EPA/600/R-96/111
                                               September 1996
  POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
           UNITED STATES POSTAL SERVICE
                  BULK MAIL CENTER
                     DALLAS, TX
                          by
          Carole O. Bell, Mary Hoel, Henry Huppert
         Science Applications International Corporation
                   Newport, RI 02840
               EPA Contract No. 68-C2-0148
           SAIC Project No. 01-0828-07-1717-060
                     Project Officers

                    James S. Bridges
                         and
                  N. Theresa Hoagland
              Sustainable Technology Division
        National Risk Management Research Laboratory
                  Cincinnati, OH 45268
        This study was conducted in cooperation with the
                United States Postal Service
NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
       OFFICE OF RESEARCH AND DEVELOPMENT
      U.S. ENVIRONMENTAL PROTECTION AGENCY
                CINCINNATI, OH 45268

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                                    DISCLAIMER
The information in this document has been funded wholly or hi part by the United States
Environmental Protection Agency under EPA contract No. 68-C2-0148 WA 3-10 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.

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                                     CONTACT
James Bridges and N. Theresa Hoagland are the EPA contacts for this report. They are presently
with the newly organized National Risk Management Research Laboratory's Sustainable
Technology Division in Cincinnati, OH (formerly the Risk Reduction Engineering Laboratory).
The National Risk Management Research Laboratory is headquartered hi Cincinnati, OH, and is
now responsible for research conducted by the Sustainable Technology Division in Cincinnati.
                                          n

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                                     FOREWORD
The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency
strives to formulate and implement actions leading to a compatible balance between human
activities and the ability of natural systems to support and nurture life. To meet this mandate,
EPA's research program is providing data and technical support for solving environmental
problems today and building a science knowledge base necessary to manage our ecological
resources wisely, understand how pollutants affect our health, and prevent or reduce
environmental risks in the future.

The National Risk Management Research Laboratory is the Agency's center for investigation of
technological and management approaches for reducing risks from threats to human health and
the environment.  The focus of the Laboratory's research program is on methods for the
prevention and control of pollution to air, land, water, and subsurface resources; protection of
water quality in public water systems; remediation of contaminated sites and ground water; and
prevention and control of indoor air pollution. The goal of this research effort is to catalyze
development and implementation of innovative, cost-effective environmental technologies;
develop scientific and engineering information needed by EPA to support regulatory and policy
decisions; and provide technical support and information transfer to ensure effective
implementation of environmental regulations and strategies.

This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office of Research and Development to assist the
user community and to link researchers with their clients.

              E. Timothy Oppelt, Director
              National Risk Management Research Laboratory
                                           111

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                                     ABSTRACT
The United States Postal Service (USPS) in cooperation with EPA's National Risk Management
Research Laboratory (NRMRL) is engaged in an effort to integrate waste prevention and
recycling activities into the waste management programs at Postal facilities. This report
describes the findings of the Pollution Prevention Opportunity Assessment of the United States
Postal Service, Bulk Mail Center located in Dallas, TX. This assessment was conducted during
the week of May 15,1995.

The report describes the mission of each of the functional areas of the BMC including operations
performed, processes and materials employed and the wastes and emissions generated.  Then, the
Assessment Team makes recommendations concerning the procurement of office supplies,
maintenance supplies and hazardous materials; management of hazardous materials and Wastes;
purchase of chemicals on USEPA's 33/50 list; 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.
                                          IV

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                            TABLE OF CONTENTS


DISCLAIMER	-	•	i

CONTACT	•	 ii

FOREWORD	iii
                                       [ -

ABSTRACT	iv

EXHIBITS	'.	-	 vi

ACKNOWLEDGMENTS	'•	  vii

INTRODUCTION	 1
      1.1    SITE DESCRIPTION	2

BULKMAIL CENTER 	J	3
      2.1    BULKMAIL CENTER	3
            2.1.1  Physical Description of Facility	.. 3
            2.1.2  Mail Handling	....	 4
      2.2    BMC WASTE GENERATING OPERATIONS	5
            2.2.1  Solid Waste Management :	 5
            2.2.2  Sorting Floor	 5
            2.2.3  Lube Room	6
            2.2.4  Tow Lines		6
            2.2.5  Cafeteria	 6
            2.2.6  OTR Repair. Vehicle Fueling/Maintenance	7
            2.2.7  Purchasing  and Stock Room	7
            2.2.8  Maintenance Shops	,	7
            2.2.9  Battery Charging Room	8
            2.2.10 Administrative Offices	8
            2.2.11 polity Perimeter	8
            2.2.12 Crossdock Pallet Facility	9
            2.2.13 Warehouse	9
      2.3   ADDITIONAL WASTE STREAMS	9
            2.3.1  Hazardous  Waste	9
            2.3.2  Used Oil	10
            2.3.3  Pest Control	10

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          2.3.4  Lighting	10

BULK MAIL FACILITY POLLUTION PREVENTION OPPORTUNITIES	11
     3.1   ENVIRONMENTAL OVERSIGHT	12
     3.2   REDUCE PAPER USE	12
     3.3   REUSE AND RECYCLING	13
     3.4   PALLETS	 17
     3.5   LIGHTING AND ENERGY	18
     3.6   FLUORESCENT LIGHTING	....	22
     3.7   RECHARGEABLE BATTERIES	26
     3.8   AFFIRMATIVE PROCUREMENT	...26
     3.8   OVERSIGHT OF CHEMICAL STORAGE	29
   .  3.9   RAGS	30
     3.10  BATTERY CHARGING	31
     3.11  DEDICATED OIL CONTAINERS	32
     3.12  POLLUTION PREVENTION INFORMATION SOURCES	32

CONCLUSIONS AND RECOMMENDATIONS  	34

APPENDICES	35
     EPA33/50 PROGRAM	 36
     OZONE DEPLETING SUBSTANCES	38
     EPA GREEN LIGHTS PROGRAM & THE FEDERAL ENERGY MANAGEMENT
          PROGRAM	40
  •   EPA ENERGY STAR® PROGRAM	42
     FLUORESCENT TUBE AND BALLAST RECYCLING	43
     POLLUTION PREVENTION INFORMATION SOURCES	45
                            EXHIBITS
3.1 BMC SOLID WASTE GENERATION	n
3.2 COST/BENEFIT ANALYSIS FOR OTRS VERSUS GAYLORD USE	14
3.3 PECYCLERS IN THE DALLAS/FORT WORTH AREA	16
3.4 EXAMPLES OF PALLET RECYCLERS IN THE DALLAS AREA	18
3.5 FEDERAL ENERGY POLICIES	;	.19
3.6 SQUARE FEET OF COVERAGE PER DAYLIGHTING UNIT	20
3.7 FLUORESCENT LIGHTING TUBE RECYCLERS	24
3.8 EPA ESTABLISHED MINIMUM RECOVERED CONTENT LEVELS	28
3.9 COST BENEFIT ANALYSIS OF LAUNDERING RAGS	 31

                               vi

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                              ACKNOWLEDGMENTS
Funding for this project was provided by the United State Postal Service under an interagency
agreement.  Jim Bridges and Terri Hoagland of the EPA Office of Research and Development,
National Risk Management Research Laboratory managed the project and participated in the
opportunity assessments. Special thanks are extended to Charlie Bravo and Beirnie Denno of the
USPS Office of Environmental Management Policy and the staff of the USPS Dallas Bulk Miail
Center.
                                         vn

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                                    SECTION 1.0

                                  INTRODUCTION
       The United States Environmental Protection Agency (EPA) is actively supporting the
development of pollution prevention program plans for Federal facilities. Since 1988, the EPA
has managed a technical support effort known as the Waste Reduction Evaluations at Federal
Sites (WREAFS) Program. WREAFS was established to provide pollution prevention solutions
to environmental issues through research, development and demonstration of pollution
prevention techniques and technologies, and transferring lessons learned within the Federal
community and related private sector support industries. WREAFS has conducted more than 37
separate RD&D efforts under funding from both EPA and nine other Federal departments and
agencies via interagency agreements.

       The United States Postal Service (USPS), hi cooperation with EPA's National Risk
Management Research Laboratory (NRMRL), is engaged hi an effort to integrate pollution
prevention and recycling activities into the waste management programs at postal facilities. The
purpose of this project is to perform pollution prevention opportunity assessments (PPOAs) at
several types of Postal Service facilities, representing a cross-section of the USPS inventory; to
identify the pollution prevention opportunities for these 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
Service Bulk Mail Center (BMC) located in Dallas, TX. The site assessment was conducted
during the week of May 15,1995.

       The Assessment Team performed a multi-media assessment. Issues of concern included:
hazardous material acquisition, use and storage; hazardous waste  storage and disposal;
procurement and solid waste management, including recycling. The report begins with a brief
description of the facility.  This is followed by descriptions of specific operations and the wastes
and emissions generated. The report makes both site-wide and operation-specific
recommendations that may lead to the elimination, reduction, or unproved management of the
facility's waste streams. While energy was not part of the multi-media assessment, the
Assessment Team makes energy-related recommendations where appropriate. Mention of trade
names, commercial products, or vendors does not constitute endorsement or recommendation for
use.

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1.1    SITE DESCRIPTION

       The BMC is located in Dallas, TX, at 2400 Dallas-Fort Worth Turnpike. The facility
occupies 75 acres along the 1-35 corridor west of downtown Dallas. The surrounding area is
devoted to mixed commercial/industrial and residential uses. The site is bordered on the north
by Route 35 and an industrial park, on the south by a residential area, on the east by Hampton
Road and a commercial area and on the west by an additional commercial area.  The USPS
operations include one major building and several smaller buildings that house maintenance,
groundskeeping and traffic control operations.

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                                     SECTION 2.0

                            BULK MAIL CENTER (BMC)
       This section addresses the operations performed within the BMC and associated facilities
and the wastes and emissions generated by those operations. The section includes a description
of current waste management practices.

2.1     BULK MAIL CENTER

       The national-bulk mail system is a network of mechanized bulk mail centers that process
3rd and 4th class mail. The USPS operates two large BMCs, five medium BMCs and 14 small.
BMCs. Classification is based on facility size, rather than mail throughput. The Dallas BMC
with approximately 450,000 square feet is considered a medium-sized BMC arid processes
between 500,000 and 800,000 parcels per day.

       The BMC facility in Pallas, TX performs the sorting and routing of packages and bulk
business mail for TX, Oklahoma and parts of Kansas, Arkansas, and Louisiana. In addition, mail
is routed to the twenty other regional BMCs.  The facility employs approximately 1,600
individuals, of which approximately 150 are supervisors and clerical workers. The facility
operates three eight-hour shifts per day, six days per week and two shifts on Sunday. An
additional 300 workers are hired during the Christmas holiday season.

2.1.1   Physical Description of Facility

       The BMC facility occupies 75 acres. The main building contains approximately 452,000
square feet of space which houses administration, workroom floor, facility electrical utilities, air
handlers and air chillers. The space is divided as follows:

Penthouse (air chillers, air handlers, electrical service)     30,064 sq. ft.
3rd Floor (Administrative/Conference Rooms)             16,128 sq. ft.
2nd floor (Administrative)                              16,128 sq. ft.
1st floor (Administrative)                               16,128 sq. ft.
Workroom floor                                      374,000 sq. ft.

       In addition, the facility houses a 2,000 sq.  ft. lubrication storage area (lube! room) that
contains supplies of petroleum products used in the BMC, a used oil storage tank, a staging area
for cardboard recycling and a staging area for oil, rags, and filter disposal.

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       At the east end of the site is a 2,048 sq. ft. former vehicle repair shop that is now used to
repair aluminum mail transport equipment known as over the road containers (OTRs). This shop
also serves as a fuel and oil dispensing area for postal vehicles.  On the west end of the site is a
1,000 sq. ft. "tin shed" that houses groundskeeping equipment and miscellaneous machinery.

       The BMC also has two remote sites: a USPS-owned warehouse at 1982 Fort Worth Ave.
which is shared with the Dallas General Mail Facility (GMF), and a leased facility of 59,000 sq.
ft. located at 3706 La Reunion Parkway that houses the Crossdock Pallet Facility (CPF).

2.1.2   Mail Handling

       Mail enters the main facility via trucks through loading docks on one of 42 inbound
docks, on the east and west side of the facility. Mail is processed and sorted and leaves the
facility via 78 outbound docks on the south of the building. Mail is handled through the facility
according to its physical characteristics and destination. Mail comes in four basic forms: sacks,
parcels, nonmachinable outsides (i.e., those pieces that can not be machine sorted), and bulk
business mail.

       Sacks enter from the inbound docks on extendible conveyors. The conveyor transports
the sacks to slides which feed keying stations. The keyer locates the sack label, positions the
sack in a cradle and keys in the zip code on the label. The cradle tips the sack onto a moving tray
sorter that travels at 70 trays per minute. Sacks placed on a tray travel to the destination chute
where the tray tips and the sack slides into the chute.  The chute leads to an extendable conveyor
on the outbound docks where the sacks are bedloaded (stacked on the bed of the vehicle rather
than containerized) onto the outgoing trucks.

       Parcels arrive at the facility in mail transport equipment (heavy-duty aluminum OTRs,
cardboard gaylords, or wire cages), sacks or bedloaded individually.  Containers are rolled of f the
trucks at the inbound docks and placed onto the Fixed Mechanization Automated Container
System (FMACS or tow line) and brought to the container unloaders. The unloader dumps the
parcels on to a conveyor which moves them to the parcel keying stations on the primary sorters.
Parcels hi sacks are sent through the sack sorter (see above) and then sorted to the sack shakeout
operation where the sacks are opened and the parcels removed and placed on conveyors leading
to the primary parcel sorter. Bedloaded parcels are unloaded directly onto conveyors which
bring them to the keying stations on the parcel sorters. Once sorted, packages slide onto a tray
sorter that dumps them to chutes according to destination. Parcels are loaded into OTRs, wire
cages or gaylords, depending on destination, and moved onto outgoing trucks.

       Bulk business mail enters the BMC on pallets and hi mailer-prepared sacks which are
distributed by the sack system to the east wing annex. Sacks are opened and dumped onto a belt
where individual bundles  are sorted to mail transport equipment and sacks.

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2.2    BMC WASTE GENERATING OPERATIONS

       Wastes generated by BMC operations include excess and obsolete equipment and
supplies; corrugated cardboard; computer paper; white paper; mixed office paper, including
forms and envelopes; magazines and newsprint; employee wastes including cans, bottles,
wrappers and food; pallets; shrink and stretch wrap; aluminum and other metals; wood;
fluorescent tubes and lighting ballasts; batteries; plastic and metal strapping; rags; and oil filters
and waste oil.

2.2.1   Solid Waste Management

       The main building at the BMC has a 40 cubic yard compactor provided by Southwest
Paper Stock. Prior to the segregation of cardboard gaylords for recycling, the compactor was
pulled 30 tunes per month. Currently, the compactor is pulled approximately 12 tunes per
month.  The BMC is charged $147.50 per pull which includes compactor rental. The waste
collected by Southwest Paper is sent to a materials recovery facility for separation prior to
disposal in a landfill. The BMC recycles aluminum and other metals, cardboard gaylords, high
grade white  office paper, and some scrap wood. In addition, there is a six cubic yard container at
the Crossdock Pallet Facility (CPF) that is pulled 26 tunes per month for a cost of $3,774 per
year.  There is no recycling occurring at the CPF.  The BMC spends approximately $27,000 per
year on waste disposal.

2.2.2   Sorting Floor

       As noted above, all bulk mail entering the facility is sorted and routed on the sorting
floor. The sorting floor generates large  amounts of cardboard, metal from equipment repair, oils,
grease, and paper. Cardboard gaylords used for the movement of packages are the largest-single
source of old corrugated cardboard (OCC). After packages that enter the facility in gaylords are
dumped for sorting, the gaylords are broken down and placed hi an OTR. The OTR is attached
to the tow line and sent to the lube room where the gaylords are processed for recycling. Staff
stated that the lack of storage space and the inability of staff to segregate reusable from damaged
gaylords prevents the wide reuse of gaylords.  Reuse of gaylords is limited to tunes when no new
gaylords are available. The BMC currently recycles only cardboard gaylords; other OCC is put
into the compactor.

       Weyerhauser places a trailer at the dock in the lube room. The gaylords are placed on
pallets in the lube room. Strapping, shrinkwrap and other contaminants are removed, and the
OCC is placed in the trailer. The BMC staff believe that they recycle approximately 70 to 80
percent of the OCC. The BMC plans to consolidate the recycling in a separate area, purchase a
horizontal auto-tie baler and become the USPS regional collection point for OCC recycling.  The
BMC recycles approximately 60 tons of gaylords per month and receives $ 140 per ton,
representing revenue of approximately $8,400 per month.

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       The sorting floor also generates significant quantities of undeliverable bulk business mail
(UBBM) and loose-in-mails (LIMs), the USPS term for loose or damaged bulk mail. UBBM is
currently discarded into the compactor. There are nine LIMs chutes that generate approximately
five to six wire cages of LIMs per day.  The LIMs are sorted to verify that no deliverable mail is
present and the remains are discarded into the compactor.

       The Rewrap Section processes mail that has been damaged or is otherwise undeliverable.
Broken, leaking or questionable packages are sent to the Rewrap Section where they are opened,
examined and, if possible, repackaged using new cardboard boxes and returned to the mail
processing system. This section generates a substantial amount of mixed paper and corrugated
cardboard that is currently discarded into the compactor.

2.2.3  Lube Room

       The lube room is located in the southeast corner of the main building and contains an oil
storage rack, a used oil storage tank, a parts washer, a tow line grease storage container and two
flammable materials cabinets. The flammable materials cabinets were completely filled with
paints, oils, cleaners, and degreasers. Several products contained ozone depleting substances
(ODS) and constituents included on the EPA 33/50 list of chemicals targeted for reduction.  See
the appendices for further discussion of ozone depleting substances and EPA 33/50 chemicals.
The lube room had an open drain that leads to the sanitary sewer. The lube room also serves as
.the staging area for loading of cardboard for recycling.

2.2.4  Tow Lines

       During routine maintenance, the tow lines are cleaned out quarterly, generating a thick
heavy grease. The BMC generates approximately four 55-gallon drums of tow line sludge per
quarter. The sludge is placed in a closed basin in the lube room.  The sludge is then biotreated
using microbes to reduce the viscosity of the grease so it is pumpable.  Following treatment the
grease is filtered and pumped to the used oil tank hi the lube room.  See Section 2.3.2 for a
discussion of used oil management.

2.2.5  Cafeteria

       The cafeteria/lunch room serves food via vending machines. Wastes from the cafeteria
include wastes disposed by employees such as paper and plastic bags, aluminum foil and other
containers, such as yogurt or soup, brought hi from home.  Food waste is mixed with these
materials. Beverages are sold in aluminum cans and glass and plastic bottles.  An aluminum can
collection box was present in the cafeteria. Deliveries of food products generate corrugated
boxes and packaging which are sent to the compactor.

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2.2.6   OTR Repair. Vehicle Fueling/Maintenance

       The BMC has a 2,000 sq. ft. repair facility that consists of two buildings at the east end of
the site. One building is used for the mechanical repair of OTRs, wire cages and other
equipment. This building houses welding equipment as well as other machine shop equipment.
Repairs performed include structural repairs as well as replacement of tow pins, wheels, or other
parts. The shop is typically staffed with five to six employees. The OTR shop repairs between
10 and 18 OTRs per person per day. The repair area had at least 300 OTRs and wire cages
stockpiled awaiting repair. Numerous additional pieces of mail transport equipment requiring
repair arrive each day from all parts of the country.

       The second building is a maintenance shop for painting and prep of OTRs and other
maintenance. This building is adjacent to the fueling area so no "hot" work occurs in this
building. In addition, this facility readies new OTRs for use by painting on the marking area and
adding a Dallas identification number.

       Each building has a flammable materials cabinet that contains numerous containers of
paints, oils, and degreasers. Several partially used containers of insecticide were also found in.
the two buildings. Adjacent to the fueling area is a flammable materials cabinet that contains
drums; of motor oil for vehicles.  An inspection of the flammable materials cabinet in the OTR
repair shop revealed the bottom filled with several inches of oil.

2.2.7   Purchasing and Stock Room

       The stock room at the BMC stores parts and materials used by the BMC staff and is the
central ordering area for equipment. All parts and supplies are ordered through the stock room.
The stock room staff uses a computerized ordering system to acquire materials from GSA or the
Materials Distribution Center in Topeka, KS. The staff also orders from local suppliers.
Approximately 25 people have access to the stock room.  Nine individuals have the authority to
order parts and materials. These orders are approved by one of three maintenance supervisors,
the maintenance manager and the purchasing officer. Parts requests from staff are entered via a
computer terminal on a shelf outside of the stock room. The stock room staff retrieves the part if
it is in stock or orders the part if necessary.

2.2.8   Maintenance Shops

       The maintenance department performs repairs on sorting equipment as well as building
maintenance and upkeep. The maintenance shop contains two degreasers that use "Powersolv"
solvent, an aqueous-based cleaner degreaser. Rags used by the maintenance staff tend to be very
oily and the staff has found that they cannot be cleaned and reused. The facility was using a rag
service, but found that they were continually purchasing new rags because the service could not
clean the rags. All rags are now purchased either locally or through GSA and disposed via
incineration. The BMC  purchased 6,250 pounds of rags in 1994 for $2,375 and hi 1995 through

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April have purchased 3,750 pounds for $555. The facility generates three to four 55-gallon
drums of rags per month which are incinerated for approximately $400 per drum ($1200 to
$1600 per month).

       All flammable materials storage cabinets contained products with chemical constituents
listed on the EPA 33/50 list. The BMC staff has discontinued ordering products containing these
chemicals, found suitable replacements  and is in the process of depleting stocks.

2.2.9  Battery Charging Room

       The battery room, located on the main floor of the BMC, is used for recharging and
storage of batteries used in BMC vehicles, approximately 37 forklifts and 20 jitneys. Each
vehicle has three batteries: one hi use, one charged and ready, and one charging. The facility
estimates there are  150 batteries  on-site. The room has an open floor dram with no diking to
prevent spills from entering the sanitary sewer. The BMC is presently in the process of
upgrading the battery charging room to  increase storage capacity, install better ventilation and
lighting and provide a limestone tank for the neutralization of any acids released hi the battery
room.  In 1994, the BMC recycled 30 batteries to Exide Corporation, a battery manufacturer.

2.2.10 Administrative Offices

       The BMC contains three floors occupied by offices and conference rooms (approximately
48,000 sq. ft.).  The significant wastes include computer printouts, white paper, mixed office
paper, toner cartridges and employee wastes. The BMC has initiated a white paper recycling
program. While some employees were participating hi the recycling program, most were not, as
evidenced by white paper in nearly all trash containers. Lighting in all offices, conference rooms
and restrooms is motion sensitive. The BMC plans to install new carpeting manufactured from
recycled polyethylene.                                                    '.

2.2.11 Facility Perimeter

       During a walk around the facility perimeter, the Assessment Team noted the presence of a
"tin shed", several  roll-off containers and several miscellaneous material storage areas. The tin
shed houses groundskeeping equipment and a variety of excess equipment and materials
including tires and other parts. Near the tin shed is a 30 cubic yard container dedicated to the
collection of wood wastes. According to the BMC staff, this container is pulled for recycling by
Southwest Paper on an "on-call" basis.  The contents of the container were contaminated with
plastic and cardboard boxes. There is also a 30 cubic yard container for metals recycling. The
BMC generates 10 to 12 tons of scrap metal per month.  The container is typically pulled twice
per month by Atlas Scrap and the USPS receives approximately $70 per ton, generating revenue
of approximately $800 per month. The facility also generates 15 to 20 tires per year.  These tires
are either removed by the tire company performing the replacement or are sent to the VMF hi
Dallas for management. Scrap equipment piles were located all around the west and northwest

                                           8

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perimeter awaiting use or disposition. Bulk aluminum is typically sold at auction in 20,000
pound lots; however, in fiscal year 1995 there has been one sale of approximately 97,000 pounds
of aluminum for which the USPS received approximately $7,929.

2.2.12 Crossdock Pallet Facility

       The Crossdock Pallet Facility (CPF) is a 59,000 sq. ft. leased facility located at 3706 La
Reunion Parkway in an industrial park approximately one mile from the BMC. The CPF
redistributes palletized materials from bulk mailers.  Palletized materials arrive on trucks from
bulk mailers. The CPF personnel unload the trucks and determine if the materials on each pallet
are already sorted by BMC or are mixed. Those pallets that are correctly separated for other
BMCs are put directly onto trucks. Pallets that contain mixed loads are broken down, sorted, re-
palletized, shrinkwrapped and put on the correct truck for shipment If the pallets are for the
Dallas region, the packages are sent to the BMC for sorting and routing.

       The CPF is also the accumulation point for all sacks for the Dallas BMC region. Sacks
arrive from all over the Dallas region loose, bagged, or in OTRs and wire cages.  The sacks are
sorted by type, checked for mail, removed from service if damaged, repackaged, and sent to the
annex. Sacks are shipped to local Post Offices or bulk mailers, as required.

       All waste generated at the CPF is disposed in a six cubic-yard container that is emptied
daily for a cost of $3,774 per year. No recycling is performed at this facility.  Wastes generated
include pallets, shrinkwrap, cardboard, damaged  sacks, and strapping. USPS plastic and
pressboard pallets are shipped to the Arlington TX pallet distribution center. Wood pallets are
disposed.  The facility also has a fork truck battery charging operation with no safety or spill
prevention equipment present.

2.2.13 Warehouse

       The warehouse, located at 1982 Fort Worth Ave., is a facility shared by the BMC and the
GMF. The facility is approximately one mile from the BMC. The BMC uses this space
prirmirily for the storage of cardboard gaylords for use in the BMC and some excess equipment.
It was unclear which material belonged to the BMC and which to the GMF. The warehouse aiso
had a fork lift battery charging station in operation with no safety or spill prevention equipment
present. One area hi the facility is used for records storage. There is no trash service at this
facility. All wastes generated here are discarded  of at the BMC or GMF facilities.

23    ADDITIONAL WASTE STREAMS

2.3.1   Hazardous Waste

       The BMC does not generate large amounts of hazardous waste on a regular basis.  The
BMC has begun to take all aerosol cans to a central depository. The aerosol cans are punctured

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and drained into one of two drums. One drum is designated for paints, the other for oils. Once
emptied, the cans are recycled with the metal scrap. The BMC has not yet generated a full drum
for disposal.

       The BMC generated one 55 gallon drum of hazardous waste in 1994, which was waste
paint classified F003 and F005.

2.3.2  Used Oil

       Used oil from sorting machines and motors is typically filtered and reused on the tow
line. The BMC uses a portable filtering unit that can be used for motor oils and cooling oils.
After final use the oils are sent to the used oil collection tank. Used oil is collected by
Worldwide Reclamation who sends it to CSC Disposal for rerefining. In 1994, the BMC
generated approximately 11,500 pounds (1,500 gallons) of waste oil.  The facility generates 10 to
20 oil filters per year from the compressors and other equipment. The oil filters are collected by
Worldwide Reclamation and sent off-site for incineration.
            .                                  , _
2.3.3  Pest Control

       The facility has discontinued the application of pesticides by its employees and contracts
all pest control to licensed applicators. The staff has attempted on more than one occasion to
remove all aerosol pesticides from the facility, but several containers were found during the
assessment

2.3.4  Lighting

       The BMC primary lighting is provided by fluorescent fixtures. The facility is in the
process of changing over to halogen lighting; however, capital improvements funding for the
lighting systems were recently denied by the regional environmental office. The BMC staff
stated that it is then- goal to eliminate all fluorescent lights from the facility because of the
environmental impacts of the disposal of fluorescent tubes.  The BMC discards 21 fluorescent
tubes per day, five days per week into the compactor.  The staff collects lighting ballasts and
batteries for recycling. The staff is currently investigating the use of new sulfur-based lighting
systems under development by Fusion Lighting and the Department of Energy.  Motion sensitive
lights were in use in me office spaces, but nowhere else.
                                            10

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                                  SECTION 3.0
       BULK MAIL FACILITY POLLUTION PREVENTION OPPORTUNITIES
      This section describes pollution prevention opportunities specific to the operations of the
Bulk Mail Facility. Exhibit 3.1 presents a summary of the BMC waste generation, current
management and potential pollution prevention opportunities.

                 EXHIBIT 3.1 BMC SOLID WASTE GENERATION
Waste
Obsolete, damaged or
defective equipment
Corrugated cardboard
Computer print-out
White paper
Mixed paper
Magazines
Toner cartridges
Pallets
Plastic stretch wrap
Rags
Fluorescent tubes
Strapping.
Oil
Alkaline Batteries
Lighting Ballasts
Current Management
Disposed or sold as scrap
Some reused, gaylords recycled,
other cardboard disposed
Discarded as waste
Some recycled
Discarded as waste
Discarded as waste
Returned for recycling
USPS pallets sent to Arlington
facility for redistribution. Pine
pallets sold as scrap for mulch
Discarded as waste
Discarded as waste
Discarded as waste
Discarded as waste
Rerefined
Recycled
PCB ballasts managed as hazardous,
non PCB ballasts recycled
Opportunities
Repair at USPS Computer Repair Facility
(CRF) in Topeka, KS, Reuse
Reduce use of gaylords;Increase use of
OTRs; Reduce incoming boxes; reuse
boxes; Improve diversion for recycling
Reduce generation, divert for recycling
I
Reduce generation, improve diversion for
recycling
Reduce generation, divert for recycling
Reduce generation, divert for recycling
Continue recycling
Reduce variety, reuse pine pallets,
establish recycling options for pine
pallets
Reduce generation, divert for recycling
Investigate rag service feasibility
Improve ambient light, install motion
sensitive lighting, divert for recycling
Divert for recycling
Purchase rerefined oil
Use rechargeable batteries
Improve ambient light, install motion
sensitive lighting, turn lights off
                                        11

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3.1    ENVIRONMENTAL OVERSIGHT

Current Conditions

       The Dallas BMC does not have an environmental coordinator who is responsible for
environmental activities at the facility. Instead, environmental activities are addressed on an as-
needed basis by either the facility maintenance supervisors or other staff members. More
importantly, no one is designated to monitor environmental compliance and issues at the site.
Ultimately, the highest ranking USPS employee on site is responsible and liable for all
environmental activities. BMC personnel attend meetings sponsored by the area environmental
compliance coordinator to share ideas on reducing the environmental impacts of USPS
operations.

Pollution Prevention Opportunities

1. Appoint an Environmental Coordinator

       The Dallas BMC should appoint at least one environmental coordinator for the facility.
This individual should monitor environmental issues and implement opportunities to reduce
waste disposal and emissions at the facility.

3.2    REDUCE PAPER USE

Current Conditions

       Office personnel interviewed by the Assessment Team, while aware of the double-sided
copying capabilities of duplicating equipment, do not consistently use those options. Staff is not
aware of any efforts to encourage reduction in the quantity of paper used and disposed. The
Assessment Team observed a significant amount of white paper and computer print-out in the
waste containers.  White paper is recycled by some personnel, but mixed office papers and
magazines are not recycled.  Some older copy machines do not have double-sided copying
capabilities,

Pollution Prevention Opportunities

1.     Adopt paper waste reduction techniques

       Before initiating an enhanced recycling program, facility managers and staff should adopt
and promote a variety of techniques to prevent or reduce the quantity of paper generated for
disposal.
                                          12

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•      Establish a duplex copying policy for all multi-page documents and provide staff training
       in the use of the double-sided function on copying equipment. As equipment is replaced,
       specify easy to use, rapid, duplex capability.  .   -               .

•      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.

•      Identify opportunities to reuse paper and paper products. Corrugated cardboard boxes,
       jiffy bags, manila envelopes and other packaging materials are reusable for their original
       function; 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 as paiper
       file copies.

3.3    REUSE AND RECYCLING

Current Conditions

       Currently, the BMC separates cardboard gaylords, aluminum cans, other aluminum and
metals, used lubricating oil and some paper for recycling. Staff flatten the gaylord boxes after
one use and place them in an OTR on the tow line for staging for recycling. All other OCC is
placed hi the trash compactor. The.BMC staff predict that they will spend more than $1,000,000
hi fiscal year 1995 to purchase gaylord boxes, each of which will be used only once. USPS
plastic and pressboard pallets are sent to the Arlington, TX pallet distribution center. Wooden
pine pallets are recycled as wood scrap. The recycling program for paper is limited to collection
of high grade white paper. The office staff has not been trained to participate in recycling; some
offices had recycling containers, many did not. Many desks had small recycled paper holders
which typically are inadequate to hold a sufficient quantity of recycled paper and often are not
used. No other paper is being recycled. UBBM and LIMs are currently discarded into the
compactor. All waste generated at the Crossdock Pallet Facility is discarded; no recycling is
occurring at this facility.

Pollution Prevention Opportunities

1.      Use OTRs instead of cardboard gaylords                            ;

       The use of gaylords for moving packages has increased significantly in the last several
years. BMC staff stated that this is caused by the inability to obtain adequate supplies of mail
transport equipment, especially BMC OTRs.  As a result, OTRs are used only to transport
packages within the Dallas region. Packages that leave the Dallas region are packed in gaylords

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or are bedloaded.  OTRs are hoarded by all USPS facilities to cope with seasonal mail volume
increases. According to USPS Headquarters Mail Transport Equipment Office, aluminum OTRs
cost $1,138 and have an expected life of 10 years. Gaylords are used for a single trip at the
Dallas BMC and cost approximately $6.00 each, depending on the size. The Dallas BMC
predicts that it will purchase in fiscal year 1995 approximately 28,425 30- inch gay lords for a
cost of $147,969 and 143,000 54-inch gaylords for $875,000. The BMC will spend more than
$1,000,000 to purchase new gaylord boxes in fiscal year 1995. Exhibit 3.2 provides a simple
cost/benefit analysis of OTR versus gaylord use. This analysis shows that an OTR could be used
as few as 39 times per year and be more cost effective than the use of gaylords. As a result, the
USPS should increase the number of OTRs hi the system and increase the repair staff to keep
OTRs in service to reduce the reliance on gaylords:

   EXHIBIT 3.2 COST/BENEFIT ANALYSIS FOR OTRS VERSUS GAYLORD USE*
Cost/Activity
a. Initial Cost
b. Number of Trips
c. Maintenance Cost
d. Scrap Value
e. Total Cost
f. Cost Per Trip
Aluminum OTR
$1,138.00
1500 (150/year for 10 years)
$1000($100/yearforlO
years)
$30
$2,108
$1.40 ;
Double-Walled Cardboard
Gaylord
$6.00
1
None
$0.70
$5.41
$5.41
 ' Assumptions:
        1.
        2.
        3.
        4.

