determine if
they should be kept or discarded.
The Technical Services Section maintains a small (approximately 50 to 100) stock of four
sizes or voltages of batteries. The brands are Motorola and Multiplier, an aftermarket vendor. Stock
is monitored for performance and rotated to prevent loss due to expiration. Before batteries are sent
to the :5eld they are charged, conditioned, and hot stamped with an expiration date two years in the
future.
Current Conditions
Wastes generated by the Technical Services Section include corrugated cardboard, paper,
circuit boards, empty aerosol cans from cleaners and degreasers that may contain chemicals of
concern, other containers, wiping cloths and rags, electronic equipment that cannot be repaired and
batteries.
Field technicians recharge batteries in the field and there is considerable variability in battery
life, depending on the amount and quality of equipment use. Batteries that can no longer hold a
charge are returned to Technical Services for replacement. For existing field equipment, batteries
are replaced on a one to one basis. New radios come with two batteries; Technical Services will
supply a backup battery. If a battery is returned from the field, Technical Services assumes thait it
is bad; there is no standard procedure to test returned batteries. If the battery is sent back by
someone known to lack technical knowledge, occasionally testing may be performed.
Returned batteries are sorted into separate bins, by manufacturer. When 20 pounds is
accumulated, the batteries are boxed and sent by registered mail to INMETCO in Ellwood City, PA
for destruction. The Postal Inspection Service is charged $0.28 per pound for the Multiplier
batteries; Motorola batteries are accepted at no charge. The Dulles facility mails out between 800
and 1,200 pounds of batteries each year.
Shipping and receiving of electronic equipment generates polystyrene peanuts and corrugated
cardboard boxes. These items are stored onsite for reuse in shipping operations. Technical Services
staff uses permanent shipping containers whenever possible, as well as Star Pack foam-lined boxes
that can be reused six to eight times.
At present, the Western Region of the Postal Inspection Service is being outfitted with new
radios. The old radios are returned to the Dulles facility where they will be scavenged for parts. The
used radios cannot be donated to other organizations, such as local police or fire departments,
because they are set to frequencies specific to the Postal Service. According to Technical Service
staff, the cost of altering the frequencies is prohibitive.
Cleaning and degreasing products, such as Formula 111 and Gold Guard, containing 1,1,1
trichloroethane, are currently in use and in stock. Purchase orders for these products are filed by the
name of the distributor, rather than the manufacturer. The Forensic Laboratory staff indicated that
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it would be too time consuming to determine when these products were last purchased and what
quantity was in stock.
Pollution Prevention Opportunities
1. Postal Service policy encourages replacement of products containing ozone1 depleting
chemicals if an alternative product that meets performance specifications is available. When current
stock of degreasers/solvents containing 1,1,1-trichloroethane is exhausted, initiate purchase of an
alternative product (see Section 7.4)
2. Aerosol cans are discarded into the solid waste stream, while the nearby VMF has a recycling
program for aerosol cans. Staff can separate the aerosol cans and other metals for recycling in
cooperation with the VMF. See Section 7.10.
3 Seek a cost effective method of altering the frequencies of the radios to allow them to be
donated for reused rather than discarded.
4. Donate the radios to a school or other facility providing training hi electronics repair.
8.4 PHYSICAL EVIDENCE SECTION
8.4.1 Description of Section
The Physical Evidence Section is described as the section that handles everything that is not
documents, fingerprints, or drugs. Usually, the Physical Evidence Section reconstructs bombs to
identify components, explosive residues and arson accelerants. In addition, the Physical Evidence
Section may examine hairs and fibers and perform physical comparisons and matches incorporating
DNA testing performed by the FBI. The section identifies toolmarks and firearms; examines postage
meter tampering; analyzes paints and polymers; and compares and identifies shoe impressions. The
Physical Evidence section also operates a small firing range on the lower level of the Laboratory.
Current Conditions
Microchemistry and instrumental analyses make up most of the workload of the section.
Small amounts of solvents are employed, primarily as degreasers, under the hood. Hydrochloric acid
may be used under a microscope. Occasionally, the section recovers microscopic amounts of
biologicals from bomb parts; these are disposed as biohazardous waste.
In the firing range room, weapons may be fired into targets in front of a complex of rubber
strips or into a 450-gallon tank of chlorinated water. Bullets are recovered for analysis and
compared with bullets from criminal investigations. The water is filtered to recover small lead
particles and other firing residues. When the tank is drained, the water flows directly to the sanitary
sewer.
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Solid wastes include computer printouts, office paper, corrugated cardboard boxes and
laboratory glass. Staff routinely places recyclable paper into waste receptacles.
