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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 vi ------- 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 vu ------- 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 vm ------- 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 ------- 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. ------- 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 ------- 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 ------- 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. ------- 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. ------- 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. ------- 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 ------- 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. ------- 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 8 ------- 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. ------- 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 10 ------- 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. 11 ------- 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 12 ------- 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 ------- 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 14 ------- 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 ------- 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 ------- 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 ------- 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. 18 ------- 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. 19 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. 24 ------- 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 25 ------- 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 26 ------- 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. 27 ------- 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 28 ------- 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 29 ------- 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. 30 ------- 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 31 ------- 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. 32 ------- 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. 33 ------- 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 34 ------- 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 35 ------- 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. 36 ------- 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% 37 ------- 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. 38 ------- 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. 39 ------- 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. 40 ------- 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 41 ------- 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. 42 ------- 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 43 ------- 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. 44 ------- 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 45 ------- 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 46 ------- 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 47 ------- 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. 48 ------- 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 49 ------- 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. 50 ------- 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. 51 ------- 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. 52 ------- APPENDICES /* 53 ------- 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. '. 54 ------- 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. 55 ------- 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. 56 ------- |