        5.
        6.
An OTR is used for three trips per week, 50 weeks per year for a total of 150 trips per year.
An OTR is in repair two weeks per year; for an annual cost of $100.00.
Life expectancy of an OTR is 10 years.
An OTR weighs 385 pounds. Scrap aluminum value is $0.08 per pound based on recent auction price
for aluminum scrap.
A gaylord is used for one trip (based on Dallas BMC usage).
A gaylord weighs 10 pounds and scrap yalue is $0.07 per pound ($140 per ton).
2.     Cancel the Integrated Mail Handling System

       USPS has an existing inventory of mail transport containers, including both aluminum
and steel BMC OTRs, originally intended for use in the immediate service area of each Bulk
Mail Center. Although OTRs were not intended to be used to move mail between BMCs or
PDCs and BMCs, workers found it too time consuming to unload bedloaded trucks. Now, postal
employees use OTRs to move mail between facilities.  BMCs and PDCs hoard OTRs for the
                                           14

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holidaiy season, and bulk mail customers take OTRs and do not return them. The BMCs have no
control over the OTR inventory, thus OTRs are not readily available to move the mail.

       To solve the problem of access to mail transport equipment, the USPS has designed the
Integrated Mail Handling System (IMHS). The planned IMHS would substitute disposable,
corrugated cardboard gaylord boxes for the permanent, reusable OTR containers. In addition,
because gaylord boxes of adequate volume are too tall, existing BMC mail handling equipment,
designed to accommodate OTRs, will require modification.

       Rather than invest in costly equipment and program modifications that will increase solid
waste quantity and handling costs, the USPS should purchase enough additional OTRs or other
permanent mail transport equipment for the nationwide movement of non-peak period mail
volume and design and implement a nationwide bar-code labeling and tracking system for the
OTRs. By utilizing Regional Equipment Processing Centers to track and distribute OTRs in a
timely fashion, the need for the cardboard gaylords will be eliminated.  The gaylords currently
stocked for the IMHS can be used only during the Christmas season.

2.     Reuse cardboard gaylords that enter facility

       As noted above, gaylords that enter the BMC are sent to the lube room for recycling.
Gaylords are only reused when no new gaylords are available. USPS employees believe that it is
too difficult to determine the structural integrity of a used gaylord and that it is too time
consuming to flatten the used gaylord and return it to the storage area for reuse.  The BMC
should establish a procedure to evaluate each gaylord entering the facility.  Reusable gaylords
should be broken down and staged for reuse. Damaged gaylords should continue to be managed
by recycling. One reuse of each gaylord will reduce the costs for gaylords in half, saving the
BMC $500,000 in purchasing expenses.

3.     Reuse cardboard boxes in other processing operations

       All corrugated cardboard, with the exception of gaylords, is sent to the trash compactor.
Boxes of the appropriate size in good condition should be reused in other operations. For
example, the Rewrap Section uses all new boxes for repackaging parcels. The BMC should
segregate the appropriate sized boxes for use hi Rewrap and only use new boxes when reusable
boxes are not available.

4.     Segregate for recycling the OCC that cannot be reused

       The BMC  believes that it is recycling 70 to 80 percent of its cardboard by recycling the
gaylords and that only 20 to 30 percent is sent to disposal. The Assessment Team believes these
figures are accurate. The BMC recycles approximately 60 tons of OCC each month and receives
$140 per ton. In fiscal year 1995, to date, the BMC has received revenues totaling approximately
$39,000. Collecting the additional 20 to 30 percent of OCC would reduce disposal costs and

                                          15

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could yield additional revenues. To increase the recycling rate, however, would require
additional labor to evaluate and separate the OCC for reuse or recycling.  This will be
economically justifiable when the proposed recycling center is built and the baler utilized.

5.     Improve office paper recycling system

       Given the current market value of all grades of office paper, the BMC should improve the
separation of paper for recycling. The BMC should provide more individual and area collection
containers for recyclable paper. These container should be clearly labeled and/or a distinct color
to distinguish them from the waste  containers.  A collection container for paper recycling should
be located next to each printer and copying machine. Employees should be encouraged to empty
their desk collection boxes into centralized consolidation containers. The recyclable paper
should be regarded as a valuable commodity, not a waste. Employees need information
concerning the kinds of paper that can and should be recycled. Employees should be involved in
the planning and implementation of the recycling program so that they will value participating in
it Exhibit 3.3 provides information on some local companies interested hi discussing paper
recycling opportunities and the materials and prices currently quoted.  USPS Environmental
Management Policy Office is developing a draft recycling contract and guidance to assist postal
facilities in selecting a recycler.

         EXHIBIT 3.3 RECYCLERS m THE DALLAS/FORT WORTH ARE A
Recycler
Recycle America Of Dallas
(Waste Management)
12260 Garland Rd
Dallas, TX
Daltex Recycling Company
408 Singleton Blvd.
Dallas, TX 75212
Rock Tenn
9233 Denton Drive
Dallas, TX 75235
i
Material Accepted
Paper
Mixed Paper
Cardboard
Paper
OCC
OCC
Mixed office Paper
Computer Paper
White Ledger
Material Price
(September, 1995)
OCC $169 per ton
Mixed Office $60-70 per ton
White Paper Varies depending on grade
Computer Varies depending on grade
OCC $205-2 15 per ton baled
$80 per ton on skids
CPO $150 per ton
Mixed $30 per ton
White $90 per ton
OCC $ 190 per ton baled
$150-170 per ton loose
Mixed office $30 per ton
Computer $400 per ton
White Ledger $300 per ton
 6.      Reduce quantity of UBBM and LIMs

        USPS bulk mail policies and support services to bulk mailers contribute to the quantity of
 undeliverable bulk business mail (UBBM), including magazines and newsprint, in the USPS
                                           16

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waste stream. Current USPS policy promotes recycling of UBBM; a policy promoting UBBM
reduction is not under consideration. UBBM and LIMs constitute a substantial input into the
BMC wastestream and the USPS incurs significant costs to process, transport, deliver and
dispose of UBBM.

       To determine whether reduction or recycling is the most cost effective management
practice for UBBM, the USPS should perform a cost analysis to compare the combined revenues
from bulk mailing and recycling of UBBM to the costs associated with sorting, handling,
transporting and processing undeliverable mail and associated packaging.

       To reduce the quantity of UBBM managed by postal facilities, the USPS could expand its
mailing list maintenance service. Annual mailing list updates, particularly for third and fourth
class mail, could be integrated into the bulk mail permitting process.

7.     Begin UBBM and LIMs recycling

       At a rninimum, the Dallas BMC should begin to recycle UBBM and LIMs to avoid the
disposal costs and potentially earn revenues.  There would be a minimal additional handling
costs because the UBBM and LIMs are already hand-verified prior to disposal and would only
need to be segregated for recycling.  Many areas have initiated hauling of UBBM, magazines and
newsprint to a central location by integrating hauling of UBBM into the existing mail
transportation system. A separate transportation system to move UBBM to an accumulation
point will increase costs and environmental impacts.

8.     Set up additional recycling bins in cafeteria

       Metal, glass and plastic food and beverage containers should be separated for recycling.
Metal containers can be accommodated in the existing metals recycling containers.  A new
recycliing program should be established for glass and plastic food and beverage containers.

3.4    PALLETS

Current Conditions

       The BMC receives a variety of pallets including pine, HDPE plastic, and pressboard
pallets. The BMC currently does an excellent job of collecting and sending the plastic and
pressboard pallets to the Pallet Distribution Center hi Arlington, TX facility. Purchasing staff
believe that pine pallets also are sent to the Arlington facility.  The wood container on the north
side of the facility, however, contained numerous pallets which were being sold as wood scrap.
In addition, pine pallets at the CPF are discarded into the waste container.
                                          17

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Pollution Prewnt'9" Opportunities

1.     Establish a recycling program for pine pallets

       Establish a formal recycling system for pine pallets.  Recyclers will repair or rebuild
pallets for resale.  Exhibit 3.4 provides a summary of some pallet recycling services available in
the Dallas area.

     EXHIBIT 3.4 EXAMPLES OF PALLET RECYCLERS IN THE DALLAS AREA
            Company
                                                   Size Collected and Price
  American Pallet Rebuilders
  Phone: (214) 744-4840
The company will only purchase 48"x 48" pallets and will pay up to $2.50
per pallet, depending on condition. Will collect, at no charge, a minimum
of 400 to 500 pallets.	            •
  AAA Pallets
  Phone:(214)445-0036
AAA Pallets will pay 50 to 75 cents per pallet, depending on condition,
Accept all sizes of pallets for recycling. For once-a-week pickup, AAA
will leave a van onsite; for once-per-month pickup, AAA will send a van.
AAA recycles and repairs pallets. Nothing goes to the landfill.
  All Size Pallet Supply
  Phone: (800) 281-8150
All Size Pallet Supply will pay $1.00 for 48" x 48" pallets. All other sizes
will be collected at no cost, but the company will not pay for them.
Pallets are torn down and rebuilt into needed sizes or repaired and sold to
customers.                             	
  Summers Pallet Service
  Phone: (800) 992-2052
 Summers will collect all pallet sizes but only pays for certain sizes. Prices
 range from 50 cents to $3.00. For a 48" x 48" pine pallet, they quoted
 $2.00. Would provide drop trailers if volume is considerable. Summers
 recycles pallets, disassembles odd sizes and remakes them, and grinds
 rotten pallets for compost.	•	
 3.5    LIGHTING AND ENERGY

 Current Conditions

        The Federal government is a major consumer of energy, using more than two percent of
 all energy consumed in the United States. The Energy Policy Act of 1992 requires Federal
 agencies to reduce energy consumption per gross square foot 20 percent by the year 2000 and
 Executive Order 12902 requires Federal agencies to reduce energy consumption 30 percent by
 the year 2005. Although the USPS is not an Executive Branch Agency, it is Postal Service
 policy to adhere to Executive Orders whenever feasible. Both reductions are from a 1985
 baseline. In addition, Federal agencies must conduct comprehensive energy audits and install
 cost-effective energy conservation measures; agencies are encouraged to audit 10 percent of then-
 facilities each year, using "no-cost"  audits where practicable. These requirements are
 summarized hi Exhibit 3.5.
                                              18

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       The BMC is in the process of upgrading the lighting on the floors with high intensity
lighting and hopes, over tune, to eliminate the use of fluorescent lights completely. The BMC is
a 22 year old building and is in need of significant lighting upgrades. One potential
improvement is to switch all the fluorescent lights to sulfur lighting tubes. The Dallas BMC has
volunteered to be a "model facility" for sulfur lighting. The USPS regional environmental
coordinator will purchase the lights, and the Department of Energy will install the lighting
system in the facility. The BMC is willing to consider other methods to improve the floor
lighting as well as the lighting efficiency.

                     EXHIBIT 3.5  FEDERAL ENERGY POLICIES
Energy Policy Act of 1992
Reduce energy consumption per gross square foot 10
percent by 1995 (1985 baseline)
Reduce energy consumption per gross square foot 20
percent by 2000 (1985 baseline)
Conduct comprehensive facility audits and install
cost-effective energy conservation measures
In Federally owned buildings, install all energy and
water conservation measures that have payback
periods of less than 10 years
Executive Order 12902
Reduce energy consumption per gross square foot 30
percent by 2005 (1985 baseline)
Reduce energy consumption per gross square foot 20
percent in industrial facilities by 2005 (1990 baseline)
Conduct surveys and comprehensive audits
Implement recommendations for energy efficiency,
water conservation and renewable energy that have
payback periods of less than 1 0 years
       In a separate, but related issue, the roof at the BMC is also in need of repairs. In several
locations throughout the building, leaks have developed in the roof. There has been some
discussion about replacing the roof and, as a result, ambient lighting projects may be considered.

Pollution Prevention Opportunities      .

1.      Increase the Use of Motion Sensitive Lighting

       While motion sensitive lighting was used hi office areas it was not apparent hi other parts
of the facility. The BMC staff should review the lighting plans and install motion sensitive
lighting hi infrequently used areas.

2.      Establish a "lights out" policy

       Establish a policy of turning off lights and equipment when leaving an area. Where
machine design permits, turn photocopiers to low power when not in use. Each kilowatt hour
saved prevents the formation of air pollutants, including 0.68 kg of carbon dioxide, 5.8 g  of
sulfur dioxide and 2.5 g of nitrogen oxides.
                                           19

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3.     Investigate Increasing the Use of Ambient Lighting

       The Dallas BMC should study the possibility of installing daylighting systems (i.e.,
skylights) to allow more energy efficient lighting into the building. An estimated 30 to 50
percent of the energy used in a commercial building is spent illuminating the interior. Daylight
can significantly reduce energy consumption and peak energy use in commercial buildings.

       There are two basic systems for daylighting, active and passive. Active daylighting
systems employ a system of stacked reflective mirrors and a robotics unit with an infrared, light-
sensitive photo diode that tracks the sun as it travels through the sky. The units are set for the
specific latitude of the building. During the day, the units turn to catch the sun at its maximum
angle, then reflect the light down through the skylight. With passive daylighting systems, the
sunlight penetrates the external dome and directs the light into the building.  Exhibit 3.6 presents
the approximate square  feet of coverage per daylighting unit.

      EXHIBIT 3.6 SQUARE FEET OF COVERAGE PER DAYLIGHTltNG UNIT
Ceiling Height (feet)
8to9
10 to 15
16 to 19
20 to 40
Low Levels of Light
(30-50 foot candles)
400 sq ft
700 sq ft
900 sq ft
1000 sq ft
High Levels of Light
(50-100 foot candles)
300 sq ft
SOOsqft
TOOsqft
800 sq ft
       There a several companies that produce and install daylighting systems. Two compani.es
provided information for this report: So-Luminaire Daylighting Systems Corporation and The
Natural Lighting Company. The So-Luminaire system is an active daylighting system that is
installed in 4' x 4' casings on the roof of a building and reflects natural sunlight through a
skylight into the ulterior of a building.  A cluster of diffusion lenses spreads the daylight inside
the building. So-Luminaire's two diffusion lenses create dead air spaces which act as thermal
barriers to reduce conductive heat gam/heat loss by approximately 50 percent. So-Luminaire
estimates that each unit eliminates the use of over two million watts of fluorescent lighting per
year, and only consumes one cent in energy costs per year.

       The Natural Lighting Company manufactures both active and passive daylighting
systems. The active daylighting system uses sun-tracking mirrors to redirect sunlight into a
reflective light well and diffusing lens. The passive daylighting system uses an innovative
prismatic dome, reflective light well and diffusing system to light interior spaces.  The Natural
Lighting Company also produces the So-Dark motorized shade screen which is built into the
skylight frame allowing a skylight to be partially or completely darkened at the flip of a switch.
This product can be used with either the active or passive daylighting systems.
                                           20

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       There are several benefits to daylighting and improved facility lighting. The most
important is that energy-efficient building design can significantly increase worker productivity.
A recent study by the Rocky Mountain Institute found that efficient lighting (as well as heating
and cooling) measurably increased worker productivity, decreased absenteeism, and/or improved
the quality of work performed. An increase of 1 percent in productivity can provide savings to a
company that exceed its entire energy bill. The study presents eight case studies of improved
productivity resulting from increased lighting efficiency.  One case study included the main post
office hi Reno, Nevada which found that a lighting retrofit with a six-year payback led to a six
percent gain in productivity — worth more than the cost of the retrofit.

Other benefits of daylighting include:

       •     reducing electric lighting utility costs
       •     reducing electric lighting maintenance costs
       •     reducing electric lighting heat loads on air conditioning systems

4.     Investigate Technical Assistance from Green Lights Program

       The staff at the BMC expressed interest in technical assistance to modify the lighting at
the facility.  USEPA operates Green Lights, a voluntary, non-regulatory program promoting
pollution prevention through the installation of energy efficient lighting. Federal partners agree
to upgrade lighting to maximize energy savings wherever it is profitable. The Green Lights
program benefits participants by lowering electricity bills, improving lighting quality, and
increasing worker productivity. Energy efficiency also reduces the quantity of pollutants
released in the generation of electricity. For example, EPA estimates that if Green Lights were
fully implemented, where profitable, in the United States, it would save over 65 million kilowatts
of electricity annually, reducing the national electric bill by $16 billion per year. The program
would also result in reductions of carbon dioxide, sulfur dioxide, and nitrogen oxides equivalent
to 12 percent of U.S. utility emissions, curbing acid rain and smog and helping to slow the
greenhouse effect.

       See the appendices for additional information on Green Lights and the Federal Energy
Management Program.
5.     Procure computers that meet Energy Star requirements

       Future computer equipment purchases should specify equipment that is energy efficient.
Executive Order 12845 requires Federal agencies to purchase computer equipment that meets
EPA Energy Star requirements for energy efficiency. The EPA Energy Star Program is a
voluntary partnership with the computer industry to promote energy-efficient personal
computers, monitors and printers. Participating companies have committed to develop computer
equipment that powers down when not in use. The "sleep" feature cuts energy use by 50-75%.

                                           21

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Energy Star also includes a category for controlling devices, external retrofit products that reduce
the energy consumption of existing computer equipment by automatically turning them off when
not in use.  The Federal Supply Service offers a product called the Intelligent Energy Saver, a PC
add-on device that controls electrical power to the PC and its peripherals. The complete PC
system can be powered on and off at user-defined dates and times. See the appendices for
additional information on the Energy Star Program.

3.6    FLUORESCENT LIGHTING

Current Conditions

       The BMC offices, warehouses and work areas are lighted with approximately 1,500
fluorescent tubes. The BMC discards at least 21 fluorescent tubes per day, five days per week
into the trash compactor. Staff believe that if they limit their disposal to 24 tubes per day, they
do not need to dispose of them as a hazardous waste.  According to the TX Natural Resources
Conservation Commission, Industrial and Hazardous Waste Division, fluorescent lights are not
automatically hazardous. A determination must be made using TCLP or by simply declaring
them as hazardous. The determination on whether they must be managed as a hazardous waste is
dependent on the RCRA status of the facility.

       Fluorescent lights are one of the most energy efficient lighting sources available.
However, fluorescent lighting tubes contain mercury, which is used as an element to conduct the
flow of the electric current.  Historically, fluorescent lighting tubes were discarded into landfills.
When the tubes broke, mercury was released to the environment. This potential hazard caused
many states to classify fluorescent lighting tubes as hazardous waste and require that they be
managed in accordance with applicable hazardous waste laws and regulations.

       Recycling spent fluorescent lighting tubes offers an environmentally sound alternative to
expensive hazardous waste disposal.  Additionally, recycling may relieve the generator of future
liability concerns associated with tube disposal.  Several companies provide recycling services
for spent fluorescent lighting tubes and some of these companies also accept ballasts, a
component of the light fixture. Ballasts manufactured prior to 1980 contain polychlorinated
biphenyls (PCBs), which also present disposal problems. However, ballasts produced after 1980
do not contain PCBs.  According to Ron Newman of A-TEC Recycling, the useful life of ballasts
is approximately 15 years. Since ballasts manufactured after 1980 do not contain PCBs, ballasts
containing PCBs should not present significant disposal problems beyond the near term.

        Some states allow ballasts that do not contain PCBs to be disposed of in sanitary landfills.
However, according to Stephanie Small of DYNEX Environmental, Inc., non-PCB ballasts
contain diethylhexylphthalate (DEHP). Evidence indicates that DEHP is a human carcinogen.
Due to either the PCBs or DEHP content, Ms. Small recommends that customers manage all
ballasts as hazardous.
                                           22

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       USPS Memorandum for Managers, Operations Support dated December 16,1994 states
that "Under no circumstances should these lamps be mechanically crushed or ground into smellier
pieces. This method of disposal increases the exposure of hazardous materials to both employees
and the environment. Lamps should be boxed prior to disposal."

Pollution Prevention Opportunities

1.     Establish Fluorescent Tube Recycling Program

       Store expired bulbs hi boxes in a safe area.  USPS facilities should ship expired bulbs to
an approved facility for recycling of glass, metals, and mercury.

        Exhibit 3.7 provides information on the specific services offered by companies that
provide fluorescent tube recycling services, the cost of the services and the geographic area
serviced by each company.
                                          23

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3.7    RECHARGEABLE BATTERIES

Current Conditions

       The Dallas facility uses numerous alkaline batteries for various functions. The batteries
are used predominantly in flash lights utilized during machine repairs and maintenance activities.
The BMC uses numerous AA, C, D, and 9v batteries. The stock room maintains a barrel to
collect the batteries for recycling. The Dallas facility generates one 55-gallon drum of used
alkaline batteries every three months; these are recycled with other rnetals.

Pollution Prevention Opportunity

1.     Purchase Rechargeable Batteries         ,

       The Dallas BMC should purchase rechargeable batteries and a charging unit to recharge
the batteries. By using rechargeable batteries, the BMC would reduce the purchase cost of
batteries. Rechargeable batteries, however, do not provide power for as long as alkaline batteries
before recharging is necessary.

       GSA has Rayovac rechargeable alkaline batteries which are now available through
Muffin or FWW-19. Rayovac's patented Renewal batteries offer the high performance attributes
of regular alkaline batteries along with the cost and environmental benefits of a reusable system.
Renewal batteries are available in battery sizes AAA, AA, C, and D.  The power stations for
recharging batteries also are available from GS A. Stock numbers and prices are listed below.
For additional information, call Ms. Genni Brown 817-334-8377.

Rayovac Rechargeable batteries

SizeD       Model 713   6140-01-413-3925  !        Box (20 per box)     $32.80
SizeC       Model 714-2 6140-01-413-3923          Box (20 per box)     $32.80
SizeAA      Model 715-4 6140-01-413-3926          Box (40 per box)     $35.90
Size AAA     Model 724-4 6140-10-413-3928          Box (40 per box)     $35.90

Charger       Model PS2   6140-01-413-3929          Box (4 per box)      $90.08
(All Sizes)

3.8    AFFIRMATIVE PROCUREMENT

Current Conditions

       The BMC 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 BMC are unaware of USPS policy and federal legislation requiring the

                                          26

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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
practicable." In 1995, EPA published the Comprehensive Guideline for Procurement of Products
Containing Recovered Material (60 FR 21370, May 1,1995) providing requirements for
procurement of 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 the USPS
include printing and writing paper, re-refined oils, engine coolant, 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.

       The BMC was not able to document successful implementation of USEPA procurement
guidelines for products manufactured with recovered content. The BMC is, however, hi the
proceiss of eliminating products containing the seventeen chemicals on USEPA's 33/50 list.
Purchasing officials are not sure whether procurement specifications have been updated to
include recycled content hi 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 BMC should establish preference programs and adopt specifications for the purchase
of products made with the percentages of recovered materials specified hi USEPA 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 BMC
purchasing official 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 3.8
presents products for which EPA has established minimum recovered content levels.
                                          27

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EXHIBIT 3.8 EPA ESTABLISHED MINIMUM RECOVERED CONTENT LEVELS
Category/Product
Paper
High grade bleached printing and writing paper
Mimeo and duplicator paper
Computer paper
Envelopes
Percent Recycled Content

20%
20%
20%
20%
Tissue Products
Toilet tissue
Paper towels
Paper napkins
Facial tissue
Unbleached packaging
Corrugated boxes
20-100%
40-100%
30-100%
10-100%

25-50%
Vehicular Products
Lubricating Oil (re-refined oil) i
Tires
25%
retread tires
Construction Products
Fiberglass (glass culler)
Cellulose loose-fill and spray-on (post-consumer paper)
Structural fiberboards
Laminated paperboards - i
Cement and Concrete (coal fly ash)
Cement and Concrete (ground granulated blast furnace slag)
Poly ester 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)
50-100% ;
80-100%
100%
Park and Recreation Products
Playground surfaces (rubber or plastic)
Running tracks (rubber or plastic)
Landscaping Products
Paper-based hydraulic mulch (post-consumer 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
90-100%
90-100%

100%
100%

20-100%
25-100%
25-80%
25-50%
80%
10-100% I
                             28

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       EPA has developed lists of manufacturers and vendors of the items designated in the
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.

       TItie U.S. General Services Administration (GSA) publishes an Environmental Products Guide.
which lists items available through its Federal Supply Service. This guide, formerly the Recycled
Products Guide, has been prepared to assist Federal civilian and military agencies to identify 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 done, 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, TX 76115 or at (817) 334-5215.

       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. at (800)
267-0707

       The Defense General Supply Center hi Richmond, VA also distributes the Environmentally
Preferred Products Catalog which lists hundreds of environmentally preferable 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-preferable products, call or write:

       Defense General Supply Center
       Alttn. Marketing Office
       8000 Jefferson Davis Highway
       Richmond, VA 23297-5762
       1-800-848-4847

3.8    OVERSIGHT OF CHEMICAL STORAGE

Current Conditions

       Alii  shops and flammable materials cabinets in the BMC contained products with chemical
constituents listed on the EPA 33/50 list. The BMC staff has discontinued ordering materials with EPA
33/50 chemicals, found suitable replacements and is hi the process of depleting stocks. The BMC has
established a system in which all material purchases are reviewed for ODS and EPA 33/50 constituents
prior to purchase.  Over time the BMC staff believes that this system will eliminate the use of ODS and

                                             29

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EPA 33/50 chemicals. The maintenance shop has a solvent sink that uses an aqueous degreaser.
Flammable materials cabinets were filled with products, many apparently very old. One flammable
materials cabinet in the OTR repair shop had several inches of oil in the bottom.

Pollution Prevention Opportunities

1.     Evaluate the Contents of all Flammable Materials Cabinets

       The BMC staff should perform an inventory on all flammable materials cabinets in Order to
determine if materials are old, expired, or no longer needed by an operation. Old or expired chemicals
should be removed from the shops and disposed of properly.  Products no longer needed should be
inventoried and used as needed in other operations.

2.     Perform, periodic inspections of flammable materials cabinets

       The BMC staff should perform periodic inspections of flammable materials cabinets to determine
if contents are intact and that products brought hi from sources other than procurement are elirninated.
Periodic inspection and cleanout of cabinets will rninimize the risk of spills and interaction of
incompatible chemicals.

3.9    RAGS

Current Conditions

       The maintenance staff currently use rags to wipe up and clean up during maintenance operations.
These rags tend to be very oily.  The facility was using a rag service in the past but found that they were
continually purchasing new rags because the service could not clean the rags. All rags are now
purchased either locally or through GSA and disposed via incineration.  The BMC purchased 6,250
pounds of rags in 1994 for $2,375 and hi 1995 through April have purchased 3,750 pounds for $555.
The Facility expects to purchase approximately 6,900 pound of rags for an approximate cost of $1,000.
The facility generates three to four 55-gallon drums of rags per month which are incinerated for
approximately $400 per drum.

Pollution Prevention Opportunities

 1. Test another rag laundering service

        Several rag recyclers and linen services hi the Dallas/Fort Worth area were contacted; only one
 would launder oily rags.  National Uniform (a division of National Linen Service) (817) 429-5891 will
 pick up, launder and deliver rags from the Dallas BMC  at a cost of $1.50 per pound.  National stated that
 they will accept oily rags but not rags with chemicals, solvents, degreasers etc and that they would
 appreciate MSDS on oils used by the USPS.  An analysis of the costs show that laundering rags may be


                                               30

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cheaper than purchasing new rags. Laundering rags may save between $400 and $1,100 per year.,
Exhibit 3.9 presents a simple cost/benefit analysis of laundering rags.

            EXHIBIT 3.9  COST BENEFIT ANALYSIS OF LAUNDERING RAGS*
Cost/Activity
Initial Rag Purchase Cost
Laundering Cost
Disposal Costs
Year 1 cost
Cost Savings
Year 2 rag replacement cost
Year 2 cost
Cost Savings
Laundering
$1,030
$10,350 ($1.50 per pound)
$3,600 (25 percent of
$14,400)
$2. 17 per pound
$414
$258
$2.06 per pound
$1,173
New
$1,030
none
$14,400 based on three 55
gallon drums per month at
$400 per drum.
$2.23 per pound


$2.23 per pound

        Assumptions:
        1.    BMC uses 6,900 pound of rags per year.
        2.    Under reuse option BMC replaces 25 percent of the rags each year.
        3.    Disposal cost is $400 per drum and the BMC currently generates 3 drums per month.

3.10   BATTERY CHARGING
Current Conditions

       The BMC uses numerous battery powered forklifts for the movement of materials. For the main
facility the batteries are stored and charged in the battery room. Typically for each forklift there zire
three batteries; one in use, one charging and one ready for use. When needed, the batteries are filled
with water and recharged. The Assessment Team noted that there was an open drain in the battery room
that leads to the sanitary sewer. The battery room in the BMC is scheduled to be upgraded to increase
the space, lighting, ventilation and add lime neutralization tanks. Forklift batteries are charged at several
other BMC locations. For example, both the warehouse and the CPF facility had battery charging
occurring with no supervision, no spill containment, and no safety equipment.

Pollution Prevention Opportunity
1.
The drain in the battery room should be diked to prevent the accidental discharge of battery acid
to the sanitary sewer. There are devices commercially available to dike drains. Once spills are
contained, neutralize the battery acid with sodium bicarbonate (baking soda) and then wash the
                                             31

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       neutralized acid down the drain with water. Neutralizing the acid will reduce the likelihood of
       corrosion of pipes.

2.     Review procedures on the proper charging of batteries to prevent accidental acid overflows.

3.     Remove battery charging operations from remote facilities if possible or provide the appropriate
       safety and containment equipment for these sites.

3.11   DEDICATED OIL CONTAINERS

Current Conditions

       The Dallas BMC oil room has a bulk distribution system which stores several types of oil and a
solvent called Pro-Power, which is an oil emulsifier. This distribution system stores materials hi 55
gallon containers and has clear PVC tubes that connect to corresponding lockable, self closing faucets to
distribute the materials:  Several unmarked, open containers are stored under the bulk distribution
system. These containers are used to distribute and transport the materials for use.  After each use, staff
must empty the remaining oil into the waste oil drum and then clean the container with solvent for reuse.
This process generates unnecessary waste because excess oil is disposed, instead of being reused, and
because the containers must be cleaned with solvent after each use.

Pollution Prevention Opportunities
*rff.«fc,Turm_:r:.im_™__iii._T ----- IT-_   ~ r r     "~";

       The BMC should purchase and dedicate containers for specific materials. These containers
should have tight-sealing lids and be clearly marked with the type of material for which the container is
intended. There are many containers on the market that also have marks indicating the volume.  This
will ease distribution and help to reduce the amount of excess material dispensed from the bulk
distribution system. Also, by having closed, clearly marked containers, the excess materials can be left
in the container for reuse. This will eliminate the need to clean the containers with solvent after each
use, thereby reducing solvent use.
3.12   POLLUTION PREVENTION INFORMATION SOURCES

Current Conditions

       During the site visit, Dallas BMC staff indicated that they would like information on accessing
pollution prevention information:

Pollution Prevention Opportunities

       There are numerous sources of pollution prevention information nationwide.
                                              32

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There are several sources of pollution prevention information on the internet. Perhaps, the best source is
Enviro$en$e. This internet-based information source is funded by the Environmental Protection Agency
and the Strategic Environmental Research and Development Program. Enviro$en$e allows those
implementing pollution prevention programs or developing research and development projects to benefit
from the experience, progress, and knowledge of their peers. Enviro$en$e includes a pollution
prevention forum for all levels of government, researchers, industry, and public interest groups.
Enviro$en$e has been developed to host an expert architecture known as the Solvent Umbrella. The
Solvent Umbrella will allow users to access solvent alternative information through a single, easy-to-use
command structure. Enviro$en$e is also modem accessible via Bulletin Board System (BBS). Through
Netscape. Enviro$en$e address is:

       http://wastenot.inel.gov/envirosense.

       The EPA also has a World Wide Web (WWW) Server, which is being run as a prototype system,
to provide public access to EPA information. The EPA provides the comprehensive Access EPA
document describing environmental information, as well as a number of other pointers to Information
Locators that can be obtained from the EPA and related organizations. In addition to this document, the
EPA's Public Information Center is available to provide assistance in accessing  environmental
information. An experimental EPA People Locator is also available.  Through Netscape, EPA's WWW
server can be accessed through http://www.epa.gov.

       The EPA WWW server provides information on EPA Agency information and environmental
data, including:
       •      Press Releases, Calendar, Announcements, Speeches,
       •      EPA Offices and Regions,
       •      Consumer Information,
       •      EPA Initiatives, Policy and Strategy Documents,
       •      Rules, Regulations and Legislation,
             EPA Standards,
       •      Science, Research and Technology,
       •      Information about Grants, Contracts (RFPs), and Job Vacancies,
       •      Newsletters and Journals, and
       •      Software and Databases.

       See the appendices for additional information on pollution prevention information sources.
                                             33

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                                        SECTION 4.0
                        CONCLUSIONS AND RECOMMENDATIONS
       This Pollution Prevention Opportunity Assessment report documents the processes performed,
wastes generated and current waste management practices at the USPS Bulk Mail Center in Dallas, TX.
During the assessment process, the Assessment Team identified opportunities to reduce both the
quantity and toxicity of the wastes generated by this facility and recommended techniques for
implementation of those pollution prevention options.  The opportunities described hi the previous
sections constitute the recommendations of the Assessment Team.  Exhibit 3.1 presents a summairy of
the major recommendations.

       Dissemination of this report will encourage application of the pollution prevention opportunities
hi USPS bulk mail facilities nationwide as well as in other Federal facilities with similar operations.
                                              34

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APPENDICES
    35

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EPA 33/50 PROGRAM

The 33/50 Program, one of EPA's Partners for the Environment Program, began in the late 1980s as a
voluntary program to reduce toxic emissions of seventeen high priority chemicals reported on the Toxic
Release Inventory (TRI). These high priority chemicals, chosen because of their relative toxicities,
volumes of use, and potential for reduction through pollution prevention include:
   Benzene
   Cadmium and compounds
   Carbon tetrachloride
   Chloroform
   Cyanide compounds
Methyl ethyl ketone (MEK)
Methyl isobutyl ketone (MTBK)
Nickel and compounds
Tetrachloroethylene
Toluene
   Dichloromethane                               *•  1,1,1-trichloroethane
   Lead and compounds                           *•  Trichloroethylene
   Mercury and compounds                        *•  Xylenes
The 33/50 Program gets its name from the original goals to reduce the 17 priority chemicals by 33% by
1992 and by 50% by 1995. U.S. EPA celebrated the early achievement of the 50% reduction goal in
September 19969 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 hi
the 33/50 Program by submitting a letter to EPA stating then- intention to participate and outlining their
reduction targets and strategies. More than 1,300 parent companies operating about 6,000 facilities in
the U.S. have participated hi 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.uiel.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.
                                             36

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37

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OZONE DEPLETING SUBSTANCES

The ozone layer in the stratosphere protects life on earth from exposure to dangerous levels of ultraviolet
light. When CFCs and other ozone-degrading chemicals are released into the atmosphere, they will
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 hi the signing of the Montreal Protocol hi
1987. In the United States, Title VI of the Clean Air Amendments of 1990 addresses the phase out of
ozone-depleting substances.

There are two classes of ozone depleting substances. A Class I substance, 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 n 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, the 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. Information on the SNAP Program is
available through the Stratospheric Ozone Hotline at (800) 296-1996.

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 maximize the use of safe
alternatives to ozone-depleting substances, and to revise procurement practices to eliminate the
requirement for ozone-depleting substances.

The best source of technical, policy, and substitute chemical information is 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.
                                              38

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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.