Pollution Prevention Opportunities
1. Monitor the quantity of lead generated and ensure proper storage and disposal.
2. Place a recycling container and a waste container at each paper source.
8.5 LATENT FINGERPRINT SECTION
8.5.1 Description of Section
The Latent Fingerprint section processes evidence to develop latent prints by visual
examination, various light sources, including lasers, dusting powders, and chemical processes,
including the Superglue process and the ninhydrin spray process. The section also evaluates latent
prints that were developed or lifted by other Federal agencies, comparing latent prints to submitted
known prints and suspects. The Latent Fingerprint section may identify suspects through print
comparisons; prepare written reports of findings; testify to findings in court; and respond to major
crime scenes. They also provide training for Postal Inspectors.
Current Conditions
The Latent Fingerprint Section generates very little waste. Evidence containing fingerprints
is processed and photographed; any packaging remains with the evidence as part of the court records.
Sensitive documents are shredded and recycled; other recyclable paper is placed hi the appropriate
recycling container. Corrugated cardboard boxes are stacked in a central location to be transported
by the contracted janitorial service to the recycling container behind the building. Cotton gloves are
collected, washed and reused.
The chemical analyses of the fingerprints generates small amounts of air emissions. The
Superglue process and the ninhydrin process generate vapors that are exhausted through the hood
and are captured in the carbon filters.
The Latent Fingerprint section also generates some waste water from the infrequent use of
the laser equipment. Water is required to maintain the temperature of the laser. The water is not
recirculated, but passes through the machine and is disposed into the sanitary sewer.
Pollution Prevention Opportunities
1. Staff mentioned that there might be an opportunity to reduce laser equipment water use by
installing a water recirculator. However, they had no records of the amount of water used per laser
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event. If the workload increased and the laser was used regularly, staff could monitor water use to
determine the actual cost/benefit of installing a water recirculation system for the laser equipment.
8.6 QUESTIONED DOCUMENT SECTION
8.6.1 Description of Section
The Questioned Document Section works with documents whose origin or authenticity is in
question. Document analysts may analyze threatening letters, forged checks, money orders on which
the amount has been altered, reused postage stamps, and pornography. The mission of this section
is to identify alterations and forgeries and to firmly establish whether a document is what.it purports
to be. Skilled inspectors examine documents for age^ obliterated writing, counterfeiting and other
criminal acts. They identify handwriting, hand printing and numbers, as well as typewriting and
typewriters, and decipher the layers of print on typewriter ribbons. They restore eradicated and
obliterated writing, examine charred documents, decipher indented writing, analyze inks and paper
packaging, and determine whether mail tampering has occurred. They also identify the origins of
commercially printed material, reused postage, and rubber stamp impressions. This Section provides
training for Postal Inspectors to help them keep abreast of the latest techniques hi these fraudulent
activities.
Current Conditions
The Questioned Document section generates very little waste. The documents undergoing
analysis are evidence and are not discarded. Sensitive paperwork concerning ongoing cases is
shredded and recycled; cardboard boxes are reused or recycled. The Assessment Team observed
recyclable paper and food and beverage containers in waste receptacles. Recyclable paper was
placed into both the recycling collection containers and the waste receptacles. Aluminum beverage
containers also were placed into the waste receptacles rather than returned to the dining area
recycling container.
Video technology and computers support the examination of most documents. Sometimes
photographic enlargements are created by the Forensic Photography Section, but these become part
of the evidence. Some investigations use Electrostatic Detection Apparatus (BSD A) that requires
a glass bead toner; the toner is reused. Mylar document protectors accompany the evidence and
become part of the court record.
Pollution Prevention Opportunities
1. Train the staff in the Questioned Document in source separation of recyclables.
2. Provide clearly marked recycling containers for each individual office.
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SECTION 9.0 CONCLUSIONS AND RECOMMENDATIONS
This Pollution Prevention Opportunity Assessment report documents the processes
performed, wastes generated and current waste management practices at the US Postal Inspection
Service, National Forensic Laboratory in Dulles, VA. During the assessment process, the
Assessment Team identified opportunities to reduce both the quantity and toxicity of the wzistes
generated by this facility and recommended techniques for implementation of those pollution
prevention options. The opportunities described in the previous sections constitute the
recommendations of the Assessment Team. Exhibits 7.1 presents a summary of the major facility-
wide recommendations.
Dissemination of this report will encourage application of the pollution prevention
opportunities in USPS forensic facilities nationwide as well as in other Federal facilities with similar
operations.
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REFERENCES
1. Crime Lab Sleuths Help Convict Criminals. Postal Life. Vol. XXIII, No. 2: 16,1989
2. Freeman, Harry (Ed.) Industrial Pollution Prevention Handbook. NY: McGraw Hill. 1995.
3. Guides to Pollution Prevention: The Photoprocessing Industry. USEPA. EPA/625/7-91/012.
October, 1991.