The mailing address for the Office of Stratospheric Protection is:

Office of Stratospheric Protection
U.S. Environmental Protection Agency
Mail Code 6205J
401MSt,SW
Washington, DC 20460

Enviro$en$e also has access to several material substitution databases. Then- World Wide Web address
is:

http://es.iQel.gov
Select "Solvent Substitution Data Systems" for links to several material substitution databases including
those that specialize in solvents with ozone depleting ingredients.
                                              39

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EPA GREEN LIGHTS PROGRAM & THE FEDERAL ENERGY MANAGEMENT PROGRAM
(FEMP)

The Green Lights Program hi a voluntary pollution prevention program that encourages the use of
energy-efficient lighting.  It is one of the several ENERGY STAR® Programs sponsored by the U.S.
EPA's Atmospheric Pollution Prevention Division.    :

The purpose of the Green Lights Program is to encourage organizations to install energy-efficient
lighting to prevent the creation of air pollution including greenhouse gases, acid rain emissions, air
toxics, and tropospheric ozone, as well as prevent the generation of solid waste and minimize other
environmental impacts of electricity generation.

Green Lights partners agree to install energy efficient lighting where it is profitable as long as lighting
quality is maintained or unproved. Participants realize average rates of return on their initial investment
of 30 per cent or more. Most reduce thek lighting electricity bill by more than half while maintaining
and often improving lighting quality.                                                ,

Federal regulations and directives require Federal agencies to reduce energy use. Section 543 of the
National Energy Conservation Policy Act, as amended by the Energy Policy Act of 1992, requires each
agency to achieve a 10 percent reduction in energy consumption hi its Federal buildings by FY 1995,
when measured against a FY 1985 baseline on a Btu per gross-square-foot basis and a 20 percent
reduction in Btu per gross-square-foot by FY 2000.  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 Department of Energy's Federal Energy Management Program has teamed up with the EPA's Green
Lights Program to assist Federal agencies to achieve the mandated energy reductions.  A kick-off is
planned hi March 1997. The U.S. Postal Service is one of the first to sign up to this new collaborative
effort as a pilot agency.  For more information, contact Rob White, National Marketing  Director for
Green Lights and ENERGY STAR® Buildings, at (202) 233-9242.

EPA provides a range of Participant Support Programs to help Green Lights members obtain
information on energy-efficient lighting technology, financing options, software analysis tools, and
public recognition opportunities.
                                             40

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For more information about the Green Lights Program, contact:

Manager, Atmospheric Pollution Prevention Division
U.S. EPA
401 M Street SW(6202J)
Washington DC 20460
Tel: (202) 233-9190
Toll Free: (888) STAR-YES
Fax:(202)233-9569
Fax-back system: (202) 233-9659.

The Green Lights World Wide Web Home Page is at:

Green Lights Home Page
http://www.epa.gov/greenlights.html
This web site includes general information about the Green Lights program, manuals and publications,
software tools, and other technical information.

The Federal Energy Management Program Home Page is at:

Federal Energy Management Program Home Page
http://www.eren.doe.gov/femp/
This web site provides news, technical assistance, project financing information, and procurement
information to assist Federal agencies achieve the mandated energy use reductions.

U.S. Postal Service participates as a member of the Federal Interagency Energy Management Task
Force. Contact Mr. Bernie Denno, Environmental Programs Analyst, at (202) 268-6014 for specific
information on U.S. Postal Service involvement in FEMP and Green Lights Programs.
                                            41

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EPA ENERGY STAR® PROGRAM

The ENERGY STAR® Program is a voluntary pollution prevention program aimed at reducing energy
consumption to help to combat smog, acid rain, and climate change through decreased emissions from
electricity generation. It includes programs aimed at homes, residential HVAC, office products,
buildings, and lighting. Programs of interest to the U.S. Postal Service include:

* Office Products. The EPA ENERGY STAR® 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 STAR®  computers, monitors and printers.

>• Buildings. EPA's ENERGY STAR® Buildings program is a voluntary energy-efficiency program for
  U.S. commercial buildings. Partners can expect to reduce total building energy consumption by 30%
  on average.

For more information about the ENERGY STAR® Program, contact:

ENERGY STAR® Programs
U.S. EPA Atmospheric Pollution Prevention Division
401 M Street SW(6202J)
Washington DC 20460
POC: Ms. Jeanne Birskin, Chief, ENERGY STAR® Programs
Tel: (202) 233-9190
Toll Free: (888) STAR-YES
Fax: (202) 233-9569
Fax-back system: (202) 233-9659.

The ENERGY STAR®  World Wide Web Home Page is at:

ENERGY STAR® Home Page
http://www.epa.gov/energystar.html
This web page contains news and information on all of the ENERGY STAR® initiatives.

The Atmospheric Pollution Prevention Division also prepares a newsletter, The Update, which
communicates events, highlights,  and news affecting Green Lights and ENERGY STAR® program
participants. It is available on-line through the ENERGY STAR® Home Page.
                                          42

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FLUORESCENT TUBE AND BALLAST RECYCLING

Fluorescent tubes and lighting ballasts contain hazardous constituents that can make their handling and
disposal problematic. Fluorescent tubes contain mercury, which under Federal regulations, may be
subject to hazardous waste regulations if deemed hazardous by the Toxicity Characteristic Leaching
Procedure (TCLP) (40 CFR 261). Fluorescent lamp ballasts may contain polychlorinated biphenyls
(PCBs). Ballasts manufactured before 1979 will contain PCBs, while those manufactured after 1979
should contain a label staling "NO PCBs."  If there is no label, you should assume that it contains PCBs.
PCB-containing ballasts that are intact and are not leaking can be disposed in a municipal solid waiste
landfill in properly packed and sealed 55-gallon drums (40 CFR 761). Again, municipal disposal of
PCB-contaminated waste poses potential liabilities to the generator.

Individual, states may have other specific regulatory requirements governing the disposal of fluorescent
tubes. However, in most cases fluorescent tubes can be legally handled and disposed as municipal solid
waste, creating a potential liability to the waste generator. To minimize potential environmental
impacts, fluorescent tubes can be recycled.  The mercury containing material can be extracted, while the
remaining glass and metal parts can be recycled. This eliminates mercury going to the landfill, while
decreasing the volume of solid waste disposal through recycling.

Before disposing of fluorescent tubes or lighting ballasts, you should contact your state or local
regulatory agency for specific handling and disposal requirements. They may also have information on
fluorescent tube recycling in your state or area. Consult your local telephone directory for phone
numbers.

For information on Federal requirements, contact the following:

Resource Conservation Recovery Act (RCRA/Superfund/Right-to-Know Hotline
Phone: (800) 424-9346 or (703) 412-9810 in the Washington DC area.
Request documents such as EPA Fact Sheet: Options for Disposal of Lights that Contain Mercury and
Lighting Waste Disposal, a general document published by the EPA's Green Lights Program on best
management practices that includes recycling. Memorandums on the subject are also available through
the fax-on-demand system. Dial  (202) 651-2060 from the fax phone receiver, press 1 to order
documents, press 11906 and 11907 (press 1 to confirm ordering each document), press # to finish
ordering, then press start on your fax machine.

Toxic Substances Control Act (TSCA) Assistance Information Hotline
Phone: (202) 554-1404
Request regulatory guidance on the management and disposal of ballasts that contain PCBs.
                                             43

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Several fact sheets are available over the World Wide Web that contain background information as well
as lists of fluorescent tube and lighting ballast recyclers:

U.S. Air Force Center for Environmental Excellence, PRO-ACT
hl^://wvvw.afcee.brooks.af.mil/pro-act/mam/proact4.htm
Select "Fact Sheets" from Home Page menu. Information hi the PRO-ACT web site is public domain.
However, telephone inquiries and requests for research or information are only available to Air Force
users.

Enviro$en$e
http://es.inel.gov/techuifo/facts/lamps-fs.html
Fact sheet on disposal of spent fluorescent light tubes, developed by the Department of Public Works,
City of Los Angeles.  Contains a list of additional resources.
                                              44

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POLLUTION PREVENTION INFORMATION SOURCES
Pollution prevention information sources are widespread. There are Federal-, state-, regional, and even
local sources of pollution prevention information. At the Federal level, the U.S. EPA Office of Pollution
Prevention and Toxics (OPPT) distributes a variety of pollution prevention information and oversees
several pollution prevention initiatives. They publish the Pollution Prevention News, available in hard
copy or through the U.S. EPA Pollution Prevention Home Page (see below for URL). OPPT also
operates the Pollution Prevention Information Clearinghouse (PPIC).  It is a free, non-regulatory service
which provides telephone reference and referral, document distribution for selected EPA documents, and
a special collection available for interlibrary loan. Publications available from PPIC are listed on the
U.S. EPA Pollution Prevention Home Page (see below for URL).

Pollution Prevention Information Clearinghouse (PPIC)
Phone:       202-260-1023 (8:30 AM to 4:00 PMEST)
Fax:         202-260-4659
E-Mail:      ppic@epamail.epa.gov
Mail:         Pollution Prevention Information Clearinghouse
             Environmental Protection Agency, MC 7409
             401 M Street, SW
             Washington, D.C. 20460
EPA Comtact: Beth Anderson 202-260-2602
When calling PPIC for the first time, request a listing of all available documents. A more useful
document for the first time user is the Pollution Prevention Directory (EPA/742/B-94/005) which
identifies Federal, state, regional, and commercially-available pollution prevention resources.

Some of the more popular World Wide Web starting points for Federal, state, and regional pollution
prevention information include the following:

U.S. EPA Pollution Prevention Home Page
http://www.epa.gov/opptmtr/p2home/
This web site provides general information on pollution prevention, pollution prevention initiatives, and
links to olher pollution prevention-related web sites.

Enviro$eri$e
http://es.inel.gov/
Enviro$en$e is a "one-stop" repository for pollution prevention, compliance assurance, and enforcement
information and data bases. Included are pollution prevention case studies, technologies, points of
contact, environmental statutes, executive orders, regulations, and compliance and enforcement policies
and guidelines, Enviro$en$e has numerous links to other Federal, regional, state, industry and academic
pollution prevention resources. Enviro$en$e is an excellent "jumping off' point for additional pollution
prevention information available on-line.
                                            45

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Defense Environmental Network & Information Exchange (DENIX)
http://denix.cecer.army.mil/denix/public/public.html
DENIX is a source of information for the Department of Defense agencies and other authorized users.  It
has a public access menu which allows users from the public domain to obtain a variety of
environmental information. Under the "Public" web cage, select "Library" then "Pollution Prevention"
for numerous pollution prevention articles and information.
                                             46

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                                              EPA/600/R-96/111
                                              September 1995
        POLLUTION PREVENTION ASSESSMENT:
                 U.S. POSTAL SERVICE
           BULK MAIL CENTER, DALLAS, TX
                          by
          Carole O. Bell, Mary Hoel, Henry Huppert
         Science; Applications International Corporation
               Newport, Rhode Island 02840
               EPA Contract No. 68-C2-0148
           SAIC Project No. 01-0828-07-1717-060
                    Project Officers

                    James S. Bridges
                         and
                  N. Theresa Hoagland
              Sustainable Technology Division
        National Risk Management Research Laboratory
                 Cincinnati, Ohio 45268
       This study was conducted hi cooperation with the
               United States Postal Service
NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
       OFFICE OF RESEARCH AND DEVELOPMENT
      U.S. ENVIRONMENTAL PROTECTION AGENCY
               CINCINNATI, OHIO 45268               ',

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                                   DISCLAIMER
The information in this document has been funded wholly or in part by the United States
Environmental Protection Agency under EPA contract No. 68-C2-0148 WA 3-10 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.

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                                     CONTACT
James Bridges and N. Theresa Hoagland are the EPA contacts for this report.  They are
presently with the newly organized National Risk Management Research Laboratory's
Sustainable Technology Division in Cincinnati, OH (formerly the Risk Reduction Engineering
Laboratory).  The National Risk Management Research Laboratory is headquartered in
Cincinnati, OH, and is now responsible for research conducted by the Sustainable Technology
Division in Cincinnati.
                                         11

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                                     FOREWORD
The U.S. Environmental Protection Agency is charged by Congress with protecting the
Nation's land, air, and water resources.  Under a mandate of national environmental laws, the
Agency strives to formulate and implement actiojns 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 hi 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
                                          in

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                                    ABSTRACT
The United States Postal Service (USPS) in cooperation with EPA's National Risk
Management Research Laboratory (NRMRL) is engaged in an effort to integrate waste
prevention and recycling activities into the waste management programs at Postal facilities.
This report describes the findings of the Pollution Prevention Opportunity Assessment of the
United States Postal Service, Bulk Mail Center located in Dallas, Texas. This assessment was
conducted during the week of May 15, 1995.

The report describes the mission of each of the functional areas of the BMC including
operations performed, processes and materials employed and the wastes and emissions
generated.  Then, the Assessment Team makes recommendations concerning the procurement
of office supplies, maintenance supplies and hazardous materials; management of hazardous
materials and wastes; purchase of chemicals on USEPA's  33/50 list; 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.
                                         IV

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                          TABLE OF CONTENTS
DISCLAIMER	...'........	 . .	. .'.	.   i

CONTACT	  ii

FOREWORD	HI

ABSTRACT	  iv

EXHIBITS	 . . .;		. . . _	vii

ACKNOWLEDGEMENTS		'...................	 . . .  viii

1.0    INTRODUCTION	 . .'.	            l
      1.1   SITE DESCRIPTION	.	 -	'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.  2

2.0    BULK MAIL CENTER 	.		               4
      2.1   BULK MAIL CENTER . .	j.	'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.  4
           2.1.1  Physical Description of Facility	             4
           2.1.2  Mail Handling	 ...............  5
      2.2   BMC WASTE GENERATING OPERATIONS	'.'.'.'.'.'.".'.'.'.'.'.'.'.  6
           2.2.1  Solid Waste Management	         g
           2.2.2  Sorting Floor	...'..'.'.'.'.'.'.'..'.'.'.'.'.'.'.'.'.  6
           2.2.3  Lube Room	.....................;...,....  7
           2.2.4  Tow Lines	          7
           2.2.5  Cafeteria	'.'.'.'.'.'.'.'.'.'.  7
           2.2.6  OTR Repair. Vehicle Fueling/Maintenance 	„ .  g
           2.2.7  Purchasing and Stock Room 	  g
           2.2.8  Maintenance Shops  . . . ;	  	    g
           2.2.9  Battery Charging Room	        9
           2.2.10 Administrative Offices	      9
           2.2.11 Facility Perimeter  		'.'.'.'.'.['.'.'.'.'.  9
           2.2.12 Crossdock Pallet Facility ;	  10
           2.2.13 Warehouse	. .        10
      2.3   ADDITIONAL WASTE STREAMS	'.'.'.'.'.'.'.'.'.'.'.  10
           2.3.1  Hazardous Waste  ....;..;......	          10
           2.3.2  Used Oil	;	'.'.'.'.'.'.'.'.'.'.'.'.  11
           2.3.3  Pest Control	  11
           2.3.4  Lighting	;	'.'.'.'.'.'.'.'.'.'.'.  11

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 3.0
  f^KAMlL FACTTT^   f**^



  j
  3.6
isSSSgp
         	
 D * SPA 33/50 CHEjur

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     /
f
£
                                                            3
                                                           12
                                                            15
                                                            17
                                                            19
                                                            20
                                                             21
                                                             26
                                                             30
                                                             33
                                 vu

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 3.0  BULK MAIL FACILITY POLLUTION PREVENTION OPPORTUNITIES      12
     3.1   ENVIRONMENTAL OVERSIGHT                            n
     3.2   REDUCE PAPER USE	      	  fl,
     3.3   REUSE AND RECYCLING ...    	'W '	  \A
     3.4   PALLETS	      '	"     ' •	  }j
     3.5   LIGHTING AND ENERGY ....    	• " "'	" ' "  j!
     3.6   FLUORESCENT LIGHTING	          '	"  ^
     3.7   RECHARGEABLE BATTERIES	     "     	•••..••••  ^
     3,,8   AFFIRMATIVE PROCUREMENT .	   ••••••	       M>
     3,,8   OVERSIGHT OF CHEMICAL STORAGE	' '	  v,
     3.9   RAGS...................       •••.......	  ^
     3.10  BATTERY CHARGING .......       •••••.	  ^
     3.11  DEDICATED OIL CONTAINERS ........'"'"""""'"'	34
     3.12  POLLUTION PREVENTION INFORMATION SOURCES  ! . . . ','. '  \ ' '  35

4.0   CONCLUSIONS AND RECOMMENDATIONS	             37

APPENDICES

     A,,    EPA 33/50 CHEMICALS AND OZONE DEPLETING CHEMICALS      38
     B.    GREEN LIGHTS INFORMATION AND .SAMPLE MEMORANDUM OF
          UNDERSTANDING (MOU) FOR GREEN LIGHTS PARTNERS        40
     C.    ENERGY STAR EQUIPMENT INFORMATION            	   ss
     D.    FLUORESCENT TUBE RECYCLERS . .     " "	"	   >n
     E.    POLLUTION PREVENTION INFORMATION SOURCES' .' '. '. '.'. '.'.'.'.'.   77
                              VI

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                            EXHIBITS
   MAP OF BMC		.	.		 . .  3
   BMC SOLID WASTE GENERATION		  12
   COST/BENEFIT ANALYSIS FOR OTRS VERSUS GAYLORD USE 	  15
   RECYCLERS IN THE DALLAS/FORT WORTH AREA	  17
   EXAMPLES OF PALLET RECYCLERS IN THE DALLAS AREA	  19
   FEDERAL ENERGY POLICIES	,	  20
3.6 SQUARE FEET OF COVERAGE PER DAYLIGHTING UNIT	  21
3.7 FLUORESCENT LIGHTING TUBE RECYCLERS	  26
3.8 EPA ESTABLISHED MINIMUM RECOVERED CONTENT LEVELS 	  30
3.9 COST BENEFIT ANALYSIS OF LAUNDERING RAGS	..............  33
1.1
3.1
3.2
3.3
3.4
3.5
                               vu

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                             ACKNOWLEDGEMENTS
Funding for this project was provided by the United State Postal Service under an interagency
agreement.  Jim Bridges and Tern 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 Dallas Bulk Mail Center.
                                        Vlll

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                                     SECTION 1.0

                                   INTRODUCTION


       The United States Environmental Protection Agency (EPA) is actively supporting the
 development of pollution prevention program plans for Federal facilities. Since 1988, the
 EPA has managed a technical support effort known as the Waste Reduction Evaluations at
 Federal Sites (WREAFS) Program.  WREAFS was established to provide pollution prevention
 solutions to environmental issues through research, development and demonstration of
 pollution prevention techniques and technologies, and transferring lessons learned within the
 Federal community and related private sector support industries.  WREAFS has conducted
 more than 37 separate RD&D efforts under funding from both EPA and nine other Federal
 departments and agencies via interagency agreements.

       The United States Postal Service (USPS), in cooperation with EPA's National Risk
 Management Research Laboratory (NRMRL), is engaged in an effort to integrate pollution
 prevention and recycling activities into the  waste management programs at postal facilities.
 The purpose of this project is to perform pollution prevention opportunity assessments
 (PPOAs) at several types of Postal Service  facilities, representing a cross-section of the USPS
 inventory; to identify the pollution prevention opportunities for these 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
 Service Bulk Mail Center (BMC) located in Dallas, Texas. The site assessment was
 conducted during the week of May 15, 1995.

       The Assessment Team performed a multi-media assessment.  Issues of concern
 included: hazardous material  acquisition,  use and storage; hazardous waste storage and
 disposal;; procurement and solid waste management, including recycling.  The report begins
 with a brief description of the facility. This is followed by descriptions of specific operations
 and the wastes and emissions generated.  The report makes both site-wide and operation-
 specific recommendations that may lead to the elimination, reduction, or improved
 management of the facility's waste streams.  While energy was not part of the multi-media
 assessment, the Assessment Team makes  energy-related recommendations where appropriate.
Mention of trade names, commercial products, or vendors does not constitute endorsement or
recommendation for use.

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1.1    SITE DESCRIPTION

       The BMC is located in Dallas, Texas, at 2400 Dallas-Fort Worth Turnpike.  The
facility occupies 75 acres along the 1-35 corridor;west of downtown Dallas. The surrounding
area is devoted to mixed commercial/industrial and residential uses. The site is bordered on
the north by Route 35 and an industrial park, on the south by a residential area, on the east by
Hampton Road and a commercial area and on the west by an additional commercial area.
The USPS operations include one major building and several smaller buildings that house
maintenance, groundskeeping and traffic control operations.  Exhibit 1.1  presents the layout of
the Dallas BMC.

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fe
©

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                                     SECTION 2.0

                            BULK MAIL CENTER (BMC)
       This section addresses the operations performed within the BMC and associated
facilities and the wastes and emissions generated by those operations.  The section includes a
description of current waste management practices.

2=1    BULK MAIL CENTER

       The national bulk mail system is a network of mechanized bulk mail centers that
process 3rd and 4th class mail.  The USPS operates two large BMCs,  five medium BMCs and
14 small BMCs.  Classification is based on facility size, rather than mail throughput. The
Dallas BMC with approximately 450,000 square feet is considered a medium-sized BMC and
processes between 500,000 and 800,000 parcels per day.

       The BMC facility in Dallas, TX performs the sorting and routing of packages and bulk
business mail for Texas, Oklahoma and parts of Kansas, Arkansas, and Louisiana.  In
addition, mail is routed to the twenty other regional BMCs.  The facility employs
approximately 1,600 individuals, of which approximately 150 are supervisors arid clerical
workers. The facility operates three eight-hour shifts per day, six days per week and two
shifts on Sunday.  An additional 300 workers are hired during the Christmas holiday season.

2.1.1   Physical Description of Facility

       The BMC facility occupies 75 acres.  The main building contains approximately
452,000 square feet of space which houses administration, workroom floor, facility electrical
utilities, air handlers and air chillers.  The space is divided as follows:

Penthouse (air chillers, air handlers, electrical service)     30,064 sq. ft.
3rd Floor (Administrative/Conference Rooms)            16,128 sq. ft.
2nd floor (Administrative)                              16,128 sq. ft.
1st floor (Administrative)                               16,128 sq. ft.
Workroom floor                                      374,000 sq.  ft.

       In addition, the facility houses a 2,000 sq. ft. lubrication storage area (lube room) that
contains supplies of petroleum products used hi the BMC, a used oil storage tank, a staging
area for cardboard recycling and a staging area for oil, rags, and filter disposal.

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       At the east end of the site is a 2,048 sq. ft. former vehicle repair shop that is now used
 to repair aluminum mail transport equipment known as over the road containers (OTRs). This
 shop also serves as a fuel and oil dispensing area for postal vehicles.  On the west end of the
 site is a 1,000 sq. ft "tin shed" that houses groundskeeping equipment and miscellaneous
 machinery.

       The BMC also has two remote sites: a USPS-owned warehouse at 1982 Fort Worth
 Ave. which is shared with the Dallas General Mail Facility (GMF), and a leased facility of
 59,000 sq. ft. located at 3706 La Reunion Parkway that houses the Crossdock Pallet Facility
 (CPF).                                      !

 2.1.2  Mail Handling

       Mail enters the main facility via trucks through loading docks on one of 42 inbound
 docks, on the east and west side of the facility.  Mail is processed and sorted and leaves the
 facility via 78 outbound docks on the south of the building. Mail is handled through the
 facility according to its physical characteristics and destination.  Mail comes in four basic
 forms: sacks, parcels, nonmachinable outsides (i.e., those pieces that can not be machine
 sorted), and bulk business mail.

       Sacks enter from the inbound docks on ejctendible conveyors.  The conveyor transports
 the sacks to slides which feed keying stations.  The keyer locates the sack label, positions the
 sack in a cradle and keys in the zip code on the label.  The cradle tips the sack onto a moving
 tray sorter that travels at 70 trays per minute.  Sacks placed on a tray travel to the destination
 chute where the tray tips and the sack slides into the chute.  The chute leads to an extendable
 conveyor on the outbound docks where the  sacks are bedloaded (stacked on the bed of the
 vehicle rather than containerized) onto the outgoing trucks.

       Parcels arrive at the facility in mail transport equipment (heavy-duty aluminum OTRs,
 cardboard gaylords, or wire cages), sacks or bedloaded individually.  Containers are rolled off
 the trucks at the inbound docks and placed onto the Fixed Mechanization Automated
 Container System (FMACS or tow line)  and brought to the container unloaders. The unloader
dumps the parcels on to a conveyor which moves them to the parcel keying stations on'the
primary sorters.  Parcels hi sacks are sent through the sack  sorter (see above) and then sorted
to the sack snakeout operation where the sacks are opened and the parcels removed and
placed on conveyors leading to the primary parcel sorter. Bedloaded parcels are unloaded
directly onto conveyors which bring them to the keying stations on the parcel sorters.  Once
sorted, packages slide onto  a tray sorter that dumps them to chutes according to destination.
Parcels are loaded into OTRs, wire cages or gaylords, depending on destination, and moved
onto outgoing trucks.

       Bulk business mail enters the BMC on pallets and in mailer-prepared sacks which are
distributed by the sack system  to the east wing annex.  Sacks are opened and dumped onto a
belt where individual bundles are sorted  to mail transport equipment and sacks.

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2.2    BMC WASTE GENERATING OPERATIONS
                                      K;     •    -ST7  •                    :
       Wastes generated by BMC operations include excess and obsolete equipment and
supplies; corrugated cardboard; computer paper; white paper; mixed office paper, including
forms and envelopes; magazines and newsprint; employee wastes including cans, bottles,
wrappers and food; pallets; shrink and stretch wrap; aluminum and other metals; wood;
fluorescent tubes and lighting ballasts; batteries; plastic and metal strapping; rags; and oil
filters and waste oil.

2.2.1   Solid Waste Management

       The main building at the BMC has a 40 cubic yard compactor provided by Southwest
Paper Stock. Prior to the segregation of cardboard gaylords for recycling, the compactor was
pulled 30 times per month. Currently, the compactor is pulled approximately 12 times per
month.  The BMC is charged $147.50 per pull which includes compactor rental.  The waste
collected by Southwest Paper is sent to a materials recovery facility for separation prior to
disposal in a landfill.  The BMC recycles aluminum and other metals, cardboard gaylords,
high grade white office paper, and some scrap wood.  In addition, there is a sb? cubic yard
container at the Crossdock Pallet Facility (CPF) that is pulled 26 times per month for a  cosit
of $3,774 per year. There is no recycling occurring at the CPF.  The BMC spends
approximately $27,000 per year on waste disposal.

2.2.2   Sorting Floor

       As noted above, all bulk mail entering the facility is sorted and routed on the sorting
floor.  The sorting floor generates large amounts of cardboard, metal from equipment repair,
oils, grease, and paper. Cardboard gaylords used for the movement of packages are the
largest single source of old corrugated cardboard (OCC). After packages that enter the
facility in gaylords are dumped for sorting, the gaylords are broken down and placed in an
OTR.  The OTR is attached to the tow line and sent to the lube room where the gaylords  aire
processed for recycling. Staff stated that the lack of storage space and the inability of staff to
segregate reusable from damaged gaylords prevents the wide reuse of gaylords.  Reuse of
gaylords is limited to times when no new gaylords are available.  The BMC currently recycles
only cardboard gaylords; other OCC is put into the compactor.

       Weyerhauser places a trailer at the dock in the lube room. The gaylords are placed on
pallets in the lube room.  Strapping, shrinkwrap and other contaminants are removed, and the
OCC is placed in the trailer.  The BMC staff believe that they recycle approximately 70 to 80
percent of the OCC.  The BMC plans to consolidate the recycling hi a separate area, purchase
a horizontal auto-tie baler and become the USPS regional collection point for OCC recycling.
The BMC recycles approximately 60 tons of gaylords per month and receives $140 per  ton,
representing revenue of approximately $8,400 per month.
                                         '  6

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       The sorting floor also generates significant quantities of undeliverable bulk business
 mail (UBBM) and loose-in-mails (LIMs), the USPS tenn for loose or damaged bulk mail.
 UBBM is currently discarded into the compactor.  There are nine LIMs chutes that generate
 approximately five to six wire cages of LIMs per day. The LIMs are sorted to verify that no
 deliverable mail is present and the remains are discarded into the compactor.

       The Rewrap Section processes mail that has been damaged or is otherwise
 undeliverable.  Broken, leaking or questionable packages are sent to the Rewrap Section
 where they are opened, examined and, if possible, repackaged using new cardboard boxes and
 returned to the mail processing system.  This section generates a substantial amount of mixed
 paper and corrugated cardboard that is currently!discarded into the compactor.

 2.2.3  Lube Room                          }

       The lube room is located in the southeast corner of the main building and contains an
 oil storage rack, a used oil storage tank, a parts washer, a tow line grease storage container
 and two  flammable materials cabinets.  The flammable materials cabinets were completely
 filled with paints, oils, cleaners, and degreasers. Several products contained ozone depleting
 substances (ODCs) and constituents included on the EPA 33/50 list of chemicals targeted for
 reduction.  Appendix A provides a list of ODCs and EPA  33/50 chemicals.  The lube room
 had an open drain that leads to the sanitary sewer. The lube room also serves as the staging
 area for loading of cardboard for recycling.

 2.2.4  Tow Lines

       During routine maintenance, the tow lines  are cleaned out quarterly, generating a thick
 heavy grease.  The BMC generates approximately four 55-gallon drums of tow line sludge per
 quarter.  The sludge is placed in a closed basin in the lube room.  The sludge is then
 biotreated using microbes to reduce the viscosity of the grease so it is pumpable.  Following
 treatment the grease is filtered and pumped to the used oil tank in the lube room.  See Section
 2.3.2 for a discussion of used oil management.

 2.2.5  Cafeteria                             j

       The cafeteria/lunch room serves food via vending machines.  Wastes from the cafeteria
include wastes disposed by employees such as paper and plastic bags, aluminum foil and other
containers, such as yogurt or soup, brought in from home.  Food waste is mixed with these
materials. Beverages are sold in aluminum cans and glass  and plastic bottles.  An aluminum
can collection box was present hi the cafeteria.  Deliveries of food products generate
corrugated boxes and packaging which are sent to the  compactor.

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 2.2.6  OTR Repair. Vehicle Fueling/Maintenance
                                    1 '.*:••     %   „                 -
       The BMC has a 2,000 sq. ft. repair facility that consists of two buildings at the east
 end of the site.  One building is used for the mechanical repair of OTRs, wire cages and other
 equipment. This building houses welding equipment as well as other machine shop
 equipment. Repairs performed include structural repairs as. well as replacement of tow pins,
 wheels., or other parts.  The shop is typically staffed with five to  six employees. The OTR.'
 shop repairs between 10 and 18 OTRs per person per day. The repair area had at least 300
 OTRs and wire cages stockpiled awaiting repair. Numerous additional pieces of mail
 transport equipment requiring repair arrive each day from all parts of the country.

       The second building is a maintenance shop for painting and prep of OTRs and other
 maintenance.  This  building is adjacent to the fueling area so no "hot" work occurs in this
 building.  In addition, this facility readies new OTRs for use by painting on the marking area
 and adding a Dallas identification number.

       Each building has a flammable materials cabinet that contains numerous containers of
 paints, oils, and degreasers.  Several partially used containers of insecticide were also found hi
 the two buildings. Adjacent to the fueling area is a flammable materials cabinet that contains
 drums of motor oil  for vehicles. An inspection of the flammable materials cabinet in the
 OTR repair shop revealed the bottom filled with several inches of oil.

 2.2.7  Purchasing and Stock Room

       The stock room at the BMC stores parts and materials used by the BMC staff and is
 the central ordering area for equipment.  All parts and supplies are ordered through the stock
 room.  The stock room staff uses a computerized ordering system to acquire materials from
 GSA or the Materials Distribution Center hi Topeka, KS. The staff also orders from local
 suppliers.  Approximately 25 people have access to the stock room.  Nine individuals have the
 authority to order parts and materials.  These orders are approved by one of three maintenance
 supervisors, the maintenance manager and the purchasing officer.  Parts requests from staff
 are entered via a computer terminal on a shelf outside of the stock room. The stock  room
 staff retrieves the part if it is in stock or orders the  part if necessary.

2.2.8  Maintenance Shops

       The maintenance department performs repairs on sorting equipment  as well as building
maintenance and upkeep. The maintenance shop contains two degreasers that use "Powersolv"
solvent, an aqueous-based cleaner degreaser.  Rags used by the maintenance staff tend to be
very oily and the staff has found that they cannot be cleaned and reused. The facility was
using a rag service,  but found that they were continually  purchasing new rags because the
service could not clean the rags. All rags are now purchased either locally  or through GSA
and disposed via incineration.  The BMC purchased 6,250 pounds of rags in 1994 for $2,375
and in  1995 through April have purchased 3,750 pounds for $555. The facility generates'

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three to four 55-gallon drums of rags per month which are incinerated for approximately $400
per drum ($1200 to $1600 per month).          !

       All flammable materials storage cabinets contained products with chemical constituents
listed on the EPA 33/50 list  The BMC staff has discontinued ordering products containing
these chemicals, found suitable replacements and is in the process of depleting stocks.

2.2.9   Battery Charging Room                •

       The battery room, located on the main floor of the BMC, is used for recharging and
storage of batteries used in BMC vehicles, approximately 37 forklifts and 20 jitneys.  Each
vehicle has three batteries: one in use, one charged and ready, and one charging. The facility
estimates there are 150 batteries on-site. The room has an open floor  drain with no diking to
prevent spills from entering the sanitary sewer.  The BMC is presently in the process of
upgrading the battery charging room to increase storage capacity, install better ventilation and
lighting and provide a limestone tank for the neutralization of any acids released hi the battery
room.  In 1994, the BMC recycled 30 batteries to Exide Corporation, a battery manufacturer.

2.2.10 Administrative Offices                 i

       The BMC contains three floors occupied by offices and conference rooms
(approximately 48,000 sq. ft).  The significant wastes include computer printouts, white
paper, mixed office paper, toner cartridges and employee wastes.  The BMC has initiated, a
white paper recycling program. While some employees were participating in the recycling
program, most were not, as evidenced by white paper hi nearly all trash containers.  Lighting
hi all offices, conference rooms and restrooms is motion sensitive.  The BMC plans to install
new carpeting manufactured from recycled polyethylene.

2.2.11 Facility  Perimeter

       During a walk around the facility perimeter, the Assessment Team noted the presence
of a "tin shed", several roll-off containers and several miscellaneous material storage areas.
The tin shed houses groundskeeping equipment and a variety of excess equipment and
materials including tires and other parts. Near the tin shed is a 30 cubic yard container
dedicated to the collection of wood wastes. According to the BMC staff, this container is
pulled for recycling by Southwest Paper on an "on-call" basis. The contents of the contaiiner
were contaminated with plastic and cardboard boxes. There is also a 30 cubic yard container
for metals recycling.  The BMC generates 10 to 12 tons of scrap metal per month. The
container is typically pulled twice per month by Atlas Scrap and the USPS receives
approximately $70 per ton, generating revenue of approximately $800 per month. The facility
also generates 15 to 20 tires per year.  These tires are either removed  by the tire company
performing  the replacement or are  sent to the VMF hi Dallas for management.  Scrap
equipment piles were located all around the west and northwest perimeter awaiting use or
disposition.  Bulk aluminum is typically sold at auction in 20,000 pound lots; however, in


                                           9

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 fiscal year 1995 there has been one sale of approximately 97,000 pounds of aluminum for
 wWch the USPS received approximately $7,929.

 2.2.12 Crossdock Pallet Facility

       The Crossdock Pallet Facility (CPF) is a 59,000 sq. ft. leased facility located at 3706
 La Reunion Parkway in an industrial park approximately one mile from the BMC.  The CPF
 redistributes palletized materials from bulk mailers. Palletized materials arrive on trucks from
 bulk mailers.  The CPF personnel unload the trucks and determine if the materials on each
 pallet are already sorted by BMC or are mixed.  Those pallets that are correctly separated for
 other BMCs are put directly onto trucks. Pallets that contain mixed loads are broken down,
 sorted, re-palletized, shrinkwrapped and put on the correct truck for shipment.  If the pallets
 are for the Dallas  region, the packages are sent to the BMC for sorting and routing.

       The CPF is also the accumulation point for all sacks for the Dallas BMC region.
 Sacks arrive from all over the Dallas region loose, bagged, or in OTRs and wire cages.  The
 sacks are sorted by type, checked for mail, removed from service if damaged, repackaged, and
 sent to the annex.  Sacks are shipped to local Post Offices or bulk mailers, as required.
                                                                          t
       All waste generated at the CPF is disposed in a six cubic-yard container that is
 emptied  daily for a cost of $3,774 per year.  No recycling is performed at this facility.
 Wastes generated include pallets, shrinkwrap, cardboard, damaged sacks, and strapping.
 USPS plastic and pressboard pallets are shipped to the Arlington TX pallet distribution center.
 Wood pallets are disposed. The facility also has a fork truck battery charging operation with
 no safety or spill prevention equipment present.

 2.2.13 Warehouse

       The warehouse, located at 1982 Fort Worth Ave.,  is a facility shared by 'the BMC and
 the GMF.  The facility is approximately one mile from the BMC.  The BMC uses this space
 primarily for the storage of cardboard gaylords for use in the BMC and some excess
 equipment.  It was unclear which material belonged to the BMC and which to the GMF.  The
 warehouse also had a fork lift battery charging station in operation with no safety or spill
 prevention equipment present. One area in the facility is  used for records storage. There is;
 no trash  service at this facility.  All wastes generated here are discarded of at the BMC or
 GMF facilities.

2.3    ADDITIONAL WASTE STREAMS

2.3.1   Hazardous Waste                                                •   ]

       ITie BMC does not generate  large amounts of hazardous waste on a regular basis. The
BMC has begun to take all aerosol cans to a central depository.  The aerosol cans are
punctured and drained into one of two drums.  One drum is designated for paints, the other


                                           10

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 for oils.  Once emptied, the cans are recycled with the metal scrap.  The BMC has not yet
 generated a full drum for disposal.

       The BMC generated one 55 gallon drum of hazardous waste in 1994, which was waste
 paint classified F003 and F005.

 2.3.2  Used Oil                             \

       Used oil from sorting machines and motors is typically filtered and reused on the tow
 line.  The BMC uses a portable filtering unit that can  be used for motor oils and cooling oils.
 After final use the oils are sent to the used oil collection tank.  Used oil is collected by
 Worldwide Reclamation who sends it to CSC Disposal for rerefining.  In 1994, the BMC
 generated approximately 11,500 pounds (1,500 gallons) of waste oil.  The facility generates
 10 to 20 oil filters per year from the compressors and other equipment. The oil filters are
 collected by Worldwide Reclamation and sent off-site  for incineration.

 2.3.3  Pest Control

       The facility has discontinued the application of pesticides by its employees and
 contracts  all, pest control to licensed applicators. ;The staff has attempted on more than one
 occasion to remove all aerosol pesticides from the facility, but several containers were found
 during the assessment

 2.3.4  Lighting

       The BMC primary lighting is provided by fluorescent fixtures.  The facility  is in the
process of changing  over to halogen lighting; however, capital improvements funding for the
lighting systems were recently denied  by the regional environmental office.  The BMC staff
stated that it is their  goal to eliminate  all fluorescent lights from the facility because of the
environmental impacts of the disposal of fluorescent tubes.  The BMC discards 21 fluorescent
tubes per day, five days per week into the compactor.  The staff collects lighting ballasts and
batteries for recycling. The staff is currently investigating the use of new sulfur-based
lighting systems under development by Fusion Lighting and the  Department of Energy.
Motion sensitive lights were in use in  the office spaces, but nowhere else.
                                           11

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                                          SECTION 3=0
         BULK MAIL FACILITY POLLUTION PREVENTION OPPORTUNITIES
 the BuIr                    Prev^on opportunities specific to the operations of
 the BulJc Mail Facility.  Exhibit 3.1 presents a summary of the BMC waste generation, current
 management and potential pollution prevention opportunities                generation, current
                    EXHIBIT 3,1  BMC SOLID WASTE GENERATION
  Obsolete, damaged or
  defective equipment
  Corrugated cardboard
        Current Management
       •""^"^—•SSSSSSSSSSSSSS
 Disposed or sold as scrap
 White paper

•"~>««—WW^MH^

 Mixed jpaper
   i ii

 Magazines
^••^^••••••••B™ ^M»^H

 Toner cartridges

 Pallets
 Some reused, gaylords recycled,
 other cardboard disposed
                         Discarded as waste
                         Some recycled
                                                           Reduce generation, divert for recycling
                        Discarded as waste

                        Returned for recycling
 Plastic iitretch wrap

 Rags   _

 Fluorescent tubes
 USPS pallets sent to Arlington
 facility for redistribution.  Pine
 pallets sold as scrap for mulch

 Discarded as waste
 Strapping

 Oil
•••MM

 Alkaline Batteries
---  . ___

 Lighting Ballasts
Discarded as waste

Discarded as waste
Discarded as waste

Rerefined

Recycled

PCB ballasts managed as hazardous,
non PCS ballasts recycled
 Repair at USPS Computer Repair
 Facility (CRF) in Topeka,iKS, Reuse
                                                           Reduce use of gaylords;Increase use of
                                                           OTRs; Reduce incoming boxes; reuse
                                                           boxes; Improve diversion for recycling
                                                           Reduce generation, divert for recycling
                                   Reduce generation, improve diversion
                                   for recycling
 Reduce generation, divert for recycling

 Continue recycling

 Reduce variety, reuse pine pallets,
 establish recycling options for pine
 pallets
VBOBBBMinnB

 Reduce generation, divert for recycling

 Investigate rag service feasibility
Improve ambient light, install motion
sensitive lighting, divert for recycling

Divert for recycling
Purchase rereflned oil
••^	      	
Jse rechargeable batteries
                                                          Improve ambient light, install motion
                                                          sensitive lighting, turn lights off
                                              12

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3.1    ENVIRONMENTAL OVERSIGHT

Current Conditions                  x
                                           j
       The Dallas BMC does not have an environmental coordinator who is responsible for
environmental activities at the facility. Instead, environmental activities are addressed on an
as-needed basis by either the facility maintenance supervisors or other staff members.  More
importantly, no one is designated to monitor environmental compliance and issues at the site.
Ultimately, the highest ranking USPS employee on site is responsible and liable for all
environmental activities.  BMC personnel attend meetings sponsored by the area
environmental compliance coordinator to share ideas on reducing the environmental impacts
of USPS operations.

Pollution Prevention Opportunities

1. Appoint an Environmental Coordinator     \

       The Dallas BMC  should appoint at least one environmental coordinator for the facility.
This individual should monitor environmental issues and implement opportunities to reduce
waste  disposal and emissions at the facility.

3.2    REDUCE PAPER USE

Current Conditions

        Office personnel interviewed by the Assessment Team, while aware of the double-
sided copying capabilities of duplicating equipment, do not consistently use those options.
Staff is not aware of any efforts to encourage reduction in the quantity of paper  used and
disposed. The Assessment Team observed a significant amount of white paper and computer
print-out in the waste containers.  White paper is recycled by some personnel, but mixed
office papers and magazines are not recycled. Some older copy machines do not have
 double-sided copying capabilities.

Pollution Prevention Opportunities

 1.     Adopt paper waste reduction techniques

        Before initiating  an enhanced recycling; program, 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
        training in the use of the double-sided function on copying equipment. As equipment
        is replaced, specify easy to use, rapid, duplex capability.

                                           13

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9      Expand and encourage the use of electronic mail rather than paper memos and
       distribution copies.                                                ;

e      Limit distribution lists.  If paper copies are necessary, circulate one memo or report
       with a cover sheet indicating distribution.

••      Identify opportunities to reuse paper and paper products.  Corrugated cardboard boxes,
       jiffy bags, manila envelopes and other packaging materials are reusable for their
       original function; paper can be turned over and used as scratch paper or made into
       message pads.

0      Encourage staff to proofread on screen and save information on disks rather than as
       paper file copies.

3.3    REUSE AND RECYCLING

Current Conditions

       Currently, the BMC separates cardboard gaylords, aluminum cans, other aluminum and
metals, used lubricating oil and some paper for recycling.  Staff flatten the gaylord boxes after
one use and place them in an OTR on the tow line for staging for recycling.  All other OCC
is placed in the trash compactor.  The BMC staff predict that they will spend more than
$1,000,000 in fiscal year 1995  to purchase gaylord boxes, each of which will be  used only
once.  USPS plastic and pressboard pallets are sent to the Arlington, Texas pallet distribution
center.  Wooden pine pallets are recycled as wood scrap.  The recycling program for paper is
limited to collection  of high grade white paper.  The office staff has not been irained to
participate hi recycling; some offices had recycling containers, many did not.  Many desks
had small recycled paper holders which typically are inadequate to hold a sufficient quantity
of recycled paper and often are not used.  No other paper is being recycled.  UBBM  and
LIMs iire currently discarded into the compactor. All waste generated at the Crossdock Pallet
Facility is discarded; no recycling is occurring at this facility.

Pollution Prevention Opportunities

1.       Use OTRs instead of cardboard gaylords

       The use of gaylords for moving packages has increased significantly in the last several
years.  BMC staff stated that this is caused by the inability to obtain adequate supplies of mail
transport equipment, especially BMC OTRs. As a result, OTRs are used only to transport
packages within the Dallas region.  Packages that leave the Dallas region are packed  in
gaylords or  are bedloaded.  OTRs are hoarded by all USPS facilities to cope with seasonal
mail volume increases.  According to USPS Headquarters Mail Transport Equipment Office,
aluminum OTRs cost $1,138 and have an expected life of 10 years.  Gaylords are used for a


                                           14

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single trip at the Dallas BMC and cost approximately $6.00 each, depending on the size.  The
Dallas BMC predicts that it will purchase in fiscal year 1995 approximately 28,425 30- inch
gaylords for a cost of $147,969 and 143,000 54-inch gaylords for $875,000.  The BMC will
spend more than $1,000,000 to purchase new gaylord boxes hi fiscal year 1995.  Exhibit 3.2
provides a simple cost/benefit analysis of QTR versus gaylord use.  This analysis shows that
an OTR could be used as few as 39 times per year and be more cost effective than the use of
gaylords. As a result, the USPS should increase the number of OTRs in the system and
increase the repair staff to keep OTRs in service to reduce the reliance on gaylords.

  EXHIBIT 3.2  COST/BENEFIT ANALYSIS FOR OTRS VERSUS GAYLORD USE*
Cost/Activity
a. Initial Cost
b. Number of Trips
c. Maintenance Cost
d. Scrap Value
e. Total Cost
f. Cost Per Trip
Aluminum OTR
$1,138.00
1500 (150/year for 10 years)
$1000 ($100/year for 10
years)
$30
$2,108
$1.40 [
Double- WaUed Cardboard
Gaylord
$6.00
1
None
$0.70
$5.41
$5.41
  Assumptions:
        1.    An OTR is used for three trips per week, 50 weeks per year for a total of 150 trips per year.
        2.    An OTR is in repair two weeks per year; for an annual cost of $100.00.
        3.    Life expectancy of an OTR is 10 years.
        4.    An OTR weighs 385 pounds.  Scrap aluminum value is $0.08 per pound based on recent auction
             price for aluminum scrap.
        5.    A gaylord  is used for one trip (based on Dallas BMC usage).
        6.    A gaylord  weighs 10 pounds and scrap value is $0.07 per pound ($140 per ton).

2.     Cancel the Integrated Mail Handling System

       USPS has an existing inventory of mail transport containers, including both aluminum
and steel BMC  OTRs, originally intended for use in the immediate service area of each Bulk
Mail Center.  Although OTRs were not intended to  be used to move mail between BMCs or
PDCs and BMCs, workers found it too time consuming to .;.-»iload bedloaded tracks.  Now,
postal employees use OTRs to move mail between facilities.  BMCs and PDCs hoard OTRs
for the holiday  season,  and bulk mail customers take OTRs and do not return them.  The
BMCs have no  control  over the OTR inventory, thus OTRs are not readily available to move
the mail.
                                          15

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        To solve the problem of access to mail transport equipment, the USPS has designed
 the Integrated Mail Handling System (IMHS). The pjanned IMHS would substitute
 disposable, corrugated cardboard gaylord boxes for the permanent, reusable OTR containers.
 In addition, because gaylord boxes of adequate volume are too tall, existing BMC mail
 handling equipment, designed to accommodate OTRs, will require modification.

        Rather than invest in costly equipment and program modifications that will increase
 solid waste quantity and handling costs, the USPS should purchase enough additional OTRs or
 other permanent mail transport equipment for the nationwide movement of non-peak period
 mail volume and design and implement a nationwide bar-code labeling and tracking system
 for the OTRs. By utilizing Regional Equipment Processing Centers to track and distribute
 OTRs in a timely fashion, the need for the cardboard gaylords will be eliminated.  The
 gaylords currently stocked for the IMHS can be used only during the Christmas season.

 2.      Reuse cardboard gaylords that enter facility

        As noted above, gaylords that enter the BMC are sent to the lube room for recycling.
 Gaylords are only reused when no new gaylords are available.  USPS employees believe that
 it is too difficult to determine the structural integrity of a used gaylord and that it is too time
 consuming to flatten the used gaylord and return it to the storage area for reuse. The BMC
 should  establish a procedure to evaluate each gaylord entering the facility.  Reusable gaylords
 should  be broken down and staged for reuse.  Damaged gaylords should continue to be
 managed by recycling.  One reuse of each gaylord will reduce the costs for gaylords in half
 saving the BMC $500,000 in purchasing expenses.

 3.     Reuse  cardboard boxes hi other processing operations

       All corrugated cardboard, with the exception of gaylords, is sent to the trash
 compactor.  Boxes of the appropriate size in good condition should be reused hi other
 operations.  For example, the Rewrap Section uses all new boxes for repackaging parcels.
 The BMC should segregate the appropriate sized boxes for use in Rewrap and only use new
 boxes when reusable boxes are not available.

 4.     Segregate for recycling the OCC that cannot be reused                ;

       The BMC believes that it is recycling 70 to 80 percent of its cardboard by recycling
 the gaylords and that only 20 to 30 percent is sent to disposal.  The Assessment Team
 believes these figures are accurate. The BMC recycles approximately 60 tons of OCC each
 month and receives $140 per ton. In fiscal year 1995, to date, the BMC has received
 revenues totaling approximately $39,000. Collecting the additional 20 to 30 percent of OCC
 would reduce  disposal costs  and could yield additional revenues. To  increase the recycling
 rate, however, would require additional labor to evaluate and separate the OCC for reuse or
recycling. This  will be economically justifiable when the proposed recycling center is built
and the  baler utilized.


                                          16                             :      '

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5.     Improve office paper recycling system

       Given the current market value of all grades of office paper, the BMC should improve
the separation of paper for recycling. The BMC should provide more individual and area
collection containers for recyclable paper. These container should be clearly labeled and/or a
distinct color to distinguish them from the waste containers.  A collection container for paper
recycling should be located next to each printer and copying machine. Employees should be
encouraged to empty their desk collection boxes into centralized consolidation containers.
The recyclable paper should be regarded as a valuable commodity, not a waste.  Employees
need information concerning the kinds of paper ;that can and should be recycled.  Employees
should be involved hi the planning and implementation of the recycling program so that they
will value participating hi it.  Exhibit 3.3 provides information on some local companies
interested in discussing paper recycling opportunities and the materials and prices currently
quoted. USPS Environmental Management Policy Office is developing a draft recycling
contract and guidance to  assist postal facilities in selecting a recycler.

        EXHIBIT 3.3 RECYCLERS IN THE DALLAS/FORT WORTH AREA
Recycler
Recycle America Of Dallas
(Waste Management)
12260 Garland Rd
Dallas, TX
Daltex Recycling Company
408 Singleton Blvd.
Dallas, TX 75212
Rock Tenn
9233 Denton Drive
Dallas, TX 75235
Material Accepted
•Paper
Mixed Paper i
Cardboard !
Paper
OCC
OCC |
Mixed office Paper
Computer Paper
White Ledger
Material Price
(September, 1995)
OCC
Mixed Office
White Paper
Computer
OCC
CPO
Mixed
White
OCC
Mixed office
Computer
White Ledger
$169 per ton
$60-70 per ton
Varies depending on grade
Varies depending on grade
$205-215 per ton baled
$80 per ton on skids
$150 per ton
$30 per ton
$90 per ton
$190 per ton baled
$150-170 per ton loose
$30 per ton
$400 per ton
$300 per ton
6.    Reduce quantity of UBBM and LIMs

      USPS bulk mail policies and support services to bulk mailers contribute to the quantity
of undeliverable bulk business mail (UBBM), including magazines and newsprint, hi the
USPS waste stream.  Current USPS policy promotes recycling of UBBM; a policy promoting
UBBM reduction is not under consideration.  UBBM and LIMs constitute a substantial input
into the BMC wastestream and the USPS incurs significant costs to process, transport, deliver
and dispose of UBBM.
                                         17

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       To determine whether reduction o| recycling is the most cost effective management
 practice for UBBM, the USPS should perform a cost analysis to compare the combined
 revenues from bulk mailing and recycling of UBBM to the costs associated with sorting,
 handling, transporting and processing undeliverable mail  and associated packaging.

       To reduce the quantity of UBBM managed by postal facilities, the USPS could expand
 its mailing list maintenance service. Annual mailing list  updates, particularly for third and
 fourth class mail, could-be integrated into the bulk mail permitting process.

 7.     Begin UBBM and LIMs recycling

       At a minimum, the Dallas BMC should begin to recycle UBBM and LIMs to avoid the
 disposal costs and potentially earn revenues.  There would be a minimal additional handling
 costs because the UBBM and LIMs are already hand-verified prior to disposal and would only
 need to be segregated for recycling. Many areas have initiated hauling of UBBM, magazines
 and newsprint to a central location by integrating hauling of UBBM into  the existing mail
 transportation system, A separate transportation system to move UBBM to an accumulation
 point will increase  costs and environmental impacts.

 8.     Set up additional recycling bins in cafeteria

       Metal, glass and plastic food and beverage containers should be separated for
 recycling.  Metal containers can be accommodated hi the  existing metals recycling containers.
 A new recycling program should be established for glass  and plastic food, and beverage
 containers.                             .                           .       |

 3.4    PALLETS

 Current Conditions                                                       ;

       The BMC receives a variety of pallets including pine,  HDPE plastic, and pressboard
 pallets.  The  BMC  currently does an excellent job of collecting and sending the  plastic and
 pressboard pallets to the Pallet Distribution Center in Arlington, TX facility.  Purchasing staff
 believe that pine pallets also are sent to the Arlington facility. The wood container on the
 north side of the facility, however, contained numerous pallets which were being sold as wood
 scrap.  In addition,  pine pallets at the CPF are discarded into the waste container.

Pollution Prevention Opportunities
                                                •                         !

 1.    Establish a recycling program for pine pallets

      Establish a formal recycling system for pine pallets.  Recyclers will repair or rebuild
pallets for resale. Exhibit 3.4 provides a summary of some pallet recycling services available
in the Dallas  area.


                                           18                            i      -

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    EXHIBIT 3.4  EXAMPLES OF PALLET RECYCLERS IN THE DALLAS AREA
            Company
                   Size Collected and Price
  American Pallet Rebuilders
  Phone: (214) 744-4840
The company will only purchase 48"x 48" pallets and will pay up to
$2.50 per pallet, depending on condition. Will collect, at no charge, a
minimum of 400 to 500 pallets.
  AAA Pallets
  Phone: (214) 445-0036
AAA Pallets will pay 50 to 75 cents per pallet, depending on condition.
Accept all sizes of pallets for recycling.  For once-a-week pickup, AAA
will leave a van onsite; for once-per-month pickup, AAA will send a
van.  AAA recycles and repairs pallets. Nothing goes to the landfill.
  All Size Pallet Supply
  Phone: (800) 281-8150
All Size Pallet Supply will pay $1.00 for 48" x 48" pallets. All oilier
sizes will be collected at no cost, but the company will not pay for
them.  Pallets are torn down and rebuilt into needed sizes or repaired
and sold to customers.
  Summers Pallet Service
  Phone: (800) 992-2052
Summers will collect all pallet sizes but only pays for certain sizes.
Prices range from 50 cents to $3.00. For a 48" x 48" pine pallet, they
quoted $2.00. Would provide drop trailers if volume is considerable.
Summers recycles pallets, disassembles odd sizes and remakes them, and
grinds rotten pallets for compost.
3.5    LIGHTING AND ENERGY

Current Conditions

       The Federal government is a major consumer of energy, using more than two percent
of all energy consumed in the United States.  The Energy Policy Act of 1992 requires Federal
agencies to reduce energy consumption per gross square foot 20 percent by the year 2000 and
Executive Order 12902 requires Federal agencies to reduce energy consumption 30 percent by
the year 2005. Although the USPS is not an Executive Branch Agency, it is Postal Service
policy to adhere to Executive Orders whenever feasible.  Both reductions are from a 1985
baseline.  In addition, Federal agencies must conduct comprehensive energy audits and install
cost-effective energy conservation measures; agencies are encouraged to audit 10 percent of
their facilities each year, using "no-cost" audits where practicable. These requirements are
summarized in Exhibit 3.5.

       The BMC is in the process of upgrading the lighting on the floors with high intensity
lighting and hopes, over time, to eliminate the use of fluorescent lights completely.  The BMC
is a 22 year old building and is in need of significant lighting upgrades. One potential
improvement is to switch all the fluorescent lights to sulfur lighting tubes.  The Dallas BMC
has volunteered to be a "model facility" for sulfur lighting.  The USPS regional environmental
coordinator will purchase the lights, and the Department of Energy will install the lighting
system in the facility. The BMC is willing to consider other methods to improve the floor
lighting as well as the lighting efficiency.
                                            19

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                       EXHIBIT 3.5  FEDERAL ENERGY POLICIES
Energy Policy Act of 1992
Reduce energy consumption per gross square foot 10
percent by 1995 (1985 baseline)
Reduce energy consumption per gross square foot 20
percent by 2000 (1985 baseline)
Conduct comprehensive facility audits and install
cost-effective energy conservation measures
In Federally owned buildings, install all energy and
water conservation measures that have payback
periods of less than 10 years
Executive Order 12902
Reduce energy consumption per gross square foot 30
percent by 2005 (1985 baseline) :
Reduce energy consumption per gross square foot 20
percent in industrial facilities by 2005 (1990
baseline) \
Conduct surveys and comprehensive audits
Implement recommendations for energy efficiency,
water conservation and renewable energy that have
payback periods of less than 10 years
         In a separate, but related issue, the roof at the BMC is also in need of repairs  In
   several locations throughout the building, leaks have developed in the roof.  There has been
   some discussion about replacing the roof and, as a result, ambient lighting projects may be
   considered.

   Pollution Prevention Opportunities                                          ,
                                                                            f
   1.     Increase the Use of Motion Sensitive Lighting

         'While motion sensitive lighting was used in office areas it was not apparent in other
  parts of the facility.  The BMC staff should review the lighting plans and install motion
  sensitive lighting hi infrequently used areas.

  2.     Establish a "lights out" policy

         Establish a policy of turning off lights and equipment when leaving an area.  Where
  machine design permits, turn photocopiers to  low power when not hi use.  Each kilowatt hour
  saved prevents  the formation of air pollutants, including 0.68 kg of carbon dioxide, 5.8 g of
  sulfur dioxide and 2.5 g of nitrogen oxides.                                     '

. 3.     Investigate Increasing the Use of Ambient Lighting

         The Dallas BMC should study the possibility ef installing daylighting systems (i e
  skylights) to allow more energy efficient lighting into the building. An estimated 30 to 5o'
  percent of the energy used in a commercial building is spent illuminating the ulterior.
  Daylight can significantly reduce energy consumption and peak energy use hi commercial
  buildings.                                                                 i
                                             20

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       There are two basic systems for daylighting, active and passive.  Active daylighting
systems employ a system of stacked reflective mirrors and a robotics unit with an infrared,
light-sensitive photo diode that tracks the sun as it travels through the sky.  The units are set
for the specific latitude of the building.  During the day, the units turn to catch the sun at its
maximum angle, then reflect the light down through the skylight With passive  daylighting
systems, the sunlight penetrates the external dome and directs the light into the building.
Exhibit 3.6 presents the approximate square feet of coverage per daylighting unit.

      EXHIBIT 3.6 SQUARE FEET  OF COVERAGE PER DAYLIGHTING UNIT
Ceiling Height (feet)
8 to 9
10 to 15
16 to 19
20 to 40
Low Levels of Light
(30-50 foot candles)
400 sq ft
700 sq ft
<>66 sq ft
1000 sq ft
High Levels of Light
(50-106 foot candles)
300 sq ft
500 sq ft
766 sq ft
806sqtt
       There a several companies that produce and install daylighting systems. Two
companies provided information for this report: So-Luminaire Daylighting Systems
Corporation and The Natural Lighting Company.  The So=Luminaire system is an active
daylighting system that is installed in 4' x 4' casings on the roof of a building and reflects
natural sunlight through a skylight into the interior of a building.  A cluster of diffusion
lenses spreads the daylight inside the building.  So-Luminaire's two diffusion lenses create
dead air spaces which act as thermal barriers to reduce conductive heat gain/heat  loss by
approximately 50 percent. So-Luminaire estimates that each unit eliminates the use of over
two million watts of fluorescent lighting per year, and only consumes one cent in energy costs
per year.

       The Natural Lighting Company manufactures both active and passive daylighting
systems.  The active daylighting system uses sun-tracking mirrors to redirect sunlight into a
reflective light well and diffusing  lens.  The passive daylighting system uses an innovative
prismatic dome, reflective light well and diffusing system to light ulterior spaces. The
Natural Lighting Company also produces the So-Dark motorized shade screen which is built
into the skylight frame allowing a skylight to be partially or completely darkened at the flip
of a switch. This product can be used with either the active or passive daylighting systems.

       There are several benefits to daylighting and unproved facility lighting. The most
important is that energy-efficient building design  can significantly increase worker
productivity.  A recent study by the Rocky Mountain Institute found that efficient lighting (as
well as heating and cooling) measurably increased worker productivity, decreased
absenteeism, and/or improved the  quality of work performed. An increase of 1 percent in
productivity can provide savings to a company that exceed its entire energy bill.  The study
presents eight case studies of unproved productivity resulting from increased lighting
efficiency.  One case study  included the mam post office in Reno, Nevada which found that a
                                          21

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 lighting retrofit with a six-year payback led to a six percent gain in productivity — worth
 more than the cost of the retrofit.        S         4!  ;

 Other benefits of daylighting include:

       !•      reducing electric lighting utility costs
       •      reducing electric lighting maintenance costs
       -•-•      reducing electric lighting heat loads on  air conditioning systems

 4.     Investigate Technical Assistance from Green Lights Program

       The staff at the BMC expressed interest in technical assistance to modify the lighting
 at the facility.  USEPA operates Green Lights, a voluntary, non-regulatory program promoting
 pollution prevention through the installation of energy efficient lighting. Federal partners
 agree-to upgrade lighting to maximize  energy savings  wherever it is profitable.  The Green
 Lights program benefits participants by lowering electricity bills, improving lighting quality,
 and increasing worker productivity. Energy efficiency also reduces the quantity of pollutants
 released in the  generation of electricity. For example, EPA estimates that if Green Lights
 were  fully implemented, where profitable, in the United States, it would save over 65 million
 kilowatts of electricity annually, reducing the national  electric bill by $16 billion per year.
 The program would also result in reductions of carbon dioxide, sulfur dioxide, and nitrogen
 oxides equivalent to 12 percent of U.S. utility emissions, curbing acid rain and smog and
 helping to slow the greenhouse effect

 5.     Become a Federal Partner in the Green Lights Program

       Federal  organizations can become Green Lights Partners by signing a Memorandum of
 Understanding (MOU) with USEPA (see Appendix B) agreeing to:

       Survey agency facilities and identify lighting upgrades that will reduce energy use 50
       percent,                                                           \  •
       Upgrade 90 percent of the square footage of agency facilities no later than September
       1,2005, and                                                     •  ;
 0      Appoint a coordinator to oversee participation in the program and document annual
       energy efficiency improvements.

       Green Lights provides free technical assistance  to participants through written
materials,  information hotlines, and thorough survey and analysis software products that allow
Green lights participants to analyze their options for installing energy-efficieiif lighting.  The
system helps participants survey the lighting systems in their facilities, assess their retrofit
options, select the  option that maximizes energy and pollution savings while simultaneously
rating or improving lighting quality and meeting the Green Lights profitability criteria, and
produces reports suitable for use by facility managers,  financial staff, and senior management.
                                           22

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       EPA provides the following support systems to help Green Lights participants obtain
information on energy-efficient lighting technology, financing options, and public recognition
opportunities.

•      Lighting Services Technical Support: provides extensive technical support through a
       hotline, a comprehensive Lighting Upgrade Manual, and workshops.

•      Survey and Analysis Tools: state-of-the-art computer software helps participants survey
       facilities and select lighting upgrade options that maximize energy savings and meet
       profitability goals.

•      Financing Directory: Federal agencies may utilize third party financing or traditional
       procurement mechanisms.  In addition, however, Federal participants may consider
       utility financing, energy savings performance contracts and the Federal Energy
       Efficiency Fund.  EPA can also provide survey and analysis services through an inter-
       agency agreement

•      The National Lighting Product Information Program: objective source of current
       performance and price information on energy- efficient lighting products.

•      Public Recognition:  participants receive public recognition for their environmental
       leadership through EPA-generated news articles, media events, and public service
       advertisements.  EPA encourages participants to promote their own Green Lights
       activities by distributing free, ready-to-use promotional materials.

       In the MOU, EPA and the Federal agency agree: "that the commitment to survey
buildings and complete lighting upgrades is contingent upon the availability of appropriated
funds or third-party financing resources."      '

       The USPS can commit to the Green Lights program by signing a Memorandum of
Understanding with USEPA agreeing to assign a coordinator, survey facilities and begin
installation of energy efficient lighting.  For further information on Green Lights for Federal
Facilities contact:

       Gwendolyn Taylor, Federal Program Manager
       Green Lights & Energy Star Programs
       501 3rd Street, NW  (Mail Code 62 02J)
       Washington, DC 20001
       Telephone: (202) 233-9472
       Fax: (202) 233-9578                               :
                                          23;

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 6.     Procure computers that meet Energy Star requirements
                                   ,  -I        • 4if  *.  .                 ;
       Future computer equipment purchases should specify equipment that is energy
 efficient.  Executive Order 12845 requires Federal agencies to purchase computer equipment
 that meets EPA Energy Star requirements for energy efficiency.  The EPA Energy Star
 Program is a voluntary partnership with the computer industry to promote energy-efficient
 personal computers, monitors and printers. Participating companies have committed to
 develop computer equipment that powers down when not hi use. The "sleep" feature cuts
 energy use by 50-75%.  Energy Star also  includes a category for controlling devices, external
 retrofit products that reduce the energy consumption of existing computer equipment by
 automatically turning them off when not in use.  The Federal Supply Service offers a product
 called the Intelligent Energy Saver, a PC add-on device that controls electrical power to the
 PC and its peripherals.  The complete PC system can be powered on and off at user-defined
 dates and times. Appendix C provides information on how to purchase Energy Star
 equipment and a list of participating companies and manufacturers of equipment that meets
 Energy  Star requirements.

 3.6    FLUORESCENT LIGHTING

 Current Conditions

       The BMC offices, warehouses and work areas are lighted with approximately 1,500
 fluorescent tubes.  The BMC discards at least 21 fluorescent tubes per day, five days per week
 into the trash compactor. Staff believe that if they limit their disposal to 24 tubes per day,
 they do not need to dispose of them as a hazardous waste.  According to the Texas Natural
 Resources Conservation Commission, Industrial and Hazardous Waste Division, fluorescent
 lights are not automatically hazardous. A determination must be made using TCLP  or by
 simply declaring them as hazardous.  The  determination on whether they must be managed as
 a hazardous waste is dependent on the RCRA status of the facility.

      Fluorescent lights are one of the most energy efficient lighting sources available.
 However, fluorescent lighting tubes contain mercury, which is used as an element to conduct
the flow of the electric current.  Historically, fluorescent lighting tubes were discarded into
 landfills.  When the tubes broke, mercury  was released to the environment.  This potential
hazard caused many states to classify fluorescent lighting tubes as hazardous waste and
require that they be managed hi accordance with applicable hazardous waste laws and
regulations.                                                             ;

      Recycling spent fluorescent lighting tubes offers an environmentally sound alternative
to expensive hazardous waste disposal. Additionally, recycling may relieve the generator of
future liability concerns associated with tube disposal. Several companies provide recycling
services for spent fluorescent lighting tubes and some of these companies also accept ballasts,
a component of the light fixture.  Ballasts  manufactured prior to 1980 contain polychlorinated
biphenyls (PCBs), which also present disposal problems. However, ballasts produced after


                                        ' 24       '

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 1980 do not contain PCBs.. According to Ron Newman of A-TEC Recycling, the useful life
 of ballasts is approximately 15 years. Since ballasts manufactured after 1980 do not contain
 PCBs,  ballasts containing PCBs should not present significant disposal problems beyond the
 near term.

       Some states allow ballasts that do not contain PCBs to be disposed of hi sanitary
 landfills. However, according to Stephanie Small of DYNEX Environmental, Inc., non-PCB
 ballasts contain diethylhexylphthalate (DEHP). Evidence indicates that DEEP is a human
 carcinogen.  Due to either the PCBs or DEHP  content, Ms. Small recommends that customers
 manage all ballasts as hazardous.

       USPS Memorandum for Managers, Operations Support dated December 16,  1994
 states that "Under no circumstances should these lamps be mechanically crushed or ground
 into smaller pieces.  This method of disposal increases the exposure of hazardous materials to
 both employees and the environment. Lamps should be boxed prior to disposal."

 Pollution Prevention Opportunities
                                           1
 1.     Establish Fluorescent Tube Recycling Program

       Store expired bulbs hi boxes hi a safe area. USPS facilities should ship expired bulbs
to an approved facility for recycling of glass, metals, and mercury.