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APPENDICES
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EPA 33/50 PROGRAM
The 33/50 Program, one of EPA's Partners-for the Environment Program, began in the late 1980s
as a voluntary program to reduce toxic emissions of seventeen high priority chemicals reported
on the Toxic Release Inventory (TRI). These high priority chemicals, chosen because of their
relative toxicities, volumes of use, and potential for reduction through pollution prevention
include: ;
Benzene
Cadmium and compounds
Carbon tetrachloride
Chloroform
Cyanide compounds
Dichloromethane
Lead and compounds
Mercury and compounds
Methyl ethyl ketone (MEK) ,
Methyl isobutyl ketone (MIBK)
Nickel and compounds
Tetrachloroethylene
Toluene
1,1,1 -trichloroethane
Trichloroethylene
Xylenes
The 33/50 Program gets its name from the original goals of the program to reduce the 17 priority
chemicals by 33% by 1992 and by 50% by 1995. The U.S. EPA celebrated the early achievement
of the 50% reduction goal in September 1996 when the 1994 Toxic Release Inventory data
became available for public release. Between 1988 and 1994, 33/50 Program participants
reduced environmental releases and off-site transfers of the 17 target chemicals by 757 million
pounds. Companies and organizations participate in the 33/50 Program by submitting a letter to
EPA stating their intention to participate and outlining then- reduction targets and strategies.
More than 1,300 parent companies operating about 6,000 facilities in the U.S. have participated
in the 33/50 Program. :
For more information about the participation in the EPA 33/50 Program, contact EPA's TSCA
Assistance Hotline at (202) 554-1404. Or contact the 33/50 Program staff directly at: ;
33/50 Program (Mail Code 7408)
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
401 M Street
Washington DC 20460
Phone: 202-260-7538
POC: Ms. Chris Tirpak
Email: tirpak.chris@epamail.epa.gov
Information on the 33/50 Program is also available on-line through the Enviro$en$e web site:
http://es.inel.gov/partners/3350/3350.html. This web site contains background information on
the 33/50 program, including history and accomplishments. It includes a series of documents
related to the 33/50 program that can be accessed directly from the web site. '.
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OZONE DEPLETING SUBSTANCES
si : '' _ . ' -
The ozone layer in the stratosphere protects life oh earth from exposure to dangerous levels of
ultraviolet light. When CFCs and other ozorie-degrading chemicals are released into the
atmosphere, they eventually rise to the stratosphere where they destroy the protective ozone
layer. This destruction is occurring at a more rapid rate than ozone can be created through
natural processes. Destruction of the ozone layer leads to higher levels of ultraviolet radiation
reaching Earth's surface. This can lead to higher incidences of skin cancer, cataracts, and
weakened immune systems. It is also expected to reduce both crop yields and ocean
productivity.
The U.S., in cooperation with over 140 other countries, is phasing out the production of
ozone-depleting substances. In 1985, the Vienna Convention was adopted to formalize
international cooperation in stratospheric ozone protection. Additional efforts resulted in the
signing of the Montreal Protocol in 1987. In the United States, Title VI of the Clean Air
Amendments of 1990 address the phase out of ozone-depleting substances.
There are two classes of ozone depleting substances. A Class I substances, as defined in section
602 of the Clean Air Act, is any chemical with an ozone-depleting potential of 0.2 or greater
(based on CFC-11 having a ozone depleting potential of 1.0). Class I substances (CFCs, carbon
tetrachloride, and methyl chloroform) were phased out of production by the end of 1995 and
halons were phased out by the end of 1993. Class II substances, hydrochlorofluorocarbons
(HCFCs), will be phased out of production and use by the year 2030. Accelerated phase outs of
the most damaging Class II substances include HCFC-141b (by January 1, 2003)^ and CFC-142b
and HCFC-22 (by January 1,2010). .,
To address the availability of approved alternatives to ozone-depleting substances, EPA's Office
of Stratospheric Protection was mandated to establish the Significant New Alternatives Policy
(SNAP) Program. The purpose of the SNAP Program is to identify alternatives to
ozone -depleting substances and to publish lists of acceptable and unacceptable substitutes.
The best source of technical, policy, and substitute chemical information can be obtained through
the U.S. EPA's Stratospheric Ozone World Wide Web Home Page:
http://www.epa.gov/ozone/index.html. This web site contains information on the science of
ozone depletion, substitutes for ozone depleting substances, international policy, and links to
other sources of information. It can be used as a "jumping off' point for a wide variety of
information related to ozone depletion available on the World Wide Web.
The U.S. EPA Office of Stratospheric Protection also operates the Stratospheric Ozone Hotline at
(800) 296-1996. It can be accessed between 10am and 4pm EST. They can field any technical or
policy related questions on elimination of ozone depleting substances at U.S. Postal Service
facilities.
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The mailing address for the Office of Stratospheric Protection is:
Office of Stratospheric Protection
U.S. Environmental Protection Agency
Mail Code 6205J
401 M St., SW :
Washington, DC 20460
Enviro$en$e also has access to several material substitution databases. Their World Wide Web
address is: http://es.inel.gov. Select "Solvent Substitution Data Systems" for links to several
material substitution databases including those that specialize in solvents with ozone depleting
ingredients.
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