        Exhibit 3.7 provides information on the specific services offered by companies that
provide fluorescent tube recycling services, the post of the services and the geographic area
serviced by each company.  For further  information on the services of each company, see
Appendix D.
                                          25

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 3.7   RECHARGEABLE BATTERIES         |

 Current Conditions

       The Dallas facility uses numerous alkaline batteries for various functions.  The
 batteries are used predominantly in flash lights utilized during machine repairs and
 maintenance activities. The BMC uses numerous AA, C, D, and 9v batteries. The stock room
 maintains a barrel to collect the batteries for recycling.  The Dallas facility generates one 55-
 gallon drum of used alkaline batteries every three months; these are recycled with other
 metals.

 Pollution Prevention Opportunity

 1.     Purchase Rechargeable Batteries

       The Dallas BMC should purchase rechargeable batteries and a charging unit to
 recharge the batteries. By using rechargeable batteries, the BMC would reduce the purchase
 cost of batteries.  Rechargeable batteries, however, do not provide power for as long as
 alkaline batteries before recharging is necessary.                             ;

       GSA has Rayovac rechargeable alkaline batteries which are now available  through
 Muffin or FWW-19. Rayovac's patented Renewal batteries offer the high performance
 attributes of regular alkaline batteries along with the cost and environmental benefits of a
 reusable system. Renewal batteries are available in battery  sizes AAA, AA, Cs and D.  The
 power stations for recharging batteries also are available from GSA. Stock numbers and
 prices are listed below. For additional information, call Ms. Genni Brown 817-334-8377.

 Rayovac Rechargeable batteries

 Size D              Model 713    6140-01-413-3925          Box (20 per box)    $32.80
 Size C              Model 714-2 6140-01-413-3923          Box (20 per box)    $32 80
 Size AA.            Model 715-4 6140-01-413-3926          Box (40 per box)    $35.90
 Size AAA           Model 724-4 6140-10-413-3928          Box (40 per box)    $35.90

 Charger             Model PS2   6140-01-413-3929          Box (4 per box)      $9008
 (All Sizes)                                                                       '

 3.8    AFFIRMATIVE PROCUREMENT

 Current Conditions               '                                        >•     .

       The BMC 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 BMC are unaware of USPS policy and federal legislation

                                         28                             ;

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requiring the purchase of materials with recovered content.  The United States Postal Sen/ice
Waste Reduction Guide (AS552, February, 1992) directs Requiring offices to "review
purchase specifications to eliminate prohibitions pr 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
practicable."  To date, USEPA has established procurement guidelines for paper and paper
products, retread tires, re-refined lubricating oil, building insulation, and cement and concrete
containing fly ash.  EPA recently published the Comprehensive Guideline for Procurement of
Products Containing Recovered Material (60 FR 21370, May 1, 1995) adding 19 additional
products including engine coolant, 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.

       The BMC was not able to document successful implementation of USEPA
procurement guidelines for  products manufactured with recovered content.  The BMC is,
however, in the process of eliminating products containing the seventeen chemicals on
USEPA's 33/50  list 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 BMC should establish preference programs and adopt specifications for the
purchase of products made with the percentages of recovered materials specified hi USEPA
Guidelines.  The GSA catalog has special sections for environmentally sound products, such
as paper with recycled content  These items are highlighted in green throughout the catalog.
The BMC purchasing official should make it a standard practice to purchase items with the
highest amount of recycled content Changes hi the procurement system will create staff
training opportunities and staff will need training on Federal affirmative procurement
requirements.  Exhibit 3.8 presents products for which EPA has established minimum
recovered content levels.
                                          29

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      EXHIBIT 3.8 EPA ESTABLISHED MINIMUM RECOVERED CONTENT LEVELS
Category/Product . Percent Recycled Content
Paper
grade bleached printing and writing paper?! &
o and duplicator paper
uter paper
ipes
Tissue Products




Unbleached packaging

Vehicular Products


Construction Products
lass (glass cullet)
ise loose-fill and spray-on (post-consumer paper)
iral fiberboards
aited paperboards

it and Concrete (ground granulated blast furnace slag)
ter Carpet Face Fiber (PET resin)
docks (rubber or rubber blends)
•locks (plastic or plastic blends)
lies (rubber)
lies (plastic)
Transportation products
cones (PVC, LDPE, Crumb Rubber)
barricades (HOPE, LDPE, Pet Steel)
barricades (Fiberglass)
Park and Recreation Products
jund surfaces (rubber or plastic)
g tracks (rubber or plastic)
50%
50%
50%
50%

20%
40%
30% :
5%

35% i

25%
retread tires

20-25%
75%
80-100%
100%
0-40%
25-50%
25-100%
90-100%
90-100%
90-100%
90-100%

50-100%
80-100%
100%

90-100%
90-100%
Landscaping Products
jased hydraulic mulch (post-consumer recovered paper)
based hydraulic mulch (recovered wood and/or paper)
100%
100%
Non-paper Office Products
recycling containers and waste receptacles (plastic)
recycling containers and waste receptacles (steel)
desktop accessories (polystyrene)
covered binders (plastic)
ard, paperboard, pressboard binders
trash bags
20-100%
25-100%
25-80%
25-50%
80%
10-100%
Tires
                                    30

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       EPA has developed lists of manufacturers and vendors of the items designated hi the
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 Recycled Products Guide, has been prepared;to assist Federal civilian and military
agencies to identify the environmentally oriented products and services available to them
through the supply system of the General Servicbs 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.

       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. at (800) 267-0707

       The Defense General Supply Center hi Richmond, VA also distributes the
Environmentally Preferred Products Catalog which lists hundreds of environmentally
preferable products hi 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-preferable products, call or write:

       Defense General Supply Center
       Attn. Marketing Office
       8000 Jefferson Davis Highway         j
       Richmond, VA  23297-5762
       1-800-848-4847
                                          31

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3.8    OVERSIGHT OF CHEMICAL STORAGE
                                     y     •    «ft  •
Current Conditions

       All shops and flammable materials  cabinets in the BMC contained products with
chemical constituents listed on the EPA 33/50 list.  The BMC staff has discontinued ordering
materials with EPA 33/50 chemicals, found suitable replacements and is hi the process of
depleting stocks. The BMC has established a system in which all material purchases are
reviewed for ODC  and EPA 33/50 constituents prior to purchase. Over tune the BMC staff
believes that this system will eliminate the use of ODCs and EPA 33/50 chemicals.  The
maintenance shops  has a solvent sink that uses an aqueous degreaser. Flammable materials
cabinets were filled with products, many apparently very old.  One flammable materials
cabinet hi the OTR repair shop had several inches of oil in the bottom.

Pollution Prevention Opportunities

1. -   Evaluate the Contents of all Flammable Materials Cabinets

       The BMC staff should perform an inventory on all flammable materials cabinets in
order to determine  if materials are old, expired,  or no longer needed by an operation. Old or
expired chemicals should be removed from the shops and disposed of properly:  Products no
longer  needed should be inventoried and used as needed in other operations.

2.     Perform periodic inspections of flammable materials cabinets

       The BMC staff should perform periodic inspections of flammable materials cabinets to
determine if contents are intact and that products brought in from sources other than
procurement are eliminated.  Periodic inspection and cleanout  of cabinets will minimize the
risk of spills and interaction of incompatible chemicals.

3.9    RAGS

Current Conditions

       The maintenance staff currently use rags to wipe up and clean up during maintenance
operations.  These rags tend to be very oily. The facility was using a rag service in the psist
but found that they were continually purchasing new rags because the service could not clean
the rags.  All rags are now purchased either locally or through GSA and disposed via
incineration.  The BMC purchased 6,250 pounds of rags hi 1994 for $2,375 arid hi 1995
through April have purchased 3,750 pounds for  $555.  The Facility expects to purchase
approximately 6,900 pound of rags for an  approximate cost of $1,000.  The facility generates
three to four 55-gallon drums of rags  per month which are incinerated for approximately $400
per drum.
                                          32

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 Pollution Prevention Opportunities

 1. Test another rag laundering service

        Several rag recyclers and linen services in the Dallas/Fort Worth area were contacted;
 only one would launder oily rags.  National Uniform (a division of National Linen Service)
 (817) 429-5891  will pick up, launder and deliver rags from the Dallas BMC at a cost of $1.50
 per pound.  National stated that they will accept oily rags but not rags with chemicals,
 solvents, degreasers etc and that they would appreciate MSDS  on oils used by the USPS.  An
 analysis of the costs show that laundering rags may be cheaper than purchasing new rags.
 Laundering rags may save between $400 and $1,100 per year.  Exhibit 3.9 presents a simple
 cost/benefit analysis of laundering rags.

         EXHIBIT 3.9 COST BENEFIT ANALYSIS OF LAUNDERING RAGS*
Cost/Activity
Initial Rag Purchase Cost
Laundering Cost
Disposal Costs
Year 1 cost
Cost Savings
Year 2 rag replacement cost
Year 2 cost
Cost Savings
Laundering
$1,030
$10,350 ($1.50 per pound)
$3,600 (25 percent of
$14,400)
$2.17 per pound
$414
$258
$2.06 per pound
$1,173
New
$1,030
none
$14,400 based on three 55
gallon drums per month at
$400 per drum.
$2.23 per pound


$2.23 per pound

        Assumptions:
        1.     BMC uses 6,900 pound of rags per year.
        2.     Under reuse option BMC replaces 25 percent of the rags each year.
        3.     Disposal cost is $400 per drum and the BMC currently generates 3 drums per month.

3.10   BATTERY CHARGING
                                            I
Current Conditions                           j


       The BMC uses numerous battery powered forklifts for the movement of materials.  For
the main facility the batteries are stored and charged in the battery room.  Typically for each
forklift there are three batteries; one in use, one charging and one ready for use. When
needed, the batteries are filled with water and recharged.  The Assessment Team noted that
there was an open drain in the battery room that leads to the sanitary sewer.  The battery
room in the BMC is scheduled to be upgraded to increase the space, lighting, ventilation and
                                          33

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add lime neutralization tanks. Forklift batteries are charged at several other ,BMC locations.
For example, both the warehouse and the CPF facility had battery charging occurring with no
supervision, no spill containment, and no safety equipment.

Pollution Prevention Opportunity

1.     The drain hi the battery room should be diked to prevent the accidental discharge of
       battery acid to the sanitary sewer.  There are devices commercially available to dike
       drains.  Once spills are contained, neutralize the battery acid with sodium bicarbonate
       (baking soda) and then wash the neutralized acid down the drain with water.
       Neutralizing the acid will reduce the likelihood of corrosion of pipes.

2o     Review procedures on the proper charging of batteries to prevent accidental acid
       overflows.

3.     Remove battery charging operations from remote facilities if possible or provide the
       appropriate safety and containment equipment for these sites.

3dl   DEDICATED OIL CONTAINERS

Current Conditions

       The Dallas BMC oil room has a bulk distribution system which stores several types of
oil and. a solvent called Pro-Power,  which is an oil emulsifier.  This distribution system stores
materials in 55 gallon containers and has clear PVC tubes that connect to corresponding
loekable, self closing faucets  to distribute the materials.  Several unmarked, open containers
are stored under the bulk distribution system. These containers  are used to distribute and
transport the materials for use.  After each use, staff must empty the remaining oil into the
waste oil drum and then clean the container with solvent for reuse. This process generates
unnecessary waste because excess oil is disposed, instead of being reused, and because the
containers must be cleaned with solvent after each use.

Pollution Prevention Opportunities

       The BMC should purchase and dedicate containers for specific materials.  These
containers should have tight-sealing lids and be clearly marked with the type of material for
which the container is intended.  There are many containers on the market that also have
marks indicating the volume.  This will ease distribution and help to reduce the amount of
excess material dispensed from the bulk distribution system.  Also, by having closed, clearly
marked containers, the excess materials can be left hi the container for reuse.  This will
eliminate the need to clean the containers with solvent after each use, thereby reducing solvent
use.
                                           34

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3.12   POLLUTION PREVENTION INFORMATION SOURCES

Current Conditions

       During the site visit, Dallas BMC staff indicated that they would like information on
accessing pollution prevention information.

Pollution Prevention Opportunities

       There are numerous sources of pollution prevention information nationwide.  Appendix
E provides a summary of pollution prevention information sources.

       There are several sources of pollution prevention information on the internet.  Perhaps,
the best source is Enviro$en$e.  This internet-based information source is funded by the
Environmental Protection Agency and the Strategic Environmental Research and Development
Program.  Enviro$en$e allows those implementing pollution prevention programs or
developing research and development projects to benefit from the experience, progress, and
knowledge of their peers. EnviroSenSe includes a pollution prevention forum for all levels of
government, researchers, industry, and public interest groups. Enviro$en$e has been
developed to host an expert architecture known as the Solvent Umbrella. .The Solvent
Umbrella will allow users to access solvent alternative information through a single,
easy-to-use command structure;  EnviroSenSe is also modem accessible via Bulletin Board
System (BBS).  Through Netscape, EnviroSenSe address is:

       http://wastenot.hiel.gov/envirosense.

       The EPA also has a World Wide Web (WWW) Server, which is being run as a
prototype system, to provide public access to EPA information. The EPA provides the
comprehensive Access EPA document describing environmental information, as well as a
number of other pointers to Information Locators that can be obtained from the EPA and
related organizations.  In addition to this document, the EPA's Public Information Center is
available to provide assistance in accessing environmental information. An experimental EPA
People Locator is also available. Through Netscape, EPA's WWW server can be accessed
through http://www.epa.gov.

       The EPA WWW server provides information on EPA Agency information and
environmental data, including:

       •      Press Releases, Calendar, Announcements, Speeches,
       •      EPA Offices and Regions,
       •      Consumer Information,
       •      EPA Initiatives, Policy and Strategy Documents,
       •      Rules, Regulations and Legislation,
             EPA Standards,


                                         35

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      •      Science, Research and Technology,
      •      Information about Grants, Contracts (RFPs), and Job Vacancies,
      «      Newsletters and Journals, thd       "
      e      Software and Databases.

      Another source of environmental information is the Air Force Center for
Environmental Excellence (AFCEE), Pollution Prevention Directorate located at Brooks APB
in Texas.  AFCEE produces PRO-ACT factsheets on various pollution prevention topics,
ranging from corrugated cardboard pallets to a summary .of environmental Executive Orders.
Through Netscape, the PRO-ACT fact sheets can be accessed through:

      http://chppm-meis.apgea,army.mil/pro-act/uidex_txt.html.
                                         36

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                                   SECTION 4.0


                   CONCLUSIONS AND RECOMMENDATIONS
      This Pollution Prevention Opportunity Assessment report documents the processes
performed, wastes generated and current waste management practices at the USPS Bulk Mail
Center in Dallas, Texas. During the assessment process, the Assessment Team identified
opportunities to reduce both the quantity and toxicity of the wastes 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.  Exhibit 3.1 presents a summary of the major recommendations.

      Dissemination of this report will encourage application of the pollution prevention
opportunities hi USPS bulk mail facilities nationwide as well as in other Federal facilities
with similar operations.
                                        37

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                                  APPENDIX A.

           EPA 33/50 CHEMICALS AND OZONE DEPLETING CHEMICALS
Benzene
Cadmium and Cadmium compounds
Carbon Tetrachioride
Chloroform
Chromium and Chromium compounds
Cyanide compounds and Hydrogen Cyanide
Lead and Lead compounds
Mercury and Mercury compounds
Methylerie  Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Nickel and Nickel compounds
Tetrachloroethylene (Perchloroethylene)  '
Toluene
1,191 -Trichloroethane
Trichloroethylene
Xylenes
                                38

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                            OZONE DEPLETING CHEMICALS
Halocarbon Number

CFC-11
CFC-12
CFC-113
CFC-114
CFC-115
Halon 1211
Halon 1301
Halon 2402
CFC-13
CFC-111
CFC-112
CFC-211
CFC-212
CFC-213
CFC-214
CFC-215
CFC-216
CFC-217
Carbon Tetrachloride
Methyl Chloroform
Methyl Bromide

HCFC-21
HCFC-22
HCFC-121
HCFC-122
HCFC-123
HCFC-124
HCFC-131
HCFC-132
HCFC-133
HCFC-141
HCFC-142
Chemical Name Primary Uses*
CLASS I ODCs
Trichlorofluoromethane 1,2,3,4,5
Dichlorodifluoromethane - 1,2,4
Trichlorotrifluoroethane 2.3.4
Dichlorotetrafluoroethane 1,2,3,4,6
Chloropentafluoroethane 6
Bromochlorodifluoromethane 3,7
Bromotrifluoromethane 1,3,5
Dibromotetrafluoroethane 1,3
Chlorotrifluoromethane 6J
Peatachlorofluoroethane o
Tetrachlorodifluoroethane 4
Heptachlorofluoropropane 0
Hexachlorodifluoropropane 0
Pentaehlorotrifluoropropane 0
Tetrachlorotetrafluoropropane 0
Trichloropentafluoropropane 0
Dichlorohexafluoroprbpane 0
Chloroheptafluoropropane 0
Tetrachloroethane 1458
. " : *5^^S*'?*'
Trichloroethane (all isomers) 4,5,8
4,5,8
CLASS II ODCs
Dichlorofluoromethane 1 4
~ *^r
Chlorodifluoromethane 1,4,5
Tetrachlorofluoroethane Q
Trichlorodifluoroethane o
Dichlorotrifiuoroethane 1,3
Chlorotetrafluoroethane 1,3
Trichlorofluoroethane \ Q
Dichlorodifluoroethane o
Chlorotrifluoroethane ; Q
Dichlorofluoroethane 2
Chlorodifluoroethane 1,4,5
* The eight use categories are as follows:

1.     Refrigeration; Air Conditioning           5.
2.     Blowing Agents for Plastics              6.
3.     Fire Extinguishing Agent                7.
4.     Solvent: Dry Cleaning Agent; Degreaser   8.
Intermediate for Synthesis of Other Compounds
Dielectric Gas
Aerospace Chemical
Fumigant:  Pesticide
                                          39

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                   APPENDIX B.

GREEN LIGHTS INFORMATION AND SAMPLE MEMORANDUM OF
   UNDERSTANDING (MOU) FOR GREEN LIGHTS PARTNERS
                   40

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United States
Environmental Protection
Agency
Air and Radiation
6202J    i
                           EPA430-B-94-001A
                           December 1994
Green  Lights for
Federal  Participants
                                               Green
                                               Lights
   When EPA launched Green Lights - its flagship
   voluntary pollution prevention program - it engaged
   the free market by promoting profitable investment in
   energy-efficient lighting.  Since 1991. more than 1.500
   organizations across the country have joined Green
   Lights to conserve energy, cut their electricity bills, and
   reduce the amount of air pollutants released into the
   atmosphere. This dynamic program continues to grow
   and meet the energy needs of the country. Currently,
   Green Lights is helping Federal agencies comply with
   mandated energy conservation goals.

   The Federal government is a major consumer of
   energy, using over 2 percent of all energy consumed
   in the US. Two mandates — The Energy Policy Act of
   1992 (EPAct) and Executive Order 12902 (EO 12902)
   — require Federal agencies to cut energy use.  Green
   Lights provides mechanisms for Federal  agencies to
   meet these mandates by offering extensive technical
   expertise and planning support.
    FEDERAL ENERGY

    CONSERVATION MANDATES


    The Energy Policy Act of 1992
    (EPAct)

    EPAct requires Federal agencies to reduce energy
    consumption per gross square foot 20 percent by the
    year 2000 (compared to 1985). It also requires that
    agencies install energy conservation measures with
    less than 10-year payback periods. Certain buildings
    are exc'^ded from this mandate (see box). EPAct
    encourages Green Lights participation in Section 543
    (paragraph b.4).


    "An agency may participate in the EPA's Green
    Lights program for purposes .of receiving
    technical assistance in complying with the
    requirements of this section."
            CONTENTS


            FEDERAL ENERGY
            CONSERVATION MANDATES.
                                        .1
            FEDERAL GREEN LIGHTS	3

            EVALUATING UPGRADE OPTIONS	4

            FINANCING OPTIONS	5
            Executive Order 12902

            EO 12902 requires Federal agencies to reduce energy
            consumption 30 percent per gross square foot by the
            year 2005 (as
            compared to
            1985).  It also
                              Buildings exempt from
                              EPAct

                              •   Federal agency facilities
                                 that generate or transmit
                                 electric energy
                              •   Uranium enrichment
                                 facilities operated by DOE
                              •   Buildings in which
                                 compliance with the
                                 requirements would be
                                 impractical
requires a 20
percent
reduction in
energy
consumption in
industrial
facilities by
2005
(compared to
1990). The
order compels
agencies to
conduct
comprehensive
facility audits and install cost-effective energy
conservation measures. Agencies should audit about
10 percent of their facilities each year.  However, if a
facility has had a comprehensive audit within the last
three years, it counts as current. Agencies must use
"no-cost" audits wherever practicable. The actions
required of Federal agencies by EO 12902 are
summarized below.
         Green Lights for Federal Participants • Lighting Upgrade Manual • EPA's Green Lights Progra.m • December 1994

                                         41

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    Goals for Energy Use/SqFt Reduction
         in Existing Federal Buildings

  EPACT. 1992	...20% by 2000 relative to 1985

  EO 12902. 1994	30% by 2005 relative to 1985
Activities Required  by EO 12902

September 1994

•/   Begin implementing cost-effective
    recommendations from comprehensive facility
    audits performed within the last three years to
    install energy efficiency, water conservation, and
    renewable energy technologies

•/   Designate one major building to showcase energy
    or water efficiency (and other renewable energy
    technologies if possible)

^   Develop showcase implementation plan

March 1995

^   Identify high priority facilities to
    audit
 '  Complete first 10 percent of
    comprehensive facility audits

 Within six months of each
 audit

 •  Begin installing cost-effective
    recommendations (i.e., those
    with less than 10 year
    payback) for energy efficiency,
    water conservation, and
    renewable esnergy technologies

 September 1995

 '  Complete prioritization surveys
    for all facilities
                  December 1995

                  '  Reclassify "exempt" or "industrial" facilities
                     based on prioritization surveys, and report to the
                     Federal Energy Management Program and the
                     Office of Management and Budget
                  Interaction Between EPAct and
                  EO 12902

                  Both EPAct and EO 12902 require Federal agencies
                  to reduce energy consumption pel- gross square foot
                  and to implement energy conservation measures.

                  EO 12902 effectively extends the; EPAct timeline for
                  Federal energy conservation measures to 200J5 and
                  requires additional energy savings by that time.  It
                  also requires energy conservation  in industrial
                  facilities. Finally, while EPAct allowed exemptions of
                  entire facilities due to specialized;  energy-intensive
                  activities, EO 12902 requires agencies to designate
                  specific buildings as exempt and implement cost-
                  effective conservation measures wherever possible in
                  other parts of those facilities.
EPAct

^ reduce energy consumption per gross ft2 10 percent by 1995 (compared
   to 1985)
^ reduce energy consumption per gross ft2 20 percent by 2000 (compared
   to 1985)                        •    .     •   :
^ install all energy and water conservation measures with payback periods
   of less than 10 years in Federally owned buildings;
^ exempt buildings in which energy intensive activities are carried out

E012902                                    I

^ reduce energy consumption per gross ft2 30 percent by 2005 (compared
   to 1985)                                    ;
y reduce energy consumption per gross ft2 20 percent in industrial facilities
   in aggregate by 2005 (compared to 1990)
^ conduct surveys and comprehensive audits and implement
   recommendations with payback periods of less than 10 years
^ reclassify "exempt" facilities
       Green Liahts for Federal Particioants • Liahtir
                                              42

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   To assist in overcoming many of the
   obstacles that may have stalled lighting
   upgrades in the past, participants will
   receive extensive support materials and
   services from EPA. We currently provide
   participants with the following products,
   information, and services.

   *  Information Hotlines
   *  Green Lights Electronic Bulletin Board
   *  Energy Star Fax-Line System
   *  Specifier Reports"
   *  lighting Answers"
   *  Light Briefs"
   *  Lighting Upgrade Manual
   *  Lighting Upgrade Workshops
   *  Green Lights Financing Directory
   *  Lighting Waste Disposal Information
   *  Decision Support System
    *  ProjectKalc
    *  ReportKalc
    *  Directories of Green Lights Allies
    *  Implementation Planning Assistance
    *  Communications Assistance
FEDERAL GREEN LIGHTS

In Federal buildings, approximately 25 percent of the
energy consumed is for lighting. Retrofitting such
systems could result in substantial energy savings,
providing cost-effective options for meeting Federal
energy mandates.

EPAct encourages participation in Green Lights
because it provides Federal agencies with many of the
tools they need to get moving on lighting retrofits.  It
offers comprehensive, up-to-date lighting information
and responsive support services. The program also
has analytic tools to help participants rapidly analyze
lighting systems and select appropriate upgrade
solutions. Additionally, Green Lights helps
participants effectively plan upgrades and publicize
their successes once upgrades are complete.
Who Can Be a Federal Partner?

Green Lights is open to any Federal organization
(including sub-agencies) that has control over its own
        facilities and budget, and has its own management
        structure.  In other words, legislative branch agencies.
        executive branch departments, and administrations.
        bureaus, and services within departments can join. A
        Diverse mix of Federal Partners has already joined the
        .program, including the Bureau of Reclamation. Kelly
        Air Force Base, the National Security Agency, and
        ! several Department of Energy and Department of
        Defense facilities.
         What Do You Agree to Do
         by Joining?

         Federal Partners agree to reduce lighting energy use
         by 50 percent, provided lighting quality is not
         compromised.  In the Memorandum of Understanding
        , (MOU), Federal Partners agree to conduct a variety of
        : energy saving activities in owned facilities:

        ] *•  Survey all agency facilities and identify lighting
             upgrades that will reduce energy use 50 percent
             without compromising lighting quality.

         »>  Upgrade 90 percent of the square footage of
             agency facilities no later than January 1, 2005.

         +  Implement all lighting projects with payback
             periods of less than 10 years by January 1, 2005.

         •  Re-survey and. if necessary, upgrade each facility
             within five years of the initial surveys and
             upgrades.

        i  o  Appoint an implementation director who oversees
             participation in the program.
        r
        i  o  Document annual energy efficiency
             improvements.

          «•  Encourage regulatory reform and  public
             awareness efforts.

          Design new facilities in compliance with applicable
          codes and regulations (e.g., 10 CFR Part 435 Subpart
          A).

          EPA encourages organizations to look at lighting as
        1  an investment opportunity,  not as an overhead cost.
        :  Green Lights asks federal participants to cut lighting
        i  energy use 50 percent, contributing to the  overall 30
          percent energy reduction required by  EPAct. This
          goal is achievable, because Green Lights participants
        I  are accomplishing average returns of over 40 percent
       Green Lights for Federal Participants • Li
43
       Manual • EPA's Green Lights Program • December 1994

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and reducing their lighting electricity
use by an average of 46 percent.
Upgrading Leased  Space

Federal Partners also agree to
upgrade leased facilities. However.
several factors can limit their ability to
upgrade these facilities: the length of
the lease, the cooperation of the
landlord and tenants, and whether the
building is federally owned. The
following MOD agreements take these
limits into account.

*   Survey leased facilities where the
    agency pays directly for electricity
    or where the General Services
    Administration (GSA) delegates
    management  authority
Definitions of Financial Terms*              i

LCC = (investment costs - salvage values) + (non-fuel O&M costs) +
       (replacement costs - salvage costs) + (energy costs)

N"V — LCC witnout oroiect * LCC ..Vitn protect
                                                 I
Savings to Investment Ratio                      .  !

     = PV Savings in energy and non-fuel Q&M costs!	
       PV Costs in investment and replacement costs - salvage values

IRR = [(terminal value of savings/present value of co?ts) !/n - 1], where
       n = the number of years in the study period    |

Simple Payback                                   '

     = Number of years required for investment costs-to equal
       (cumulative energy cost savings - non-fuel costs), not
       considering future price changes or discount rates

* as defined  in 10 CFR Part 436                     ;
 *   Identify lighting upgrades in
    applicable facilities that will reduce energy use 50
    percent without compromising lighting quality

 *-  Upgrade 90 percent of the square footage of
    qualifying leased facilities no later than January 1
    2005.

 Non-delegated GSA buildings are the responsibility of
 the GSA. not the Federal Partner. However, Partners
 agree to work with the GSA to expedite surveys and
 upgrades of these buildings.  If landlords or tenants
 refuse to cooperate. EPA will conduct meetings to
 identify the benefits of Green Lights and to seek GSA
 cooperation.

 Three  circumstances generally preclude upgrades in
 leased spaces:

 *   payback period exceeds the remaining'duration of
    the lease term

 *   lease expires less than five years from the date
    the MOU is signed

 *   Federal Partner does not pay utilities directly
                   EVALUATING  UPGRADE

                   OPTIONS

                   Green Lights encourages Partners to choose
                   profitable lighting alternatives thait are the mosit
                   energy-efficient, thereby maximizing energy savings.

                   As they begin their upgrades, participants use the
                   Decision Support System (DSS) to select the mix of
                   technologies that maximize energy savings.  Next
                   they use internal rate of return (IRR) and net present
                   value (NPV) to measure profits from lighting
                   investments. A Green Lights upgrade is considered
                   profitable if the  IRR is equal fo or greater than 20%.
                   Green Lights chooses this hurdle  rate because of the
                   low risk involved in lighting upgrades and the added
                   benefit of pollution prevention.  NPV calculations help
                   participants select the most profitable project among
                   several that meet the IRR test.  ProjectKalc (another
                  v Green Lights analytical tool) can analyze NPV on a
                   system- or building-wide basis.  For more information.
                   see Financial Considerations, a section of the Lighting
                   Upgrade Manual.
       Green Lights for Federal Participants • Liaht
          44

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.ife-Cycie Costs

 PAct refers to 10 CFR Part 436 to specify life-cycle
ost calculations. According to these regulations,
ife-Cycie Costs (LCC) refer to the total costs of
wning, operating, and maintaining a building over its
sefui life, and are determined by evaluating and
omparing
Itemative building
ystems. For
jased buildings,
ne LCC are
Calculated over the
jffective
emaining term of
he lease. The
nethod of
:alculattng LCC.
specified in 10
Internal rate of
return (IRR) is an
acceptable LCC
method provided
that the IRR (as
described in 10
CFR 436.22) is
greater than the
discount rate as set
by DOE.
DFR 436. is a
systematic
analysis of
•elevant costs — excluding costs incurred before the
analysis ~ producing a discounted cash flow and
calculating the net present value. Future versions of
:he DSS and ProjectKalc will calculate LCC.

Cost-Effectiveness

Building energy conservation measures are deemed
cost-effective if one of the following criteria is met.

•   LCC are estimated to be lower than other
    alternatives.

v   NPV is estimated to be positive.

*   Savings-to-investment ratio is estimated to be
    greater than one.

•   Adjusted IRR is estimated to be greater than the
    discount rate as set by DOE.

^   Simple payback is significantly less than the life of
    the system and the federal building in which it is
    installed.

Investments are not deemed cost-effective for
buildings that are...

*   under a short-term lease, with less than one year
    remaining and without a renewal option or with a
    renewal option that is not likely to be exercised.
                                 occupied under a lease that includes utilities in the
                                 rent and does not provide a pass-through of
                                 energy savings to the government.

                                 scheduled to be demolished or retired from
                                 service within one year or less.
 FINANCING OPTIONS

: Besides third-party financing and traditional
 procurement routes. Federal agencies have several
 options for financing lighting upgrades. They are:

. *  utility financing
 *•  energy savings performance contracts
: *  Federal Energy Efficiency Fund

 The Federal MOU includes a financial disclaimer
; stating that "both parties agree that the commitment
; to survey buildings and complete lighting upgrades is
\ contingent upon the availability of appropriated funds
 or third-party financing resources."
                              Utility Financing

                              EPAct authorizes agencies to participate in utility
                              programs that increase energy efficiency, conserve
                              water, or manage electricity demand.  According to
                              EPAct, agencies may accept rebates or other
                              incentives to increase energy efficiency and may not
                              be denied them if they satisfy the criteria other
                              customers must meet. Agencies may also enter into
                              negotiations to address any unique needs  of their
                              facilities.
                              Energy Savings Performance
                              Contracts

                              Energy savings performance contracts (ESPCs) are
                              also authorized by EPAct. ESPCs are contracts with
                              energy service companies that guarantee energy
                              savings to an agency and require annual energy
                              audits. The contractor ir urs the costs of
                              implementing energy savings measures — including
                              the costs of audits, equipment installation, and training
                              - in exchange for a share of the energy savings. The
                              head of a federal agency may enter into these
                              contracts to achieve energy savings and benefits.
                                                        The term - which may not exceed 25 years -
                                                        conditions of any government payments and
                                                                       and
       Green Lights for Federal Participants • Lighting
                                                45
                              iual • EPA's Green Lights Program • December 1994

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 performance guarantees are specified in the contract
 Aggregate annual payments to utilities and contractors
 cannot exceed the amount an agency would have paid
 for utilities without an ESPC. Additionally, Federal
 agencies may incur debt to finance energy
 conservation measures using ESPCs, provided
 guaranteed savings exceed payments.

 To facilitate the selection of contractors, DOE has
 developed an annually-updated list of qualified energy
 service firms. Federal agencies are required to use
 contractors from this list.
Federal organizations that make the commitment to
Green Lights are profiting by reducing their energy
consumption and electricity bills, improving lighting
quality, and increasing worker productivity. Ely using
energy-efficient lighting, they are also reducing the air
pollution caused by power generation (particularly
carbon dioxide, sulfur dioxide, nitrogen oxide, and
heavy metal emissions).  As one of the first market-
driven, non-regulatory  programs sponsored by EPA,
Green Lights is revolutionizing the way America
cleans up the environment.
 Federal Energy Efficiency Fund

 The Federal Energy Efficiency Fund was established
 by EPAct to provide grants to assist agencies in
 meeting its requirements. Guidelines for submitting
 proposals were issued on June 30, 1993.

 Funds have been appropriated through 1995 Up to
 36 million was available for fiscal year 1994, and up to
 $50  million is available in fiscal year 1995  These
 funds will be distributed to agencies based on a
 combination of several factors:

 *  cost-effectiveness of project

 *  amount of energy and cost savings anticipated

 *  amount of funding committed to the project bv the
    agency

 *  the extent to which proposals leverage financing
    from non-Federal sources
FEDERAL AGENCY ACCOUNTING
REQUIREfl/IENTS

To encourage energy efficiency, EPAct mandates that
some of the energy and water cost savings remain
available to Federal agencies. An amount equafto 50
percent of the cost savings (from utility rebates or
ESPCs) remains available for additional energy
efficiency programs, particularly at those facilities
where energy savings are achieved. To maintain
these savings, agencies must establish a fund and
maintain strict financial controls, documenting savings
realized and expenditures made. These records must
be made available for public inspection upon request
      Green Lights for Federal Participants • Liohtino
                                               46

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NOTES:
       Green Lights for Federal Participants • Light    47     yianual • EPA's Green Lights Program • December 1994

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GREEN LIGHTS
A Bright Investment in the
Environment

Green Lights is an exciting and innovative programs
sponsored by the US Environmental Protection Agen-
cy (EPA) that encourages major US corporations and
other organizations to install energy-efficient lighting
technologies.

Organizations that make the commitment to Green
Lights will profit by lowering their electricity bills,
improving lighting quality, and increasing worker
productivity.  Thesy will also reduce the air pollution
caused by electricity generation.

For more information contact:

Green Lights Program
US  Environmental Protection Agency
401 M Street. SW (6202J)
Washington. DC  20460

Green Lights Information Hotline
(for program, technical, and software support)

»  (202)775-6650
Fax (202) 775-6680

Green Lights Ally Information

»  (202)293-4527
Fax (202) 223-9534

Energy Star Fax-Line System

S  (202)233-9659
Green Lights for Federal Participants is an appendix
to the Lighting Upgrade Manual.  Other documents in
the Manual are listed below.     '.

Lighting Upgrade Manual

PLANNING                   ;

«   Green Lights Program
-«   Implementation Planning Guidebook
«   Financial Considerations    ;
•   Lighting Waste Disposal
••   Progress Reporting         '
»   Communicating Green Lights Success

TECHNICAL

•   Lighting Fundamentals      I
«   Lighting Upgrade Technologies
«   Lighting Maintenance       \
•   Lighting Evaluations        '
•   The Lighting Survey
      To order other.
      documents or appendices
      in this series, contact the
      Green Lights Hotline at
      (202)775-6650. Look in
      the monthly Green Lights
      Update newsletter for
      announcements of new
      and relevant publications.
                                                                     EPA
                                                               IW Green
                                                                   Lights
      Green Liahts for Federal Participants . i
                                         48

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    In order to maintain consistency and fairness among program participants, this Memorandum of Understanding may not be changed.

                                     Memorandum of Understanding Between
                                The United States Environmental Protection Agency
                                                        and
                                                  Federal Agency
I. Common Agreements and Principles








Computers Program.  Etther or both of those programs may be entered by signing addenda to this Memorandum of Undemanding.

                                                        'ightin* ^ ""•""• P"*-* ** «-P-*~ nsiuce gove_
D. Federal Partner and EPA agree that energy^mciem lighting can maintain or enhance lighting quality and ean improve employee productivity.
                         agree thai :communicating Farmer's commteents (as satsd in .his MOU) to the public demonstrates:
                     of Federal Partner for die environment.
         • the vitality of the free enterprise system in reducing costs, and
         • me capability of voluntary programs to achieve national goals with minimal regulation.

                                              confidenM in *• credibility of *e Green

                                                                                                                 Water
II. Federal Partner's Responsibilities

                                                       • L> 102-486> authorizes ft**-«P— » P^cip^ in the Green Lights
                                                                                 Pollution *»*«*» Act (42 U.S.C. 13101)
   fc7 Att     TrLT^n3™1 *tl ^^ 0rdeF 12902 ^ Secsi011 543 of *e National En«sy Conservation aSKl
Polwy Act (42 U.S.C. 8253). as amended by the Energy Policy Act of 1992, provide authorities for Federal energy
                                 ^ °'?eratioMl conttoj of «™ or •" of to fteBWet. and farmer agrees mat te membership in Green
                               SUborgsnKanons <«*» » «**««ita. divisions, campuses. «B.) over whkh it can and/or doTs «««»
                                       e square footage tally on Appendix A. Federal Partner agrees to include ail facilities .owl
                                     rn-  Ceral ^amWr agreea W appoint a «"*«• ^"^"""ve of the organization (designated on
    p™                            Director- Th« Green Lights Implementation Director will be the person responsible for ensuring
Serr^naL^^rlSS rn   P   IB cominitmems « ««« ™ *« MOU. and Federal Partner agrees to assize aumority to the
Implementaoon D.rector needed to execute that responsibility.  The Green Lights Implementation Director's responsibiHties include:
                                                   49

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             • estaeusning ana overseeing Green Light Farmer's implementation plan, which includes the securing of personnel
               and financial resources, and  the scheduling of upgrade projects.                              :
             • directing Federal Partner's lighting upgrades.
             • cooirdinating Federal Partner's participation in Green Lights activities.
             « facilitating communication with the Green Lights Program Office at EPA. and
             • annual reporting to EPA of Federal Partner's lighting surveys and upgrades.                    1

 Federal Parmer agrees to notify EPA in writing within two weeks of any change in the designation of the Green Lights Implementation Director.

 C. CoasmtHkationg Director. Federal Partner agrees to appoint a representative of the organization (designated on Appendix A) as Green Lights
 Communications Director. The Communications Director will direct Federal Partner's communications effort to ensure (as deemed appropriate
 by Federal Farmer) that the organization is properly  recognized for its environmental protection achievements through Green Lights, and. in
 addition, to educate ail employees and the general public about the Program. Federal Partner agrees to notify EPA in writing within two weeks
 of any change in the designation of the Green Lights  Co>ni:iuitk3uons
  D. Staff CarasmfaaisK. Based on the experience of Partners who have already joined the Green Lights Program. Federal Partner should anticipate
  devoting a combination of internal (staff) and external (consultant/contractor) personnel resources at the approximate level of I  person-year for
  every 5 million square feet of facility space, for the purpose of surveying buildings, specifying upgrades, supervising upgrade installations, and
  managing other aspects  of Federal Partner's  participation in Green Lights.  Federal Partner agrees to provide adequate staff to fulfil! the
  commitments it undertakes in the MOU.

  E. FErandaS Comaatment.  Federal Partner recognizes that, although energy-efficient lighting upgrades are highly profitable (typically earning
  20-40% post-tax rates of  retumj. an initial investment of S0.5Q-2.00 per square foot (depending upon existing equipment, purchasing strategy,
  and scope of the lighting upgrades? will be required on average to implement its participation in Green Lights. Federal Partner agrees to allocate
  each year sufficient funds  (or secure third-party financing) to allow for the investment in energy-efficient lighting to meet its commitments under
  this agreement.                                                                                       >          . •

  F. Energy-EJftitient Lighting Upgrades (terms in bold defined at Appendix B).



Federal Partner agrees to:                                                                                .
            ° survey the lighting in ail of the square footage of its eligible facilities.                           j
            ' consider the full range of lighting technology, design, and maintenance options that can reduce energy use. and
            o upgrade the lighting with the set of options that, taken as a whole on a facility- aggregate basis, maximizes energy savings and
            tot also (I) reduces lighting  energy use by 50% and (2) meets Federal Partner's lighting quality objectives.
            « maximize energy savings while meeting lighting quality objectives: where lighting quality concerns prevent energy (eductions of
            5056 or more .  Partner agrees to maximize energy savings while meeting quality objectives.       ' ',    '
Federal Partner agrees to complete no later man January I. 2005:                                            :
            « lighting surveys of 100% of die square footage of its eligible facilities, and                                             .
            » upgrades of 90% of the square footage of its eligible facilities other than those that are no-upgrade facilities.
            •  projects with payback of less than 10 years, using methodologies for estimating payback consistent with Section 544 of the
            National Energy    Conservation Policy Act (42 U.S.C. 8234) and implementing regulations at 10 CFR Pan 436 Subpart A ("A
            Methodology for Life Cycle  Cost   Analyses).                                                ',    '.   .           •

The following is a recommended implementation schedule:                                                  ,
Cumulative Percentage of Squire Footage
End of
Year
1
3
5
Completed
Surveys
5%
90%
100%
Completed
Upgrades
1%
40%
90%
                                                     50

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                                                                            criteria
                                                                               morc *• flve yeara ater *• *• *is MOU
                                      ^f ?"*•  Notw.ilhsonfn8 P^P" H.F. if Federal Partner's facilities are comprised of more
                   ,.                (less than 5 years remaining) leased space. Federal Fanner agrees to:
                « survey at least 5055 of its short-term leased space.

                                 l0I "ghlinS technoio«y- desisn. and maintenance options that can reduce energy use and




                                                                        VkleS a P&ybSCk ffl™ shoner *"" *• — «» term

                                                                        of te
             neaonA            !Msed «V *e Generai Services Adminisnation (GSA) »nd in which
             n^tgcrnentauinonty has been delegated by GSA to Federal Farmer. Federai Partner agrees to neat such buildings us in paragraph
                                                          agree m« space managed by GSA without deiegadon « Federal Farmer

                                                                     FCdeni Pa™e^-» - ^ -* GSA in good ft* c,
                                                                                              Panner WSfor



   H.  Qukk SUrt. Wmin 180 days of signing mis MOU, Federal Partner agrees to-


                                                                    g UpgmSe Whh "ctakil ««l»«tai ft« KPA. if needed.
                                                                    «»nWP« wiil do « *««"«ton upgrade of at least 50%
                                              0                                         -
                                      upgrade budget. EPA agrees to provide assistance with budges estimation, upon PsdenUPtrmer' s

                                               "ick^ff meeting.  EPA agrees mat it will provide materials, orientation informatien.
                                            2? networking ideas at or to mis kfctoff meeting. -FedemS Fanner agrees that all pam of
                                                                       envimrmScompiiance. humanSrees. o£L
upS^cSS^e^l^rSo TSf (ft R(^nW«" fc**)- EPA and Fedmi Partner 8gree that fecslitiei m which

Sti^^S.^Tn I1ff JJ'."1   J"1 to ""^^ arad- accordin8 " *• ^^
                                          o

          i.n             J'i^.^"1^ J"1 to ""^^ arad- accordin8 " *• ^^
    suivey wouWc^Sn^ thwro additio^ m^^OT w^^
    in a thorough manner.       waiDonai measures are warranted in r, previously upgraded facility, provided mat me earlier upgrade was done
    a,                                                                             "
    Pinner agrees to submTrepom at least anSTi             °f MCh hghOng ""^ "^ Upgnde projecl *«
                                                                     ievemems.

    Federal Partner is encouraged to submit this information to DOE's Annual Report on Federal Eniny Management.




Fanner Memorandum of Understanding 10/94
                                                51

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               MB. Fedeni Farmer agrees to design ail
               IFR Pan 43$ <;.•>.«.» A	•  _.,
                                                                •«
                 —— -   i ii "« • «*4*e**o* 4HlEdi
•HCSUXBO to 10 CFR Part 43S Suboan A. as renu^r»ri hv in    u/i.^ —™~t"—«—» "•»« «^vi»l**«"s coaes ana reguuaons. vriai panscajsg'
mmnufaeamng or commerciai or indusmai praossin*FV»deni pi*  ^^ desi8nins ne* ''Shoag systeass in areas that are not intended for
lighting energy stanianis. defined as follows:               «nner runner agrees to at least meet (and attempt to exceed) trie most current
                                                                 -'•   '"                       '
                                                            ' com*iiance *«h *PPiKafaie code* and reguiations. vrrtfa paraeote
                                                             deM8nins ne* "snoas systems in anas that are not intended for
          . if no new IIS stanoatd
                                                                   *
                                                                            issued). M ASHRAE/ffiS 90.M9H9
           *• ASHRAE/Q3 90. 1

Federal Farmer agrees that ail new leases that it signs
            -                                 in*
                                                                                        ****** «««"
                                                             ,
                                                           » lesser or lessees lasting 5- yews or longer will be treated as '
L,           .   eeause o te ojnnnuing improvement m and
re-survey niaiiries «t reanalyze opsons « all eligible fadiiuTno
tot the teiluy was a 'no^pgrade facility."  Federal PannTr aRreeTt
exist withm fivc years of the-re-survey.                   *"** to

Mo Employee Eduction.  Federal Fanner agrees to edueaiE
lighting a*d. . *e extern mat . possAle and consent wJ
their homes.
N.
                                                                                        •««*««. F«ler,t Farmer agrees Je
                                                                      ***** comPiennS an UP8"^ at that facility or detemnmng
                                                                    opnons that meet the Green Lights upgrade criteria that then
                                                                                 environmencU ^vantages
                                                                         ra encourage employees to purchase such products for
                   Federal Farmer agrees to cooperate with EPA *«„«.   u.
          of ener,gy^ffScient lighting in general. TO, couW tactetofei .^ ra'Se PUbHc awareness ^ *? Green Lights Program and of
Ceases and their distribunon to the media, employees, o^r Gre«fu^         * $ ""P"8™11 of «««• «^i«. advertisements, and press
Fanner agrees to provide at least one case study to ^A™ the^S of S ^^^"^oT^1"^ V™**3*"*- ^ »« gwenl public.  Federai
 O. NonoEndcii^sexaent. Fedeni Fanner agrees that    '  '
 publicity relating » itt participation in the Green Ugh
 *» commit to insallenergy.fficient lighting.
 P.  Refuiatorf Reforra. Federai partner agrees to work with
 the widespread adoption of energy-efficient lighting.
 the widespread adopoon of energy-efficient
 authority.
                                                                        f"?™n- «» «f *•» Green Ughtt Prcgimm logo,

                                                                                    ^
                                                              **" My unjusdfied ««8rtMoiy. administzative. and other barriers to
                                                                mmOtti addirionai ™**™*™ and incentives tim will encourage
                                                                   . consistent with overall Federai policy and l-ederai Partners
 Preaervasion Act. as amended.
OL Associated
                                                    Bm te ««t"Ked to underake any actions that would violate the National Histene
 A. The. EPA strongly encourages and recommends that Partner*
 as heating or air conditioning.  EPA experience has show
 sigiuficandy impact and reduce HVAC reqairements and

 IV. EPA's RRttpoimbflittet

 A. Liaison. EPA agrees to designate a single liaison mint fa
 weeks of any change in the designated liaison. TTie liaison is-
 DC 20460: PHI :ro2-233-oi2o: FAX
 B. Technical Support. EPA agrees to assist Federal
             1. H?A agrees to ptovide ID Federal P
            efficient lighting and implementation
                                                                     Hghthlg Up8nde projecxs prior * omer ***** ****«>* ™&
                                                                         accomplisned fn>m  "rt** improvement projects can
                                                                                             '
                                                                     f"8nun. and will attempt to notify Fedend Partner within 2
                                                                     *""** U'S' EPA (6202J): ^01 M Street- -
                                                               TOW cost-effecjive "ghting technologies in the following ways:
                                                             summary of *« bea available infonnation about energy-
            use of technical tool, developed by the Green UghaTPn.^

                                                    52
                                                                                    anaiyticai techniques, anol the

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             i!^  *^   ^mg "aiysis "*""* ^ned »' t«lP F«teni Panner conduct thek iigiuiag surveys.
        ««8Pfctt *«r options analyses. and choose the most enerfy-efficietti and profile iightmg upgrade paeteute.
        *A »^f« » ">*»«« G«tn Lights Allies Programs in which JigtahT.n^aS iS^
               untaes. lighting equipment distributors, and lighting surveyors agree to follow specific entera.
                                                                                             .
                                                 P«**«es mtonmnoa pragma that will an* iigtttmg products on a
                              ftumer agrees mpnwide Federal Parrot wi* a ^


                              F^al Paraaer whh * ""P"*"** dkeemry (updated sessi-anraoity) of milky reiaes
                            In mddioa^.  EPA agrees se pnmie a siraimriy updaa^d direese^ of nattily firsaneisi

                                 CompMie* ««» enet«y ^^ companies^ dm provide finding for ene

         T-BRAagrees 0 operae infcnratjomi hodina for Federal Partner m provide Federal
                      to prwnoemodel Requests for Proposals (RFPj) for Ftdesai Puraen wishing so proeare iighi^t pnxiuos asd

                               S         ^'JliS*iPannCrlS """^ EPA 88teeS " un!iemte «"•)« »nd anmlyses for pan or ail of Federal Partner's facilitte
cotragem upon die compleoonof xpame mnagency agreements that contain sufficient funds to support such activities by EPA's expert «nu

V. Use of EPA-Dfrreloped Materials


A. EPA Mmlerials. Bothparries to this agreement agree mat EPA-developed publications are a valuable tool in educating the public abom fee
pollunon-preveraion benefhs of energy-efficient lighting and me Green Lights Program.                      ^^
                                                        "* ** Gree° Ughls Panner io*° for ttse on "» Product-specific matemls
                             hv*     h        htS Pt0gnin- Fedenl Panner agrees *« *PP"Pri«e use of me EPA Gr^n
         gmn togo a encouraged by EPA. but that such use does not constitute EPA's endorsement of Fe' ,Tal Pmrmer's products or services
                                                    53

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C.  EPA Materials. EPA agrees to provide to Federal Fanner, at Fanner s request, available camera-ready negatives, mechanicals, and other
'iirectly reproducible material, from which Federal Farmer can create:                                     ;
            1.     Green Lights brochures. Light Briefs, and video
             •  Partner's failure to nuke adequate progress on lighting upgrades,  to the point where it is evident that Panner will
               not be able to fulfill its upgrade commitments as stated in mis MOU. and                   <
            . •  Panner's use of the Green Lights logo in an inappropriate manner.

  Because public confidence in the cred&flay of Federal Partners1 achievements is so important. EPA will make a best-faith effort to assist Fedesml
  Panner in meeting; all of the goals of this MOU.                                                     '

  C. Each pany's coramionenB will be subject to any legal restrictions that may apply.                     J
                                                                                                l
  D. EPA agrees ttait information provided by Federal Partner to EPA wild be treated pursuant to EPA's public information regulations under 40
  Code  of Federal Regulations. Pan Two.

  E. Both pareas agiiee that me commtimem as survey buildings and complete lighting upgrades is contingent uponithe availability of appropriai^
  funds or mini-parry financing resources.                                                            ;

  The undersigned hereby execute mis Memorandum of Understanding on behalf of their parries. This Memorandum takes effect when signed by
  bom parties.                              •                                                    I

  For  the U»S. Environmental Protection Agency (EPA):
   Paul Stoipmam. Director
   Office of Atmospheric Programs
                                                    On:

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For Federal Agency:



	—	—.	 On:.
Name (Please Print)
(1) the signed MOU in its emrrry including        ces        a.ix n\
of company logos in Green Lights bnxhures. .SteerTandttoiS.?!?^1*"1**1* Ve™On °f y°UF Or8an*2ati°n's »°S® (EPA uses colhfes
is given the opportunity to review and approve the loco use > w^W r    f^1"!1* orSanizaaon ts ^^ focussed on. thai organisation
401 M Street. SW: Washington. DC 20460                        Gree" Ughts Branch: US Enviiomnental Pro««tion Agency (62Q2J):
Thmnkyou. Welcome aboard.           "                     :
                                                     Federal Agency
Appendix A:  Please enclose the following information with the signed MOU:

Secretary/Administrator's Name:	               •

Tide:.	
Address:.
Telephone Number:
 Pkue identify your Green Lights Implementation Director                                «_   ;H|lfwH.
 Comrnunkations Director:                                                           pte"Sffi   ldeanfy
 ™.	__                                       ^_

 Address	
        	!	-—__	;	_„„.                             Address
                                       ,Fax	        '   	


                                                                                   Fax
 What is the Nature of Organization's Business	_.         glC Code

 Approximate number of empioyees__Approximaie number of facilities	

 Headquarters location                                      ;

 Approximate square footage:


     Oflffce	—— Warehouse                           Health Care_

     Indusmal/Manufacturing		 Lodging (hoe|S. donnitories)

     Education (classrooms)		 Assembly (auditoriums)

     Food Sales & Services	^^

     Other<          )	
                                       please specify


                                                55
                                                                Parking Garage

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   Is die onnuzanon signinf this MOU a csmponem of aoAer o
                                                                ?  If ». pie^ provide the «a»W ft* parent organisms
What is the first: day of your organization's next fiscal year?.

Who referred you m Green Lights?

          terminating
             Fed*
ewers into force an!
lessor and less^. are di
                                                                       *-
                                                                         ««o force.  Space that Federal Fanner leases under

                                                                                       *" "fcligiWe ^^ Ml -(3) ri!
                           °e!i»ibie faciK      FPA                                 » five years from the date this agreement
                           er' New €0^00?  enCOUn8e$ Fcderai Panner • ine"«te ^««es outside the U.S.  New teases, as
                                                     energy^ent pnxiuots and *e tangiNe. butdifficuit . m^re. be^fits
Lights partners to include measurWwtoin «
indtviduai nuaara
distress may quaiify
                                            «i


                                                                              ^ ** «*««. EPA doe, not expect Greea
                                                       *                  .  EPA defines a nor. sast-sffecrive nwmsure as anv
                                                  ra« of ««^ of less than tweive percentage points. (Organizations in financial
                                                                — ai« detenninanons affe«ing| iighdng ouaiit,. and puannty
                                                                                                                   -* «

     that such cireumsances are rare        obJ««ves. such a

                                                         "J" — perate in the proposed ihstaHation program and in the
     Panner. If. lowing good-fiai* ^om inu^pln ofT^eS tZFS££?? ?' ^^ «**«*•,««** le for FederaJ
     prov.de EPA ^ . opponunity . ^ the ,L,ort, c^nuo^

                                                                                           ^  i
     division of financial benefits 
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Federal Agency
                                    ency



       ^'">^-^~±i^rs^^^
   zm or IMMMH of ma „, f -r  a"aifs «teP""««. environment

   "na^es a^S^S^Sv^ """ *"""*- """*
 " '  "              6. _
-- _ _ _.     - : — • -- — - - __ 11.
_                 -- —    __        ' —    — — — — ____  16...
                  7                         —
                  - - - : -- _  12. _
                  -- —      -^      ~ - ~~"=- - ! — ! — —       17.
4- — - -                    ~~
- — , _ _..  _   ~~~ -- — - - -     14.
                         57

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           APPENDIX C.




ENERGY STAR EQUIPMENT INFORMATION
            58

-------
                                EXECUTIVE ORDER #12845
                             Requiring Agencies to Purchase
                         Energy Efficient Computer Equipment


      Whereas, the Federal Government should set an example in the energy-efficient operation of its
facilities and the procurement of pollution preventing technologies;

      Whereas, the Federal Government should minimize its operating costs, make more use of
taxpayer provided dollars and reduce the Federal deficit; and

      Whereas, the Federal Government is the largest purchaser of computer equipment in the world,
and therefore has the capacity to greatly accelerate the movement toward energy efficient computer
equipment;

      Now, therefore, by the authority vested in me as President by the Constitution and the laws of
the United States of America, including section 381 of the Energy Policy and Conversation Act, as
amended (42 U.S.C. 6361), section 205 of the Federal Property and Administrative Services Act, as
amended (40 U.S.C. 486), section 152 of the Energy Policy Act of 1992 (Public Law 102-486), and
section 301 of title 3, United States Code, and to ensure the energy-efficient operation of the Federal
Government's facilities and to encourage the procurement of pollution-preventing technologies that will
save taxpayer money, reduce the Federal deficit and accelerate the movement to energy-efficient
designs in standard computer equipment, it is hereby ordered as follows:

      Section 1.  Procurement of Computer Equipment That Meets EPA Energy Star Requirements for
Energy Efficiency.
       (a)  The heads of Federal agencies shall ensure that,  within 180 days from the date of this
order, all acquisitions of microcomputers, including personal computers, monitors and printers, meet
"EPA Energy Star" requirements for energy efficiency. The heads of Federal agencies may grant, on
a case-by-case basis, exemptions to this directive for acquistions, based upon the commercial
availability of qualifying equipment, significant cost differential of the equipment, the agency's
performance requirements and  the agency's mission.
      ^ (b) Within 180 days from fee date of this order, agencies shall specify that  microcomputers,
including personal computers,  monitors and printers, acquired by the agency shaE be equipped with  the
energy-efficient low-power standby feature as defined by the EPA Energy Star computers program.
This feature shall be activated  when fee equipment is shipped and shall be capable of entering and  '
recovering from fee low-power state unless fee equipment meets Energy Star efficiency levels at all
times. To fee extent permitted by law, agencies shall include this specification in all existing and
future contracts, if both fee Government and fee contractor  agree, and if any additional costs would be
offset by fee potential energy savings.
       (c) Agencies shall ensure feat Federal users are made aware of fee significant economic and
environmental ^benefits of fee energy-efficient low-power standby feature and its aggressive use by
including this information in routine computer training classes.
       (d) Each agency shall  report annually to fee Ger ,ral Services Administration on acquisitions
 exempted from fee requirements of this Executive order, and fee General Services  Aministration shall
 prepare a consolidated annual  report for fee President.

       Sec. 2. Definition. For purposes of this order, fee term  "agency" has fee same meaning  given
 it in section  151 of fee Energy Policy Act of 1992.

       Sec. 3. Judicial Review. This order does not create any  right or benefit, substantive or
 procedural, enforceable by a nonfederal party against fee United  States, its officers or employees, or
 any other person.

                                        59

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                    United States
                    Agency
                              rotection
                    Air and Radiation
                    6202J
                                          EPA 430-1^3.549
                                          November 19S3
                     Energy Star  Computers
Introdudng^                             i.     <
The Energy Star Computers  Procjram
    Pmteafon Agency
 (EPA) promotes energy
    efficiency because
  electricity generstipn
 contributes to air pollu-
  tion, Inducing 35 per-
       mit of all US.
   emissions at caioan
 accounts for 75 percent,
   and38pemehtofail
 US. emissions of sulfur
   dioxide ana nitrogen
    oxides, respectively.
  By using more energy-
  efficient equipment in
  our homes, offices, and
      factories, we can
  reduce this pollution—
    while saving money!
                    Why Enersy-Efficient Computers?
fasust-growing eieeeicity
         lecaicity
            action
                     .is not taken, this could rise
                     to 10 percent by the year
                     2QQQ. Ironlcaihr. much of
                     tiis eiesmcny is wasted:
                     nresarch snows that most:ot
                          oersonai computers
What Is EPA Doins About It?
                   are on, they
                   in use — ami 3Q-4ff perein£
                                        on weekends.
                     tiffliading nanufecturar
 desktop csmoutersand 9Q
 peasnt at all.laser printers
      iesktep computers.
  *non'rtois, ornrimers tnat can
  automatically power-down to
  save energy when they are
  wscbe&ig used. This "sleep"
  feature could cut a product's
  annual electricity, use dy
  about one-naif.
    Consumers will easily
  recognize the new, more
  efRcJent systems because
  they will be identified by the.
  EPA Energy Star™ logo
1  shown here.
                     Euaigy SCarnK-&eainiff attics equipment
                eo
eoo^electrntye^yeartopowrVeimoatftaw
Hampshire, and Maine,, cat electricity tttits tyr^M-
Ron, and reduce GOi pollution equal ito too Bdissjans
front 5 million autos.

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                 An EPA Energy Star  '

           computer can save users a

      great deal of money by going to

sfeep. And according to manufacturers.

  a majority of their products will have

    this feature within just a couple of

 years. This added functionality will be

  invisible to the user, both in terms of

    performance and in terms of price

 tag—making it noticeable only by the

     EPA Energy Star™ logo—and, of

      course, the lower electricity bill.
                                       How Much  Can  My  Energy Star Save?*
                                                      Conventional System
                                                      On all the time
                                                      Annual Cost $165
                                                             *As compared to a typical
                                                             computer, monitor, and laser
                                                             printer an all day and night,
                                                             assuming 23S W, 8e/kWh.
                                                             Does not include heat gain
                                                             from computer equipment
                                                                             Energy Star System
                                                                             On ail the time
                                                                             Annual Cost $84
Who Buys Enersy Star Computers?
   EVERYONE! Everyone
who values high perfor-
mance at a lower cost—and
the extra satisfaction of
owning an environmentally
superior product.
   The U.S. Government
—the largest buyer of com-
puter equipment in the
world—will take the lead in
purchasing Energy Star
equipment.
   President Clinton, in an
Earth Day address empha-
sizing the link between the
environment and a growing
economy, released an
Executive Order directing
U.S. agencies to purchase
only desktop computers,
monitors, and printers that
 meet EPA Energy Star
 requirements for energy effi-
 ciency—provided that they
 are commercially available ;
 and meet the agencies' per-
 formance needs. The
 Executive Order took effect
 in October 1993 and will
 save taxpayers $40 million
' annually. In fact, EPA itself
 will save enough money
 using the new, energy-effi-
 cient products to pay for the
 Energy Star Computers pro-
 gram several times over-
 making it one of the most
 cost-effective government
 initiatives in history.
   ERA is also encouraging
 public- and private-sector
 consumers to buy product!?
                                                           bearing the Energy Star™
                                                           logo. Many of these organi-
                                                           zations are already part of
                                                           EPA's Green Lights program,
                                                           and are asking EPA for advice
                                                           on other smart energy-effi-
                                                           ciency investments.
                                                              Iri addition, electric
                                                           utilities will purcnase
                                                           Energy Star^bearina com-
                                                           puters for their own use and
                                                           will encourage companies in
                                                           their service territories to do
                                                           the same.
                                                              If your organization is
                                                           interested in learning more
                                                           about maximizing its pur-
                                                           chasing power to help the
                                                           environment, contact EPA
                                                           about available Energy Star
                                                           products.
                                                                                                Energy Star
                                                                                                Turned off at nigf
                                                                                                Annual Cost $28
    PQIUJTISM PSEVENTE

For more information abci
Energy Star Computers,
please contact
Manager
Energy Star Comouters
U.S.EPA{62Q2J)
Washington, DC 2Q46Q
fax: 202 775-6680
Or call: 202 775-6850

For more information by fe
(available 24 hours a day),
call: 202 233-9659.
ggr? i
                                           61

-------
                      United States
                      Environmental Protection
                      Agency
                               Air and Radiation
                               6202J
                                        EPA 430-K-94-006
                                        July 1994
                                           Purchasing An
                         Energy Stai^'Computer
                                                    EPA POLLUTION PREVENTER
 Cbmputersjprpgramr
   is a. partriershiir
           ! r •.
   effbrtwijihdher
 computer? jidustrp

   to promt jtediifc

   introduclion-of
   energy-effiici enfc

personaLcokjnphters,
   monitors|.aud.
 printers; Reducing
         - |!      5
energy co nsum ption

 cairhelp.toi jcoi nbat

smog^acidrr^ir ^and-
 globaL warmin g: fay
 reducing emissions

   fronrelectricity
generationr-lBy using
efficient eqi nptnent

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        *!  !   I
    offices? j^uic

 factories; WCM ran

 bothTimproyethe-

 environmeiitraijc/.

   savetmoiiiey
   What is Energy Star

        Equipment?

 "Energy Stars" are energy-efficient
 computers, monitors, and printers
 that save energy by powering down
 and going to "sleep" when not being
 used. An Energy Star computer has ail
 the performance features of a regular
 computer—it simply has the addi-
 tional ability to "power-down." These
 energy-efficient machines save money
 on electricity bills and reduce pollu-
 tion, improving your bottom line and
 the earth's environment

 EPA has signed partnership agree-
 ments with industry-leading manufac-
 turers who sell more than 75 percent
 of ail desktop computers and 90
 percent of all laser printers sold in the
 United States. These companies have
 introduced more than 2,000 desktop
 computers, monitors, and printers
 that have earned the right to bear the
 EPA Energy StarSM logo, shown at the
 top of the page.

 Computer equipment is the fastest
 growing electric load in the business
 world, and  energy use by computers
 could double by
 the year 2000.
 Ironically, much
 of this energy is
wasted: re-
search shows
that most of the
time personal
computers are
on they are not
 100 New Computers and Monitors

Non-Energy Star          Energy Star
                                         $0/year savings
 actively in use—arid 30 to 40 percent
 are left running at|night and on week-'
 ends. By the year 2000, Energy Star
 equipment could save enough electric-
 ity to power Vermont, New Hampshire,
 and Maine for a year, cut electricity bills
 by $2 billion, and reduce CO2 pollution
 equal to the emissions from 5 million
 automobiles.     i

         Real Savings

 Energy Star computers are available at
 no additional cost,! and a single Energy
 Star computer and; monitor can save
 anywhere from $7\to $52 per year in
 electricity bills. If ypu notice computers
 and printers left on when leaving the
 office at night and on weekends, your
 savings will be towkrd the higher end of
 this range.       '

 If you add an Energy Star printer to your
 system, you can increase your savings
 by an additional $35 per year.

 For an office environment where one-
 third of the computers are left on all the
 time, purchasing 100 Energy Star PCs
 and monitors instead of non-efficient
 equipment could save you $2,400 per
 year. In addition, Energy Stars generate
	;    less heat, and
                    upgrading your
                    existing equip-
                    ment to Energy
                    Star as it natu-
                    rally turns over
                    can lead to
                    cooling reduc-
                    tions of up to
                    25  percent
                     $2,400/year
                       savings
                                       62

-------
                                                      PURCHASING AN  ENERGY STAR COMPUTER
               How to Find

         Energy Star Products

Consumers can easily recognize the new, more effi-
cient systems because they will be identified by the
EPA Energy Star5" logo. Since there are now more than
2,000 products available from all major manufactur-
ers, EPA is encouraging companies and organizations
to specify Energy Star compliance in all future pur-
chases of computer equipment.

•  If you are a business, ask your MIS or procurement
   official about purchasing Energy Star equipment,
   and look for the Energy StarSM logo in advertise-
   ments and on specification sheets.

•  If you work in the Federal Government, the Gen-
   eral Services Administration has issued  guidelines
   on the acquisition of Energy Star computers. Call
   1202) 519-4860 for a copy.

•  If you need a computer for home, look for the
   Energy Star5" logo on display models in local retail
   stores—if you do not see it, ask for it.
To help, EPA offers a database of available products
which is updated monthly. Just call or write EPA to
receive a copy.

            User Advantages

Besides the cost savings, Energy Star equipment offers
users several key advantages.

•  Energy Star PCs can be quieter since some have
   no fans.

•  Sleeping Energy Star monitors emit fewer electro-
   magnetic fields (EMF) since they are not display-
   ing any visual image when "asleep."

•  Energy Star monitors can also  increase file secu-
   rity since the "sleeping" screen is dark.

*  All Energy Star equipment produces  less heat, and
   thus contributes to a cooler and more comfort-
   able workspace.

*  Energy Star PCs tend to be a less intrusive desk-
   top item since they are usually smaller than tradi-
   tional PCs.
         increased Reliability

In addition, Energy Star equipment may actually last
longer than conventional products because it.will most
likely spend a large portion of time in a low-power
sleep mode. Non-Energy Star computer equipment
left on at night and over weekends may last only 2 to
3 years, but Energy Star computers "sleeping" during
the day and turned off at night could last almost 10
times as long (see graph).
        (2 years)
 ON ALL
THE TIME
 OFf AT
 "ISIGHT
 ENERGY
STAR AND
 OFF AT
• NIGHT
(Source: Dataquest, 1993)
                 (10 years)
                                        (22 years)
^^^^^^^^^•••^^^^^^••^^^^^•^••^^^^••••••^^^•••^•••••••MBaH
By spending time "sleeping," Energy Star equipment can reduce
wear and tear, leading to extended life and increased reliability.


           Which Energy Stair

             Is Right for Me?

Committing to an "Energy Star purchasing strategy" for
your organization is the first crucial step. The second
step is figuring out which Energy Star products to buy.
It is important to realize that not all Energy Star com-
puters are the same, and your choice will depend on
your needs and preferences.

If you operate on a Local Area Network (LAN), make
sure that your Energy Star computer is compatible
with that network system. Most Energy Stars are now
being network tested, but specify your particular
environment—whether its Novell Netware, Banyan
Vines, Windows NT, Lan Manager, or others, to ensure
that it is compatible (see sample procurement lan-
guage on page 4).
                                          63

-------
                                                     PUR'CHA.SING AN  ENERGY STAR  COMPUTER
You also may want to specify certain "user-friendl.y"
features, such as an Energy Star or power managt-
ment "icon", which is easily accessible and gives the
user a quick and simple way to change the "sleep"
settings. Some users may want to set their computer to
go to sleep after 15 minutes  of inactivity, while others
may chooseJIO minutes. Having a user friendly power
management feature to
customize an Energy Star
computer to your own
schedule contributes to
productivity and increases
energy savings.
   What If No
  Energy Star Is

    Available?

If you need an expert
computer system or an
extremely high speed
printer, there might not
yet be an Energy Star
model available. Because
high-end equipment was
designed to give you
maximum performance, it
also tends to use more
power. Until the design-
ers of this higher end
equipment develop
Energy Star models, you
will have to buy non-
Energy Star. The goal of
the Energy Star program is to save energy with no
sacrifice in performance or cost, If you need a high-
end, system to do your job, and there is not an Energy
Star available, then buy what you need.
However, if you are considering the purchase of a
computer with certain specifications and have the
choice between an Energy Star and a non-Energy Star
machine, buy the Energy Star. If both machines have
the exact same performance and are similar in cost,
purchasing the Energy Star system will give you the
additional benefits of saving on your electric bill and
helping to prevent pollution.
         President Clinton's
           Executive Order

In April 1993, President Clinton signed Executive
Order 12845 requiring ail federal agencies to pur-
chase Energy Star computers, monitors, and printers
where commercially available. This order/which
took effect on October 18, 1993, reads in part:

      Agencies shall specify that microcom-
      puters, including personal computers,
      monitors, and printers, acquired by the
      agency, shall meet the EPA Energy Star
      specifications. This feature shall be  ,
      activated when the equipment is
      delivered to the customer and shall be
      capable of entering and recovering from
      the low-power state unless the equip-
      ment meets Energy Star efficiency levels
      at all times.
        Should I Still  Turn My

      Energy Star Off at Night?

Yes. Power-managed Energy Stars will go to sleep by
themselves, but remember that the sleep mode does
not mean "off." Sleeping Energy Stars use less power
                        than when fully activated,
                        But they still draw some
                        power when in the sleep
                        rhode. To save additional
                        energy and increase the
                        lifetime of the equipment,
                        be sure to turn your
                        system completely off at
                        the end of each day. It is a
                        common myth that turning
                        computer equipment off
                        and on  is bad for it; in
                        fact, the exact opposite is
                        true. Turning off your
                        computer at night may
                        actually increase its life
                        because it will reduce
                        susceptibility to heat and
                        mechanical stress, the two
                        leading causes of personal
                        computer failure. The
                        recommended approach:
                        set your Energy Star to
                        sleep when you are away
                        during the day, and turn off
                        the system when you leave
                        ait night.

          What Can 1 Do for
                         i         -      •  .
      My Existing Equipment?

Again, turning off your existing equipment at night is
the easiest and most cost-effective strategy for reduc-
ing the energy consumption :of non-Energy Star equip-
ment. However, if you are unable to turn off existing
equipment or wish to make additional savings, con-
sider retrofitting your equipment with an Energy Star-
compliant controlling device, These devices are fairly
easy to install and can completely shut off the power
to your PC, monitor, or printer after a period of
inactivity or at a specified time of the day.
                                       64

-------
  PURCHASING AN  ENERSY STAR  COMPUTER
                           What to  Specify When  Ordering
                                  Energy Star Equipment
       Energy Star
       Compliant
  ref
Shipped
Activated
  Ef
Network
Compatibility
       Monitor
       Control
  ~ljr  Software
  —I Compatibility
"Provide computer products that meet the EPA Energy Star requirements for energy
efficiency in the requested configuration/' This means that PCs, monitors, and printers
shall be able to enter and recover from a low-power standby mode when not in use. For
PCs and monitors, the low-power mode is defined as 30 watts or less (30 watts for the PC
and 30 watts for the monitor). For printers with speeds of less than 15 pages per minute,
the requirement is 30 watts; and for printers with speeds of 15 or more pages per minute,
the requirement is 45 watts. All high-end color printers must not exceed 45 watts in low-'
power mode.                                                          «

"Ship all products with the Energy Star low-power feature activated or enabled." This
eliminates the need for users to configure the power management feature after delivery
and helps to ensure that the energy-saving feature is used.

"If equipment will be used on a local area network, the PC must be fully compatible
with the specified network environment? PCs resting in a low-power state should not
be disconnected from the network." Many manufacturers are now testing their Energy
Star equipment on networks and can report, for example, that they are compatible on
Novell Netware, Banyan Vines, Windows NT, Lan Manager, and other network systems.

"Ensure monitors are capable of entering a low-power mode when connected to the
accompanying PC".Most monitors cannot power dqwn by themselves, and must rely on
some external input to. trigger their low-power state. This is typically accomplished via one
of the following: (1) VESA Display Power Management Signalling (DPMS), a signalling
protocol that allows a PC equipped'with DPMS to control a DPMS compatible monitor
(both the computer and monitor must be DPMS compatible), (2) the actual shut off of '
power to the monitor via a special plug from the PC (this does not require an Energy Star
monitor), or (3) the use of a proprietary software utility shipped with the monitor. Organi-
zations may wish to specify one approach or the other. DPMS compatible PCs and moni-
tors will provide seamless power management and immediate recovery from the low-
power state, but only when used with each other. PCs that include the power switch
approach can shut off power to any monitor, not just an Energy Star monitor.

System must be able to run commercial off-the-shelf software both before and after
recovery from a low-power state, including retention of files opened before the power
management feature was activated.
What Products are Available?

Vtore than 2,000 products are now available that meet
;he Energy Star guidelines.

Ib receive an abbreviated list of qualified products, call
:he Energy Star fax-back line. Dial 202 233-9659 and
inter #5305 for PCs, #5309 for  monitors, and #5307
or printers.

Ib receive the detailed list of qualified products by mail,
"all fhp Fncrm- 
-------
                        EPA ENERGY STAR
                    Participant List as of February I, 1995
                                                               iPA P9UUTIOM PHEVIEMTER
COMPUTERS AND MONITORS (aumben 387)
 3D Microcomputers
 * A Plus Info
 if Acer/Acros
 Achieva Computer
 if ACMA Computers
 ACME
 •*• ACTech
 Aciiois Electronics
 if Aeuia Technology
 Addtech Computer
 * Adtec
 * Advanced Digital
   Systems
 Advanced Integration
   Research
 •Jr Advanced Intelligence
 Akran Systems
 if Alikris
 Allen Bradley Company
 •Ar AL,R
 Aitima Systems
 AMAX
 if Anibra Computer
 American Business
   Computers (ABC)
 ir American Megatrends
 •*• Anirei Technology
 ANT Computer
 Antecbron  Research
 Apaq Technology
 APF
 ir Apple
 *• Applied Digital Data
   Systems
 Apricot
 ir Aquarius System
 ir Aquaiine
 if Arcbe Computer &
  Technologies
 Area Elecrtrossies Systeim
 * Aspect Computer
 ir AST Research
 ir AT&T Global
  Mbrmatioa Solutions
 Atima Techisoiogy
 ATS
 if Austio Computer
 if-Avaot Computer
 Aak Computer
 if Bankers Systems
 Barron Microcomputer
 Blue Star Marketing
 •sir Bridge Information
 Brother International
  Europe
 Byte Technology
 *• Caliber
 if Canon
 if Capetronic
CTC Technology Services
Channel Electronics
ie Cheer Electronics
CHEM
ir Chien Htm Electronics
Cognisoft
Commas Technologies
Commodore
ir Communication Lab
  International
ir Cumpal Electronics
ir Compaq
ir Compudyne
ir Computer Creations
Computer Dealers Source
 Computer Extension
   Systems
 Computer Management
   Professional
 Computer Tec
 CompuTrend System!!/
   Premio
 Cbmtech Micro System
 Comirade
 Conrac SJektron
 Continental Reaourcts?
 Corion Dodustriai
 ir Cornerstone Imaging
 Corporate Micro Systems
 if CP & G Technologies
 (CSS) Computers, Etc.
 if CSS Laboratories
 CTL   .:
 * CTX Internationa],
 Cube Computer
 T*rCyberStar
 ir Daesun Industrial
 Daewoo Electronics
   Canada
 •*- Daewoo Telecom
 if Daly Computers
 ir Data General
 •*• Data Storage Marikcting
 if DataExpcrt
, '^atavarehuset
 DD & TT Enterprise USA
 if DDI Dynex
 * Delta Producis
 ir Desktop Displays
 Destiny
 if Diamond Technologies
   Indicates companies which have announced Energy Star compliant products
                                  6-6

-------
  if Digital Equipment
   (DEC)
  Dimension Computer
  Display Technologies
  Duich Computer Systems
  it DTK
  it Duracnm Computer
   Systems
  T*r DynaColor
  EFA
  EKM Computer
  Electronic Technology
  Group
  itEbnex
 ElsaGmbH
 EMPaG
 * EPS Technologies
 ^r Epson
 itEquix
 Ergo Computing
 •rfr Essex Monitor Company
 Tir Kverex Systems .
 Evergreen Systems
 •A* Fair Electronic Company
 Fedcom Microsource
 it Kcldworks
 Firepower
 it First International
   Computer
 it Flytech Technology
 it Foshan Wingbao
   Inforrnation Enterprise
 •*• Fountain Technologies
 Fujitsu
 i(t Gateway 2000
 GCH Systems
 Gcnova
 it Glga-Byte Technology
 it GoldStar
 Grand Micro
 Great Lakes Electronics
  Distributing
 Green Labs
 Green PC
 GVC
 Hammond and Hammond
 •*• Hectronic
 •*• Hewitt Rand
 it Hewlett-Packard
Highwave Technologies
HIQ  Computer Systems
  •*• Hitachi America
  it Hitachi European Centre
  Hitachi, Office Systems
   Division
  ffl-Vl Electronics
  Hil
  ie Hyundai Electronics
  it IBM
  itICL
  it IDEA
 it Identity Systems
   Technology
 itIDP
 Ikegami Electronics
 Infotel/Midwest Micro
 itXnmac
 *& Insight Distribution
 Integrated Systems
   Group, jjio,
 Intelleom USA
 ImeUIgent Computers and
   Technologies
 Intelligent Decisions
 Intelligent Notebook
 Interactive Computing
   Devices
 Intergraph
 Icttermec
 <& laternadonal Data
   Systems
 Intra Electronics USA
 itlPC
 it LS.L. Automatisering
 J-MARK Computer
 JTA
 Key Power
 Keydata
 Keypomt
it Korea Computer
it Korea Data System,
•& Korea Electronics
LCC Computers
it Leading Edge
•st Leo Systems
LION America
if Lite-On Technology
it Lhiski International
it MAG lonovision
  ManTech Systems
  Manufacture Technology
   Resource
  it MASS Research
  T*T Matsushita Eiecoic
   IndysxriaJ
  it Max Group
  Max Vision
  •JfcMeeer
  it Memores Telex
  Metrovision Microsystems
  Micron Computer
  MicroNiche Information
   Systems
  it Mierouics Computers
  MlcroPen Computer
             (TX)
 Mini-Micro Supply
 m&o Computer Products
 •i-Mtac-
 it Mltsuba
 it Mitsubishi
 Modem Instruments
 Modular
 Monitor Technology
 MSSI Consultants
 Multimax
 •& Mustek
 MynoE Technologies
 NAI Technologies
   Systems Division
 it Nanao  USA
 National Advantages
 National Microcomputer
 itNCD
 it NEC
 NETiS
 it Ntuei Sangyo
  America/Hitachi
 it Nokia
 Northern Electronic
  Technologies
 Northern. Micro
 itNotthgate
 Northwest Micro
 Ocean Informatian
  Systems
Ocean Interface
Ocean State Computer
  Indicates companies which have announced Energy Star compliant products
                                 67

-------
 Office Automated
   Technology
 •Ar Olivetti
 * Opiiquest
 if Orion Electric
 Osborae Computer
 * Packard Bell
 Paid Pacific Associates
 if Panasonic
 Paragoin Development
   Systems
 Patriot Computer
 PC Channel
 if PC-iExpanders
 PC Pros
 •*• PC&.C
 PC Ware International
 if' Percomp Microsystems
 Perpetual Technologies
 if Philips Consumer
   Elmrantcs\Magaavox
 Pine Tixhnology
 Pioneer Technologies
   Group
 'if Planar Systems
 * Precision America
 if Precision Technology
 if President Technology
 if Primax Data Products
 if Projjjcn
 PSI
 * FT Pembina Oalindra
   Electric .
    QHT Systems
 *QNDC Computer
 if Quantex Microsystems
 if Quest Group
 -*• Qume
 R & S Computers &
   Enhancements
 "*• Radius
 Random
 RasterGps
 if Kegient Technologies
 Reiialogic
 •A-ReJisys
 Repco Data
 if Republic Technology
 Royal Electronic
       .';        «-1i-
 ie Royal Information
  Electronics    ^
 if Sampo Technology
 if Samsung Electronics
 ^r Samtron Displays
 Sanyo Information
  Business
 if Sceptre Technologies
 •& Scion Computers
 -jtr Seanix Technology
 Sarviceworks Distribution
 •&- Shamrock Technology
 if Sharp Electronics
 •Ar Sherwood Terminals
  DhHsion, Inkel (USA)
 * Sbix Ho Tech/Hi-Com
 •ArShinlee
 if Shuttle Computer
 ir Sidus Systems
 if Siemens Nkdarf
 Sigma Designs
 Sigma Designs Imaging
  Systems (SOS)
 •&• SOeni Systems
 Silicon Graphics
 StO Technology
 Sirex USA
 ir SKV International/
  Compuiermill
Smith Corona
 *Sony
SsangVoag Computer
  Systems
 if STD Technology
Summit Micro Design
 if Sun Microsystems
Super Distributor
                                •*• Taiuisg
Synaex Technology
  Tnternationul
•Ar Sysorcx
Tae fl Media
if Tagram
-*- Taiwan & Hong Kong
  Monitor
ir Taiwan Video and
  Monitor
if Tandberg Data Display
if Tandy
•*• Tangent Computer
                               TCP
                               TeamMax
                               Tempest Micro
                               if Texas Instruments
                               Tk Tobbhi Electronic
                                 Company
                               * Toshiba
                               Total Coatroi Praducti
                               Total Peripherals
                               Tri-Cor Industries
                               l&Star Computer
                               if TriGem America
                               •^r TriGism Microsystems
                               Tripote  I
                               TS Micro!
                               TTX Computer Prodmcts
                               •^r Tulip Computers
                               TWC
                               Twinhead Intemationai
                               Twin T Distributor
                               * Tyh Fa Electronic
                               Tystar Electrooics
                               if Unisys
                               Unisys  Canada
                               if United; Solutions
                               *• Unitek Technology
                               Uoitron
                               * USA Teknik
                               usrr    !
    Systems and
  Technologies
-ArVeridata
Vextrec Technology
Vierci Computers
if ViewSonic
   Vision Computer
  Technologies
if Vita Electronics
Vobis Microcomputer
VTech Computers
Wang Laboratories
A- Wearnes Technology
Wedge Technology
WEN Technology
if Indicates companies which have annuuaced Energy Star compliant products
                                   58

-------
   Western Imaging
   if Win Laboratories
   Winnet
   WyJe Laboratories
   ic Wyse Technology
   xcv

 PMNTERS (number: 56)

   Tk- Advanced Matrix
     Technology
   if Alps Electric
   if Apple
   * Brother
   * Bull Italia
   *CalComp
   *C-TECH
   •*• Canon
  CIE America
  Citizen Watch
   •*• Data General
   * Data Rental & Sales
  Dataproducts
  T*r Digital Equipment
    (DEC)
  if Enabling Technologies
  Epson
  * Fujitsu
  * GCC Technologies
  if General Parametrics
 Xiociron
 Xpro Systems
 Xyst Infotek
 Yanjen Electronic
 Young Microsystems
 * GENICOM
 Goldstar
 •*• Hewlett-Packard
 IBM
 Intergraph
 * Kodak
 if Kyocera
 •irLsssaek
 ie Manncsrnaan Tally
 if Olympus Image
   Syssems
 if Output Technology
 if Panasonic
 if Pentax Technologies
 Printronix
Qnk Computer
Ricoh
 CONTROLLING DEVICES1 (number: 36)

  if Alpha Micro
    Technologies
  Antechron Research
  T*r Aten International
  Bayvicw Technology Group
  T*rB 48:8 Electronics
  Comraunica
- CompuSci
  •A-Coonectix
  (CCS.) Computers Etc.
  Curtis Manufacturing
  Cypress Computer
  * Defenders Network
Dinexcom
Energy Interface
Engram International
* Ergonomics
Eskei-Porter
Glitch Master
Greenlnk
Greenware Technologies
Hiberaation Software
 Z & M, Advanced
    Technology
 ie Zenith Data Systems
 if Zenon
 •drZeos
 Sanyo Inforaiaiion
   Business
 Seiko Instruments USA
 Senneeworks Diatril)uition
 ^r Sharp Electronics
 Sony Electronics
           Computer
                                              cs
 if Tesas losduments
 Toshiba America
   buTormation Systems
 Twin T Distributors
 •^.Unisys
 Westrex
 if Xerox
                                * Star
                                if
 if Mecer
 MSSI Consultants
 Newpoint
 Optiquest
 Panamax
if Image Plus
ir King Jaw Industrial
Quantum Composers
Sequence Electronics
snc
Sophisticated C~cuits
Tripp Lite
                                    ** K*W* *? 6ttergy «"-?«« of no^-En^gy Star compuu.n,

^r Indicaies companies which have announced Energy Star compliant producis
                                   69

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ALLIES2 (Components and Software: number. 144)
 Achieva Computer
 Acromcs Systems
 Advanced Micro Devices
 Advanced Integration
   Research
 AFEQT
 Allied Signal, Amorphous
   Metais
 Alpha Technology
 American Proimage
 Americas Power
   Conversion
 Amkly Systems
 Anigma
 Artek Innovations
 Arvee Systems
 Asian Computer
 Astec
 ATMEL
 AT&T Microelectronics
 Award Software
 Axeiea
 B&B Electronics
 BCM,
 Bevond Technology
 CAREO
 Cartaco
 Chips and Technologies
 Chisholai
 Cirrus Logic
 Computer Resources
 Connor Peripherals
 CreSonic
 Cypress (roraputer
 Cyrix
 Databouk
 DELTEC:
 DPI
 DIA Semicoa Systems
 Diablo Scientific
 Diamond Computer
  Systems
 DynaComp
 EFA
 EFAR Microsystems
 EH Electronics
 Elitegroup
 Elsa GmbH
                d'  %
     ^  oncepts
 Engram International
 Exide Electronics
 First fmernational
   Computer
 Free Computer
   Technology
 Glitch Master
 Gulden Power Systems
 Grees Labs
 Greoiware Technologies
 HatBsooy Power
 Hibernation Software
 HIPRO Electronics
 Hoily Electronic
 image Plus
 Infoffiadc Power Systems
 Lite!
 Iomega
 J-MARK Cumpuier
 Jabii Circuit
 Lattice Semiconductor
 Lead Year Enterprise
 LION  America
 Lite-On
 LLR Technologies
 M Technologr
 Macase industrial
 Market Cuntrdi
 Maxi Switch
 Maxtor
 Metasoft
 Michada Computers
 Mlchi Tech System
 Micro Energetics
 Microsoft
 Micro test
 Minta Technologies
 Moretec Electronics
  Industrial
 Morex  Information
  Enterprise
New Bios
NMB
North American Power
  Supplies
 Nova Distributing
 Ogdcn Atlantic Design
 OFT!
 Orchid Technology
 Palo Alto Digital Systems
 Pauamax
 PAOKU P^C
 Para Systems
 Pboenix Technoiogies
 PieoPower Technology
 Pise Technology
 Ptonacb Micro
 Power Monitors
 Professional Sound
 PSC      :
 Puikzi Engineering
 Quadcovatipn
 RuDsatson Technologies
 SdTech Software
 Seagate Technology
 Sejin America-
 Sequence Electronics
 Server Technology
 Silicon Star 'international
 Silicon Valley TechnolofQr
 Smart Industries
 SOLA
 Southeastern-Facts
 SoyoUSA  !
 Speaking Devices
 Sprint Manufacturing
 Standard Microsystems
 SuaPics    !
 Symphony Laboratories
 SystemSoft
 T & T Computer
 Takes     '
 Tamarack
 Teach Me How Company
 TEKRAM  i
Texas Instruments
Texas ISA  '
TMC Research
Topowcr Computer
Tripp Lite  ,
US. Power & Technology
Unlpower  >
United Solutions
  2 The /Uly agreement does not contain individual product specifications, so no products are "compliant.*
                                 70

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USARSysUsms                VLSI Technology               Western Telonatic
Vasco Import und              Wave Energy                   Zylee
  Vertriefas GmbH             WCLC
Vcxtrcc Technology             Western Digital
                               71

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                                    APPENDIX D

              FLUORESCENT LIGHTING TUBE RECYCLING SERVICES

Envirosol
212 South Mesquite
Suite 2A
Arlington, TX 76010
(800)488-7974

       Envirosol provides lamp recycling and ballast disposal services. Envirqsol can arrange
for lamp pick up or the lamps may be delivered.  The company requests that the generator
place tiie lamps back into the boxes in which they were received.
                                                                      PCB ballasts.
                                                                     recycled for $
                                                                           shipping.
       Envirosol's service area is Texas.  The company accepts PCB and non-
The cost of fluorescent recycling is $ 0.10-0.12 per linear ft.  HID lights are
3.00 each.  Ballasts are recycled for $0.80-0.90/lb.  The above costs do not include
There is a $300 minimum per shipment.

DYNEX Environmental, Inc.
4751 Mustang Circle
St. Paul, MN 55112
(612)784-4040                                                        !

       DYNEX Environmental provides lamp recycling and ballast disposal services.
DYNEX can arrange for lamp pick up or the lamps may be delivered.  The company requests
that the generator place the lamps back into the boxes in which they were received.  If the
customer does not have the original boxes, DYNEX provides a rental service for reusable
boxes.
                                                                      I
       DYNEX maintains a nationwide service area. The lamps are processed; in the
company's  Milwaukee, WI facility where they are placed in a lamp machine.  The machine
breaks  the glass and separates the  glass, mercury and metal into separate containers.  The
metals  are recovered for reuse, the recovered glass is used hi products,  such as!fiberglass, and
the mercury is purified and reused in various commercial applications.
             • •                              -                          i
       The company accepts PCB and non-PCB ballasts. As mentioned above* the company's
representative recommends that generators manage all ballasts as hazardous.  DYNEX offers
the following three options for ballast disposal:

       1.     Environmental Protection Agency (EPA') Approved Landfill Method - the
             ballast is transported in Department of Transportation (DOT) approved drums
             to an EPA approved hazardous waste landfill.  This option is the least
             expensive of the three (disposal cost: $1.19 per pound, 1 drum minimum at
                                    72

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              $795); however, future liability concerns remain because the waste has not been
              destroyed.

       2.     EPA Approved Reclamation Decap Method - The capacitor within the ballast
              contains the PCB oil. Under this method, the capacitor, which comprises
              approximately 20% of the total weight of the ballast is transported to an EPA-
              approved facility for incineration, eliminating future liability.  The remaining
              80% of the ballast contains metals that are  recovered and reused.  This decap
              process is conducted at DYNEX's Detroit,  MI facility. This method is not an
              option if the ballast is leaking.  The disposal cost is $1.49 per pound, 1 drum
              minimum at $1100.

       3.     EPA-Approved Total Incineration - The whole ballast is transported in DOT
              approved drums to an EPA approved facility for total incineration, eliminating
              any future liability for the waste. This is the only option available for leaking
              ballasts.  The disposal cost is $2.59 per pound, 1 dram minimum at $2000.

       The price of DYNEX's recycling services are dependent upon volume, lamp type and
transportation.  General price information, excluding transportation, is:  39 cents per 4 foot
lamp, with a minimum of 100 lamps; 66 cents per lamp over 4 feet, with a minimum of 100
lamps; and $2.89 per HID.

Lighting Resources, Inc.
386 S. Gordon Street
Pomona, CA  91766
(800) 572-9253
(800) 866-6818

       Lighting Resources is an ally of EPA's Green Lights Program, which is a voluntary
program to encourage American corporations to assist with pollution prevention by using
more efficient lighting systems.  Lighting Resources provides complete lamp recycling
services throughout the continental United States.  The company picks up lamps  from the
generator. Lighting Resources requires that the customer  pack the lamps and prepare the bill
of lading.

       The lamps are processed in a manner similar to the processes described above.  The
glass recovered from the process is sent to a cullet broker and is ultimately used in products,
such as fiberglass.  The aluminum recovered from the lamp end caps is also recovered for
reuse.  After an initial distillation process, the recovered mercury is sent to Bethlehem
Apparatus Company for additional processing and ultimate reuse (for more information on
Bethlehem Apparatus Company, see the contact summary  below).

       Lighting Resources accepts ballasts and processes them at two of its three facilities.
The company's Greenwood, IN facility handles both lamps and ballasts. The PCB ballasts are
disassembled and the capacitors are incinerated or landfilled.  The remaining metals  are
recovered for reuse.
                              73

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       Cost for services provided by Lighting Resources is dependent on lamp 'and ballast
volume and shipping distances.  Jerry Balch provided a price range for the recycling services:
7 to 10 cents per lamp; 75 cents to $2.75 per HID; and approximately 75 cents; per pound of
ballasts or $700 to $750 per 55  gallon drum of ballasts.                     !

Mercuiy Technologies International                                     j
1940 Westwood Blvd., No. 218                                •          !
Los Angeles, CA 90025                                                 i
(310)475-4684                                                         j
                         -•                    •             '              r
       Mercury Technologies International (MTI) also is an ally of EPA's Gre^n Lights
Program. MTI provides complete fluorescent lighting tube recycling services. The
company's facilities located in California, Florida and Pennsylvania provide nationwide
service.  However, MTI does not accept ballasts.

       MTI can arrange for lamp pick up. The  lamps are processed in- house and all
materials are recycled; according to Sandy Factor, nothing is land disposed. MTI  also
performs a triple distillation process to prepare the mercury for immediate commercial reuse.
                                                                        !
       The recycling fees vary based on volume and shipping distance. Generally, MTI
charges between 7.5 and 10.5 cents per linear lamp foot. For HIDs, MTI charges  $3 00 each.

Recyclights
2010 E.  Hennepin Av^ue                                               ',
Minneapolis, MN 55413-2799                                            J
(800) 831-2852 or (612) 378-9568

       Recyclights offers lamp recycling services on a nationwide basis, but dobs not handle
ballasts.  The company can arrange to pick up the spent lamps.  The lamps are processed
within 24 hours after arriving at the Recyclights facility. The materials recovered  from the
process include purified liquid mercury, aluminum,  metals, soda-lime glass and; a
calcium/iron-based powder. Following processing, Recyclights provides the customer with a
certificate of conversion, a formal record of disposal in accordance with regulatory
requirements.                                                            ;

       The price of the services provided by Recyclights depends upon the type  and quantity
of the lamps and transportation requirements. Generally, Recyclights charges 40 to 60 cents
per 4 foot lamp.  Lamps measuring longer than 4 feet cost between 60 and 83 cents per lamp
and HIDs cost between $2.50 and $5.00 per lamp.                    __~     (
                                   74

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 Mercury Refining Company
 1218 Central Avenue
 Albany, NY  12205
 (518) 459-0820
       The Mercury Refining Company provides fluorescent lighting tube recycling services
on a nationwide basis. The company does not accept ballasts.

       Mercury Refining Company can arrange for pick up of the spent lamps. The
company, a permitted treatment, storage and disposal facility, processes the lamps, recovers
the metals for reuse and processes the mercury using a thermal distillation process, called
retorting, for future commercial use.  The glass is disposed of in a hazardous waste  landfill,
even though the glass is not considered hazardous. According to Steve Graves, this option
avoids future liability concerns.

       The prices of the recycling services, which do not include transportation, are: 8 cents
per linear foot for whole tubes; and $650 per 55 gallon drum containing crushed lamps.  The
price of processing HIDs received in 55 gallon drums are: $15 per gallon for fflDs with a
diameter larger than 1.5 inches; and $20 per gallon for fflDs with a diameter of less than 1.5
inches.

Bethlehem Apparatus Company, Inc.
890 Front Street
P.O. Box Y
Hellerton, PA 18055
(610) 838-7034

       The Bethlehem Apparatus Company, Inc. provides fluorescent lighting tube recycling
services on a nationwide basis. The company does not accept ballasts.

       Bethlehem Apparatus does not provide or arrange for any transportation/pick up
services. The customer may ship whole tubes in their original box or another appropriate
box, or ship crushed lamps in 55 gallon drums.  The company processes the lamps, recovers
the mercury and disposes of all other materials including the glass and metals.

       Bethlehem Apparatus charges the following for various volumes and types of lamps:
Quantity
1-3000 Lamps
3000-6000 Lamps
> 6000 lamps
Whole 4 ft Fluoreseeir*
Lamps
$3.00 each
$2.25 each
$1.50 each
Whole 8 ft Fluorescent
Lamps
. $4.50 each
$3.50 each
$2.25 each
                                  75

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Number of 55 Gallon Steel Drums
1-5 Drums
6-10 Drums
> 10 Drums
Crushed Fluorescent Lamps
$1235 each'
$910 each ;
$650 each
USA Lights Environmental Inc.                                        |
2007 Country Road C-2                                               I
Rosevffle, MN  55113
(612) 628-9370

       USA Lights provides complete fluorescent lighting tube recycling services on a
nationwide basis.  The company claims that it is the only fluorescent lamps recycling
company that owns and operates its own transportation system, which services only facilities
located in Minnesota and Wisconsin.  USA Lights would arrange for pick up land
transportation services from facilities located in other states.                i

       USA Lights requests that the customer pack the spent lamps in the original  box and
secure the box with tape, if necessary. The customer should record the number of lamps on
the box.                                                               !

       USA Lights processes the materials using the USA Lights Model 2000 system, wlu'ch
is a self-contained, continuous flow process.  The glass,  metals and mercury all are recovered
for reuse.  The lamps are processed within 24 hours of receipt and the company issues a
certificate of recycling to document that lamp processing has been completed:

       The company has $6 million Pollution Liability Insurance coverage, which  protects the
customer from  financial responsibility should an accident occur either during [transport or at
the facility.                                                           !

       USA Lights' prices for recycling services, excluding transportation, are: 44 cents per 4
foot lamp; 62 cents per 8 foot lamp; and $2.29 per HID lamp.             '

       USA Lights does not accept ballasts.                              1
                                  76

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                                        APPENDIX E.
                  POLLUTION PREVENTION INFORMATION SOURCES
CLEARINGHOUSES AND ASSOCIATIONS

1.   Pollution Prevention Information
     Clearinghouse (PPIC)

     Pollution Prevention Information
     Clearinghouse
     u.a EPA
     PM211-A
     401 M Street, SW
     Washington, DC 20460
     Phone:    202-260-1023
     Fax;;      202-260-0178

    The Pollution Prevention Information
     Clearinghouse (PPIC) is dedicated to
     reducing or eliminating industrial pollutants
    through technology transfer, education, and
    public awareness.  It is a free,
    nonregulatory service of the U.S. EPA and
    consists of a repository of pollution
    prevention information, a telephone
    reference and referral service and a
    computerized information exchange
    system.

2.   The International Cleaner Production
    Information Clearinghouse (ICPIC)

    Industry and Environment Program Activity
    Center
    Uniteid Nations Environment Programme
    39-43 quai Andre Citroen
    7S739 Paris CEDEX 15
    France
    Phone:     33-1-30-58-88-50
    Fax:       33-1-40-58-88-74

   The international  Cleaner Production
   Information Clearinghouse (ICPIC) is a
   clearinghouse operated by the United
   Nations Environment Programme (UNEP).
   The ICPIC provides information to the   '
   international community on all aspects of
   low- and non-waste technologies and
   methods.
 3.  OzonAction            I

     Industry and Environment 'Program Activity
     Center                 ;
     United Nations Environment Programme
     OzonAction
     39=43 quai Andre Citroen
     7S739 Paris CEDEX 15
     France
     Phone:    33-1-30-58-88-50
     Fax:      33-1-40-58-88-74

     OzonAction relays technical and
     programmatic information on alternatives to
     all ozone depleting substances identified by
     the Interim Multilateral Ozohe Fund of the
     Montreal Protocol Agreements.

 4.   American Institute for Pollution
     Prevention (AIPP)

     Thomas R. Hauser, Ph.D., Executive
     Director
     American Institute for Pollution Prevention
     Department of Civil and Environmental
     Engineering             ;
     University of Cincinnati
     Cincinnati, OH 45221-0071 i
     Phone:    513-556-3693

    The AIPP was founded jointly by U.S.  EPA
    and the University of Cincinnati in 1989 to
    assist EPA in promoting the adoption of
    pollution prevention concepts.

5.   Center for Environmental Research
    Information (CERI)       '-

    Dorothy Williams
    U.S. Environmental Protection Agency
    Center for Environmental Research
    Information (CERI)
    26 West Martin Luther King Drive
    Cincinnati, OH 45268      ;
    Phone:   513-569-7562
    Fax:      513-569-7566

    CERI serves as the exchange of scientific
    and technical environmental information
    produced  by EPA by publishing brochures,
                                         77

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     capsule and summary reports, handbooks,
     newsletters, project reports, and manuals.

 6.  Center for Waste Reduction
     Technologies (CWRT)

     Center for Waste Reduction Technologies
     (CWRT)
     American Institute of Chemical Engineers
     345 East 47th Street
     New York, NY 10017
     Phone:    212-705-7407
     Fax:      212-752-3297

     CWRT was established in 1989 by the
     American Institute of Chemical Engineers to
     support industry efforts in meeting the
     challenges of waste reduction through a
     partnership between industry, academia,
     and government

 7.   Hazardous Waste Research and
     Information Center (HWRIG)

     Allsa WteMiff
     Hazardous Waste Research and
     Information Center
     One East Hazlewood Drive
     Champaign, IL 61820
     Phone:    217-244-8905
     Fax:       217-333-8944

     HWRIC is a division of the Illinois
     Department of Energy and Natural
     Resources.  HWRIC combines research,
     education, and technical assistance in a
     muitldlsclplinary approach to manage and
     reduce hazardous waste in Illinois. HWRIC
     collects and shares this information through
     fts library/clearinghouse and several
     computerized waste management tools.

8.   The National Roundtable of State
     Pollution Prevention Programs
     (Roundtable)

    David Thomas
    National Roundtable of Pollution Prevention
    Programs
    One East Hazlewood Drive
    Champaign, IL 61820
    Phone:    217-333-8940
    Fax      217-333-8944
     The Roundtable is a group of pollution
     prevention program at the State and local
     level in both the public and academic
     sectors. The member programs are
     engaged in activities including multi-
     audience training  and primary to post-
     secondary pollution prevention education.

 9.   Northeast States Pollution Prevention
     Roundtable (NE Roundtable)

     Terri Goldberg. Program Manager
     Northeast States Pollution Prevention
     Roundtable / Northeast Waste
     Management Officials' Association
     85 Merrimac Street
     Boston, MA 02114
     Phone:    617-367-8558
     Fax:       617-367-2127

     The  NE Roundtabie was initiated in 1989 by
     the Northeast Waste Management Officials'
     Association to assist State programs,
     industry, and the public implement effective
     source reduction programs.

 10.  Pacific Northwest Pollution Prevention
     Research Center

     Madeline Grulich, Director
     Pacific Northwest Pollution Prevention
     Research Center
    411 University Street, Suite 1252
    Seattle, WA 98101
    Phone:    206-223-1151
    Fax:       206-467-0212

    The Pacific Northwest Pollution Prevention
    Research Center is a non-profit public-
    private partnership dedicated to the goal of
    furthering pollution prevention in the Pacific
    Northwest

11.  Solid Waste Information Clearinghouse
    (SWICH)

    Lori Swain, Manager
    Solid Waste Information Clearinghouse
    Solid  Waste Association of North America
    P.O. Box 7219
    Silver Spring, MD 20910
    Phone:     1-800-677-9424
    Fax:       301-585-0297
                                                78

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 12.
13.
 SWICH is an information clearinghouse
 covering  a wide range of solid waste
 issues. SWICH components include an
 electronic bulletin board, a library and a
 hotline.

 Waste Reduction Institute for Training
 and: Applications Research, Inc.
 (WHITAR)

 Terry Foeeke or Al Innes
 Wasite Reduction Institute for Training and
 Applications Research
 1313 5th Street, SE
 Minneapolis, MN 55414-4502
 Phone:    612-379-5995
 Fax;       612-379-5996

 WRITAR Is designed to identify waste
 reduction  problems, held find their
 solutions,  and facilitate the dissemination of
 this information to a variety of public and
 private organizations.

 Waste Reduction Resource Center for
 the Southeast (WRRC)

 Gary Hunt
 Waste Reduction Center for the Southeast
 3825 Barrett Drive
 P.O. Box 27687
 Raleigh, NC 27611 -6787

 WRRC was established to provide
 multimedia waste reduction  support for the
 eight states of U.S. EPA IV (Alabama,
 Florida, Georgia, Kentucky, Mississippi,
 North Carolina, South Carolina, and
Tennessee).
 FACILITY PLANNING AND GENERAL
 POLLUTION PREVENTION MANUALS
                            I
 1.  Audit and Reduction Manual for
     Industrial Emissions and Wastes

     United Nations Environment Programme
     (UNEP) and United Nations Industrial
     Development Office (UNIDO), 1991
     UNEP                  !
     1889 F Street, NW
     Washington, DC 20006   ;
     Phone:    202-289-8456
     Cost: Contact UNEP for cost and
     availability information    ;

     The manual addresses the ifollowing topics:
     introduction to waste auditing, the audit
     procedure, pre-assessment,  material
     balance, process inputs and outputs, and
     synthesis, and three technical case studfes.

 2.   Facility Pollution Prevention Guide

     U.S. EPA Office of Research and
     Development
     Center for Environmental Research
     Information
     26 West Martin Luther King Drive
     Cincinnati, OH 45268
     Phone:     513-569-7562
     Cost: Free              |

     The manual describes how to conduct a
     waste assessment, from the
     planning/organization stage through the
     assessment and feasibility analysis to fireil
     implementation of pollution prevention
     options.                 ;
                            i
3.    Industrial Waste Minimization Manual

    Center for Hazardous Materials Research
    University of Pittsburgh Applied Research
    Center                  \
    320 William Pitt Way      j
    Pittsburgh, PA 15238
    Phone:    412-826-5320
              800-334-CHMR
    Cost: $40

    This manual provides information and
    guidance to all industrial waste generator!!
                                        79

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     on pollution prevention practices and
     suggested compliance requirements for
     RCRA and other related Federal acts.

4.   Industrial Waste Prevention

     Waste Advantage, Inc. 1988
     17117 West Nine Mile Road, Suite 902
     Southfleld, Ml 48075
     Phone:    313-569-8150
     Cost: $195 (Includes access to technical
     assistance hotline)

     This practical guide provides step-by-step
     instructions for developing an effective
     waste minimization program.

5.   Pollution Prevention Case Studies
     Compendium

     U.S. EPA
     Office of Research and Development
     Rfsk Reduction Engineering Laboratory.
     Cincinnati, OH 45268
     Phone:    513-569-7562
     Cost: Free from CERI

    The studies are a collection of summaries
     of pollution prevention demonstrations,
     assessments, and research projects
     conducted with the Risk Reduction
     Engineering Laboratory.

6.   Pollution Prevention Pays Instruction
     Manual

    Dr. Susan Smith
    Center for Improving Mountain Living
    Bird Building
    Western Carolina University
    Cuilowhee, NO 28723
    Phone:    704-227-7492
    Cost $28

    This manual conce-trates on (1) current
    legal and environmental issues that create
    the need for an industrial pollution
    prevention program and (2) an innovative
    systems approach to industrial-resource
    management that can reduce pollution.
7.   Pollution Prevention Resource Manual

     Chemical Manufacturers Association
     2501 M Street, NW
:     Washington, DC 20037
     Phone:    202-887-1100
     Cost: $75

     This manual was designed for use by
     personnel of all levels who are involved
     with planning or implementing a pollution
     prevention program.

8.   Waste Minimization Training Manuals

     Department of Toxic Substances Control
     Attention: Robert Ludwig
;     Alternative Technology Division
     714/744 P Street
     P.O. Box 806
     Sacramento, CA 9SS12-0806
     Phone:   916-324-1807
              916-322-3070

    This includes three pollution prevention
     modules on waste minimization.  Each
     manual consists of a workbook and video.

9.  Waste  Reduction Assessment and
    Technology Transfer (WRATT) Training
    Manual

    George Smelcer
    Center for Industrial Services
    University of Tennessee
    286 Capitol Boulevard Building
    Suite 606
    Nashville, TN 37219-1804
    Phone:    615-242-2456

    This manual includes information on waste
    reduction awareness and incentives,
    Federal safety standards, State and Federal
    regulations, how to establish a waste
    reduction program and conduct a waste
    assessment and waste reduction
    approaches for specific industries and
    waste types.
                                          80

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 POLLUTION PREVENTION VIDEOS          4.
                                          ' £

 1.   1990 Clean Air Act Overview
     (20min.)

     Sylvia Gordon
     WRATT Case Studies
     University of Tennessee, 1991
     Center for Telecommunications and Video
     Suite 61.1345 Circle Park Drive
     Knoxvilie, TN 37996-0312
     Phone:    615-974-1313
     Cost      $25 (available only from the
               producer)

     The new Clean Air Act is reviewed,
     esp
-------
7.  Waste Reduction Assessment
    Opportunities
    (32 min.)

    Tennessee Valley Authority, University of
    Tennessee-CIS
    University of North Carolina Asheville-EQI,
    1989
    Attention: Carroll Ouggan
    Waste Technology Program
    2F 71B Old City Hall Building
    Knoxville, TN 37902
    Phone:    615-632-3160
    Cost*     $25

    This video summarizes the multimedia
    waste reduction assessment procedure and
    its application at several businesses.

8.  Why Waste? Waste Minimization for
    Today's  Businesses
    (28 min.)

    California Department of Toxic Substances
    Control, 1990
    Attention: Kathy Varwick
    Alternative TEchnoIgy Division
    Technology Clearinghouse Unit
    P.O. Box 806
    Sacramento, CA 95812-0806
    Phone:    916-324-1807
    Cost:     $15

    The video defines waste minimization and
    illustrates waste reduction successes in
    several different types if businesses.
                                        82

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                    POLLUTION PREVENTION ASSISTANCE
 CLEARINGHOUSES AND ASSOCIATIONS

 1.   Pollution Prevention Information
     Clearinghouse (PPIC)

     Pollution Prevention Information
     Clearinghouse
     US,, EPA
     PM211-A
     401 M Street, SW
     Washington, DC 20460
     Phone:    202-260-1023
     Fax,;      202-260-0178

    The Pollution Prevention Information
     Clearinghouse (PPIC) is dedicated to
     reducing or eliminating industrial pollutants
    through technology transfer, education, and
    public awareness.  It is a free,
    nonregulatory service of the U.S. EPA and
    consists of a repository of pollution
    prevention information, a telephone
    reference and referral service and a
    computerized information exchange
    system.

2.   The International Cleaner Production
    Information Clearinghouse (ICPIC)

    Industry and  Environment Program Activity
    Center
    Untasd Nations Environment Programme
    39-43 quai Andre Citroen
    7S739 Paris CEDEX 15
    Ranee
    Phone:    33-1-30-58-88-50
    Fax:      33-1-40-58-88-74

    The International Cleaner Production
    Information Clearinghouse (ICPIC) is a
    clearinghouse operated  by the United
    Nations Environment Programme (UNEP).
    The ICPIC provides information to the
    international community on all aspects of
    low- and non-waste technologies and
    methods.
 3.  OzonAction

     Industry and Environment Program Activity
     Center
     United Nations Environment Programme
     OzonAction
     39-43 quai Andre Citroen  [-
     75739 Paris CEDEX 15
     France
     Phone:    33-1-30-58-88-50
     Fax:       33-1-40-58-88-74

     OzonAction relays technical and
     programmatic information on alternatives to
     ail ozone depleting substances identified by
     the Interim Multilateral Ozone Fund of the
     Montreal Protocol Agreements.

4.   American Institute for Pollution
     Prevention (AIPP)

     Thomas R. Hauser, Ph.D.,  Executive
     Director
     American Institute for Pollution Prevention
     Department of Civil and Environmental
     Engineering   -          ;
     University of Cincinnati    j
     Cincinnati, OH 45221-0071
     Phone:    513-556-3693
                            !
                            !
    The AIPP was founded jointly by U.S. EPA
    and the University of Cincinnati in 1989 to
    assist EPA in promoting the adoption of
    pollution prevention concepts.
                            I

5.   Center for Environmental Research
    Information (CEHI)

    Dorothy Williams
    U.S. Environmental Protection Agency
    Center for Environmental Research
    Information (CER1)
    26 West Martin Luther King Drive
    Cincinnati, OH 45268
    Phone:    513-569-7562
    Fax:       513-569-7566

    CERI serves as the exchange of scientific
    and technical environmental! information
    produced  by EPA  by publishing brochures,
                                          83

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     capsule and summary reports, handbooks,
     newsletters, project reports, and manuals.

 6.   Center for Waste Reduction
     Technologies (CWRT)

     Center for Waste Reduction Technologies
     (CWRT)
     American Institute of Chemical Engineers
     345 East 47th Street
     New York, NY 10017
     Phone:    212-705-7407
     Fax:       212-752-3297

     CWRT was established in 1989 by the
     American Institute of Chemical Engineers to
     support Industry efforts in meeting the
     challenges of waste reduction through a
     partnership between industry, academia,
     and government

 7.   Hazardous Waste Research and
     Information Center (HWRIC)

     Allsa WIctdiif
     Hazardous Waste Research and
     Information Center
     One East Hazlewood Drive
     Champaign, IL 61820
     Phone:   217-244-8905
     Fax:      217-333-8944

     HWRIC Is a division of the Illinois
     Department of Energy and Natural
     Resources. HWRIC combines research,
     education, and technical assistance in a
     muitWIsciplInary approach to manage and
     reduce hazardous waste in Illinois. HWRIC
     collects and shares this information through
     its library/clearinghouse and several
     computerized waste management tools.

a  The National Roundtable of State
     Pollution Prevention Programs
     (Roundtable)

    David Thomas
    National Roundtable of Pollution Prevention
    Programs
    One East Hazlewood Drive
    Champaign, IL 61820
    Phone:    217-333-8940
    Fax:      217-333-8944
 9.
 The Roundtable is a group of pollution
 prevention program at the State and locafi
 level In both the public and academic
 sectors.  The member programs are
 engaged In activities including multi-
 audience training and primary to post-
 secondary pollution prevention education.

 Northeast States Pollution Prevention
 Roundtabie (NE Roundtable)

 Terri Goldberg, Program Manager
 Northeast States Pollution Prevention
 Roundtabie / Northeast Waste
 Management Officials' Association
 85 Merrimac Street
 Boston, MA 02114
 Phone:   617-367-8558
          617-367-2127
 10.
The NE Roundtable was initiated in 1989 by
the Northeast Waste Management Officials'
Association to assist State programs,
industry, and the public implement effective
source reduction programs.

Pacific Northwest Pollution Prevention
•Research Center

Madeline Grulich, Director
Pacific Northwest Pollution Prevention
Research Center
411 University Street, Suite 1252
Seattle, WA 98101
Phone:    206-223-1151
Fax:      206-467-0212

The Pacific Northwest Pollution Prevention
Research Center is a non-profit public-
private partnership dedicated to the goal of
furthering pollution prevention in the Pacific
Northwest
11. Solid Waste Information Clearinghouse
    (SWICH)

    Lori Swain, Manager
    Soiid Waste Information Clearinghouse
    Solid Waste Association of North America
    P.O. Box 7219
i    Silver Spring, MD 20910
    Phone:     1-800-677-9424
    Fax:       301-585-0297
                                         84

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     SWICH is an information clearinghouse
     covering a wide range of solid waste
     issues.  SWICH components include an
     electronic bulletin board, a library and a
     hotline.

 12.  Waste Reduction Institute for Training
     and Applications Research, Inc.
     (WH1TAR)

     Teny Foecke or Al Innes
     Wasste Reduction Institute for Training and
     Applications Research
     1313 5th Street, SE
     Minneapolis, MN 55414-4502
     Phene:    612-379-5995
     Fax;:      612-379-5996

    WRITAR is designed to identify waste
    reduction problems, held find their
    solutions, and facilitate the dissemination of
    this information to a variety of public and
    private organizations.

13.  Waste Reduction Resource Center for
    tie Southeast (WRRC)

    Gary Hunt
    Waste Reduction Center for the Southeast.
    3825 Barrett Drive
    P.O. Box 27687
    Raleigh, NC 27611-6787

    WRRC was established to provide
    multimedia waste reduction support for the
    eight: states of U.S. EPA IV (Alabama,
    Florida,  Georgia, Kentucky, Mississippi,
    North Carolina, South Carolina, and
 FACILITY PLANNING AI^D GENERAL
 POLLUTION PREVENTION  MANUALS

 1.  Audit and Reduction Manual for
     Industrial Emissions and'Wastes

     United Nations Environment Programme
     (UNEP) and United Nations Industrial
     Development Office (UNIDO), 1991
     UNEP                  i
     1889 F Street, NW       ;
     Washington, DC 20006    '
     Phone:    202-289-8456
     Cost: Contact UNEP for cost and
     availability information    ;

     The manual addresses the following topics:
     introduction to waste auditing, the audit
     procedure, pre-assessment, material
     balance, process inputs and outputs, and
     synthesis, and three technical case studies.

 2.   Facility Pollution Prevention Guide

     U.S. EPA Office of Research and
     Development
     Center for Environmental Research
     Information
     26 West Martin Luther King; Drive
     Cincinnati, OH 45268
     Phone:     513-569-7562
     Cost: Free

     The manual describes how;to conduct a
     waste assessment, from th^
     planning/organization stage through the
     assessment and feasibility analysis to finial
     implementation of pollution prevention
     options.

3.    industrial Waste Minimization Manual

    Center for Hazardous Materials Research
    University of Pittsburgh Applied Research
    Center
    320 William Pitt Way
    Pittsburgh, PA 15238
    Phone:    412-826-5320
              800-334-CHMR
    Cost: $40

    This manual provides information and
    guidance to all  industrial waste generators
                                     85

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     on pollution prevention practices and
     suggested compliance requirements for
     RCRA and other related Federal acts.

 4.   Industrial Waste Prevention

     Waste Advantage, Inc. 1988
     17117 West Nine Mile Road, Suite 902
     Southfield, Ml 48075
     Phone:    313-569-8150
     Cost: $195 (includes access to technical
     assistance hotline)

     This practical guide provides step-by-step
     instructions for developing an effective
     waste minimization program.

 5.   Pollution Prevention Case Studies
     Compendium

     U.S. EPA
     Office of Research and Development
     Rfek Reduction Engineering Laboratory
     Cincinnati, OH 45268
     Phone:    513-569-7562
     Cost: Free from CERI

     The studies are a collection of summaries
     of pollution prevention demonstrations,
     assessments, and research projects
     conducted with the Risk  Reduction
     Engineering Laboratory.

6.   Pollution Prevention Pays Instruction
     Manual

     Dr. Susan Smith
     Center for Improving Mountain Living
     Bird BuHdlng
    Western Carolina University
    Cullowhee, NC 28723
    Phone:    704-227-7492
    Cosfc$28

    This manual concentrates on (1) current
    legal and environmental issues that create
    the need for an industrial pollution
    prevention program and (2) an innovative
    systems approach to industrial-resource
    management that can reduce pollution.
 7.   Pollution Prevention Resource Manual

     Chemical Manufacturers Association
     2501 M Street, NW
 ;    Washington, DC 20037
     Phone:    202-887-1100
 I    Cost: $75

     This manual was designed for use by
     personnel of all levels who are involved
     with planning or implementing a pollution
     prevention program.

 8.   Waste Minimization Training Manuals

     Department of Toxic Substances Contrd
     Attention: Robert Ludwig
     Alternative Technology Division
     714/744 P Street
     P.O. Box 806
     Sacramento, CA 9S512-0806
     Phone:    916-324-1807
              916-322-3670

    This includes three pollution prevention
    modules on waste minimization.  Each
    manual consists of a workbook and video.

9.  Waste Reduction Assessment and
    Technology Transfer (WRATT) Training
    George Smelcer
    Center for Industrial Services
    University of Tennessee
    266 Capitol Boulevard Building
    Suite 606
    Nashville, TN 37219-1804
    Phone:    615-242-2456

    This manual includes information on waste
    reduction awareness and incentives,
    Federal safety standards, State and Federal
    regulations, how to establish a waste
    reduction program and conduct a waste
    assessment and waste reduction
    approaches for specific industries and
    waste types.
                                             86

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 POLLUTION PREVENTION VIDEOS

 1.  1990 Clean Air Act Overview
     (20 min.)

     SyKia Gordon
     WRATT Case Studies
     University of Tennessee, 1991
     Center for Telecommunications and Video
     Suite 61,1345 Circle Park Drive
     Knoxville, TN 37996-0312
     Phone:    615-974-1313
     Cost:     $25 (available only from the
               producer)

     The new Clean Air Act is reviewed,
     ©specially Title 1,3,4, and 6. Pollution
     prevention implications are discussed.

 2.   Beyond Business as Usual: Meeting the
     Challenge of Hazardous Waste
     (28:30 min.)

     U.S. EPA  Region VIII
     999 18th Street, Suite 500
     Denver, CO 80202-2405
     Phone:    303-293-1603
     Cost:     Contact EPA Region VIII for
              cost and availability information

    This video promotes source reduction and
    recycling as the best hazardous waste
    management options and includes success
    stories from industry, Federal agencies, and
    state and local government programs.

3.   The Competitive Edge
    (17:50 min.)

    Ontario Waste Management Corporation,
    2 Bloor Street West, 11th Roor
    Toronto, Ontario, Canada M4W3E2
    Phone:    416-923-2918
    Cost:      $24 (available only from the
              producer)

    The video is designed to acquaint
    employess with the industrial auditing
    process by explaining the six steps of an
    audity in clear and simple terms.
 4.   Pollution Prevention: The Bottom Unis
     (24 min.)                i

     Coastal Video Communications Corporation
     3083 Brickhouse Court
     Virginia Beach, VA 23452
     Phone:    800-767-7703  i
     Cost:      $195
     The video includes interviews with official of
     major international corpors|tions and deals
     with environmental legislation, cost
     motivation, and the identification and
     implementation of pollution prevention
     techniques.              !

5.   Reducing Waste in the Workplace
     (24 min.)

     Coastal Video Communications Corporation
     3083 Brickhouse Court    !
     Virginia Beach, VA 23452
     Phone:     800-767-7703
     Cost:      $495          i

    This video discusses materials handling
    and inventory control, equipment
    operations and scheduling, cleaning and
    maintenance, and waste collection and
    management.             ;

6,   Waste Not...Want Not
    (15 min.)                 I

    U.S.  EPA Region IV, 1989
    345 Courtland Street, N.E.
    Atlanta, GA 30365         ;
    Phone:    404-347-7109   '
    Cost:     Contact EPA Region IV for cost
              and availability information
                             r
    The video presents EPA's waste
    management hierarchy, led py source
    reduction and recycling, to handle the
    current municipal solid waste crisis.
                                        87

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7.  Waste Reduction Assessment
    Opportunities
    (32 mia)

    Tennessee Valley Authority, University of
    Tennessee-CIS
    University of North Carolina Asheville-EQI,
    1989
    Attention: Carroll Duggan
    Waste Technology Program
    2F 71B Old City Hall Building
    Knoxville, TN 37902
    Phone:    615-632-3160
    Cost     $25

    This video summarizes the multimedia
    waste reduction assessment procedure and
    Its application at several businesses.

8.  Why Waste? Waste Minimization for
    Today's Businesses
    (28 mia)

    California Department of Toxic Substances
    Control, 1990
    Attention: Kathy Varwick
    Alternative TEchnolgy Division
    Technology Clearinghouse Unit
    P.O. Box 806
    Sacramento, CA 95812-0806
    Phone:    916-324-1807
    Cost:     $15

    The video defines waste minimization and
    Illustrates waste reduction successes in
    several different types if businesses.
                                        88

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                               PROJECT SUMMARY
             POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
                        UNITED STATES POSTAL SERVICE
                        BULK MAIL CENTER, DALLAS, TX
                                      Abstract                        !
                                                                     i
      As part of its Waste Reduction Evaluation at Federal Sites (WREAFS) Program, the
U.S. Environmental Protection Agency (USEPA) National Risk Management Research
Laboratory (NRMRL) worked cooperatively with the U.S. Postal Service (USPS) to integrate
waste prevention and recycling activities into the waste management programs at various
Postal facilities through the conduct of pollution prevention opportunity assessments (PPOA).
The Pollution Prevention Opportunity Assessment (PPOA) summarized here was conducted at
the USPS Bulk Mail Center (BMC) located in Dallas, TX.

      The report describes the mission of the BMC including operations performed,
processes and materials employed and the wastes and emissions generated. Thd report makes
recommendations concerning the procurement of office supplies, maintenance supplies and
hazardous materials; management of hazardous materials and wastes; purchase of chemicals on
USEPA's 33/50 list; improvement of source separation and recycling of paper and paper
products, metals and plastics;  management of unwanted equipment; and other options for
reducing or eliminating pollution.                                        •
                                                                     i
      This Project Summary was developed by USEPA's National Risk Management
Research Laboratory, Cincinnati, OH to announce key findings of the research project that is
fully documented hi a separate report of the same title.                      ;

INTRODUCTION                                                    !

      Since 1988,  EPA's National Risk Management Research Laboratory (NRMRL) 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 industries.                                      :

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        The United States Postal Service (USPS), in cooperation with NRMRL's WREAFS
program is engaged hi an effort to integrate pollution prevention and recycling activities into
the waste management programs at postal facilities. The purpose of this project was to
perform pollution prevention opportunity assessments (PPOAs) at Postal Service facilities,
recommend implementation strategies, and develop facility guidance that can be incorporated
into a revision of the USPS Waste Reduction Guide.  The project was funded by the U.S.
Postal Service through an interagency agreement (IAG) with EPA NRMRL.   :

       This report describes the findings of the PPOA conducted for the United States Postal
Service Bulk Mail Center (BMC) located in Dallas, TX.  The site assessment was conducted
during the week of May 15,  1995.                                         '

FACILITY DESCRIPTION

       The BMC facility in Dallas, TX performs the sorting and routing of packages and bulk
business mail for Texas, Oklahoma and parts of Kansas, Arkansas, and Louisiana as part of a
national network of mechanized bulk mail centers that process third and fourth class mail.
The facility employs approximately 1,600 individuals and operates  three eighth-hour shifts per
day, six days per week and two shifts on Sunday.  An additional 300 workers are hired during
the Christmas holiday season.                                             ;

       The BMC facility occupies 75 acres; the main building contains approximately 452,000
square feet of space.  In addition, the facility houses a 2,000 sq.  ft. lubrication storage area; a
2,048 sq. ft. former vehicle repair shop that is now used to repair "over-the-road"  aluminum
mail-transport equipment (OTRs) and as a fuel and oil dispensing area for postal vehicles; and
a 1,000 sq. ft. shed that  houses groundskeeping equipment and miscellaneous machinery. The
BMC also has two remote sites: a USPS-owned warehouse, which is shared with the Dallas
General Mail Facility (GMF), and a leased facility of 59,000 sq. ft. that houses the Crossdock
Pallet Facility  (CPF).                                                     ;

WASTE MANAGEMENT                                               ;      -••

       Wastes generated by BMC operations include excess and  obsolete equipment and
supplies; corrugated cardboard; computer paper; white paper; mixed office paper,  including
forms and envelopes; magazines and newsprint; undeliverable bulk business mail (UBBM) and
"loose-in-mail" pieces (LIMs); employee wastes, including cans, bottles, wrappers, and food;
pallets; shrink and stretch wrap; aluminum and other metals; wood; fluorescent tubes and
lighting ballasts; batteries; plastic and metal strapping; rags; and oil filters and waste oil.
Additionally, the BMC facility generates small quantities of hazardous wastes from aerosol
cans, primarily paints and oils.  In 1994, one 55-gallon drum of F003 and F005 waste was
generated.  Exhibit 1 presents the composition of the solid waste stream, the current
management practice for each component, and a summary of pollution prevention
opportunities.  Exhibit 2 summarizes the current costs of waste collection.    '

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Exhibit 1.  BMC Solid Waste Generation and Pollution Prevention Opportunities
Waste
Obsolete, damaged or
defective equipment
Corrugated cardboard
Computer print-out
White paper
Mixed paper
Magazines
Toner cartridges
Pallets
Plastic stretch wrap
Rags
Fluorescent tubes
Strapping
Oil
Alkaline Batteries
Lighting Ballasts
Current Management
Disposed or sold as scrap
Some reused, gaylords recycled,
other cardboard disposed
Discarded as waste
Some recycled
Discarded as waste
Discarded as waste
Returned for recycling
USPS pallets sent to Arlington
facility for redistribution. Pine
pallets sold as scrap for mulch
Discarded as waste
Discarded as waste
Discarded as waste
Discarded as waste
Rerefined
Recycled
PCB ballasts managed as hazardous,
non PCB ballasts recycled
Opportunities
Repair at USPS Computer Repair
Facility (CRF) in Topeka, KS, reuse
Reduce use of gaylords, increase use of
OTRs, reduce incoming boxes, reuse
boxes, improve diversion for recycling
Reduce generation, divert for recycling
Reduce generation, imprpve diversion
for recycling • '
Reduce generation, divert for recycling
Reduce generation, divert for recycling
Continue recycling ;
Reduce variety, reuse pine pallets,
establish recycling options for pine
pallets '
Reduce generation, divert for recycling
Investigate rag service feasibility
Improve ambient light, install motion
sensitive lighting, divert for recycling
\
Divert for recycling '.
Purchase rerefined oil
Use rechargeable batteries
	 ;
Improve ambient light, install motion
sensitive lighting, turn lights off

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                      Exhibit 2. Current Cost of Waste Collection
Material
Mixed Waste at
BMC
Mixed Waste at
CPF
Oily Rags
Container
size
40 cu yd
6 cu yd
55-gallon
drum
Collection
frequency
12 per month
26 per month
3-4 drums per
month
Total
Monthly fee
$147.50 per
pull or $1,770
per month
$3,145
$400 per drum
or $1,200 to
$1,600 per
month
Annual Cost
$21,240!
. i
$37,740
$14,400'to
$19,200i
$73,380 -$78, 180 '
POLLUTION PREVENTION OPPORTUNITIES

       Exhibit 3 presents the pollution prevention opportunities that offer the 1JSPS significant
cost reductions hi addition to reducing pollution.  The primary pollution prevention
opportunities identified by the PPOA are addressed in the sections below.    :
                                                                      i
       Environmental Oversight                                         ',
                                                                      ',
       •     Appoint an Environmental Coordinator to monitor environmental issues
             and implement opportunities to reduce waste and prevent pollution at the
             facility.                                                  i

       Reuse and Recycling                                             •

       The BMC presently receives approximately $100,000 in annual revenue from its old
corregated cardboard (OCC) recycling program (recycled gaylord boxes), approximately
$9,600 hi annual revenue from scrap metal recycling, and in 1995, to date, the BMC has
received $7,929 hi revenue from scrap aluminum recycling. Postal employees use metal
"over-the-road" (OTR) containers to move mail between facilities, although this was not their
intended use, and facilities hoard OTRs for the holiday season.  The BMCs have no control
over the OTR inventory 5 thus OTRs are not readily available to move the mail in the BMC
service area. To solve the problem of access to mail transport equipment, the 'USPS has
designed the Integrated Mail Handling System, which would substitute cardboard gaylord
boxes for the reusable OTRs and require modifying existing mail handling equipment to
accommodate the gaylords. Recommendations are:                        i

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       Cancel the Integrated Mail Handling System, (IMHS) and use
       OTRs instead of cardboard gay lord boxes.

       Purchase enough additional OTRs or other permanent mail
       transport equipment for the nationwide movement of non-peak
       period mail volume and design and implement a nationwide bar-
       code labeling and tracking system for the OTRs.

       Reuse cardboard gaylord boxes that enter facility, rather than
       recycling them after one use.  One reuse of each gaylord will
       reduce costs by $500,000.

       Reuse cardboard boxes in other processing operations

       Segregate for recycling the OCC that cannot be reused

       Improve the office paper recycling system

       Reduce the quantity of undeliverable bulk busines mail (UBBM)
       and recycle rather than dispose of "loose-in-mail" pieces (LIMs)
Pallets
       Establish a formal recycling system for pine pallets.  Recyclers will
       repair or rebuild pallets for resale.  Several pallet recycling services are
       available in the Dallas area.
Fluorescent Lights                                                 \

•      Establish a fluorescent tube recycling program for the 1,500 flurpescent
       tubes used at this facility.

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Cancel the Integrated Mail Handling System, (IMHS) and use
OTRs instead of cardboard gay lord boxes.

Purchase enough additional OTRs or other permanent mail
transport equipment for the nationwide movement of non-peak
period mail volume and design and implement a nationwide bar-
code labeling and tracking system for the OTRs.

Reuse cardboard gaylord boxes that enter facility, rather than   ;
recycling them after one use.  One reuse of each gaylord will
reduce costs by $500,000.                                  '

Reuse cardboard boxes in other processing operations          ,

Segregate for recycling the OCC that cannot be reused

Improve the office paper recycling system

Reduce the quantity of undeliverable bulk busines mail (UBBM)
and recycle rather than dispose of "loose-m-mail" pieces (LIMs).

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          Exhibit 3. Cost-Saving Pollution Prevention Opportunities
Item(s) of
Concern
Gaylords/OTRs
Cardboard
Gaylords
Old Corrugated
Cardboard
Rags
Current Practice
Use disposable
gaylords in place of
durable aluminum
OTRs.
Recycle after single
use.
Recycle cardboard
gaylords
Dispose remaining 30
percent of OCC stream
as waste.
Purchase new rags
Dispose rags via
incineration
Pollution Prevention
Opportunity
Purchase sufficient
quantity of reusable
OTRs and maintain for
10 years t
Reuse gaylords
Continue current
recycling practices.
Utilize baler and recycle
remaining OCC.
Launder rags
Dispose 25 percent of
rags annually
Summary of Estimated Potential
Cost Per Trip:
Aluminum OTR1 Cardboard Gavlord
$1.40 $5.41
(150 trips/ ' (single use)
yr for 10 yrs)
After 39 trips/year, OTRs are more cost effect
Potential savings of $4.01 per trip.
1 $1,138 purchase cost and $1,000 lifetime mai
Based on annual purchase costs of $1,000,000,
reuse of each gaylord equal $500,000. '
Approximately $100,000 revenue (at 60 tons/
gaylords.
Approximately $100 to $140 per ton in revenu
corrugated cardboard recycled.
Yearl
Laundering New Cost Saving
$2.17/lb ' $2.23/lb $414
! Year 2
Laundering New Cost Saving
$2.06/lb $2.23/lb $1,173
* Purchase of new rags costs approximately $1
disposal costs are $14,400.
* Cost of laundering rags is approximately $10
disposal costs with laundering are $3,600.
Pallets
       Establish a formal recycling system for pine pallets.  Recyclers will
       repair or rebuild pallets for resale.  Several pallet recycling services are
       available hi the Dallas area.
Fluorescent Lights                                                    :
                                                                      p

•      Establish a fluorescent tube recycling program for the 1,500 flurpescent
       tubes used at this facility.

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        Rechargeable Batteries

        •     Purchase rechargeable batteries and a charging unit to recharge ,
              the batteries.  GSA has available rechargeable alkaline batteries
              that offer the high performance attributes of regular alkaline
              batteries along with the cost and environmental benefits of a
              reusable system.                                   '         >

        Affirmative Procurement

        •     Establish preference programs and adopt specifications for the purchase
              of products made with the percentages of recovered materials specified
              in USEPA Guidelines.                                      .

        Lighting

        •     Increase the use of motion sensitive lighting

        •     Install motion sensitive lighting in infrequently used areas.     i

        •     Establish a "lights out" policy

        •     Establish a policy of turning off lights and equipment when leaving an
              area.  Where machine design permits, turn photocopiers to low power
              when not in use.
                                                                         i
                                                                         i
        •     Increase the use of ambient lighting

        •     Become a Federal Partner in the Green Lights Program

       Computers                                                        :
                                                                         i
       •     Procure computers that meet Energy Star requirements         ;

       Battery Charging

       •     Review procedures on the proper charging of batteries to prevent
              accidental acid overflows.
                                      -      ,-      ,             ,       -i

       Dedicated Oil Containers                                           j

       The Dallas BMC has a bulk distribution system which stores several types of oil and a
solvent called Pro-Power, an oil emulsifier, but the facility uses one container to transfer the
products. This process generates unnecessary waste because excess oil is disposed, instead of

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being reused, and because the containers must be cleaned with solvent after each use.
Therefore, dedicated containers should be purchased and used for each specific material.

CONCLUSIONS AND RECOMMENDATIONS

       The BMC facility has taken admirable steps hi terms of implementing a relatively
aggressive recycling and reuse program for many commodities, such as OCC, metal, and
pallets.  In terms of OCC, the BMC should focus on reusing cardboard gaylord boxes,
replacing these with durable aluminum OTRs, and capturing for recycling the 20- to 30-
percent of the OCC stream that is disposed.  The BMC should investigate a rag laundering
service and also should implement more aggressive policies  to reduce the amount of paper
waste generated and disposed, most notably UBBM and LIMs.  Facility staff showed an
openness to pollution prevention ideas and should continue to explore new options  such as
energy savings through daylighting, the Green Lights program, and procurement of Energy
Star computers, as well as more simple options such as lights out policies, double-sided
copying, and adopting an affirmative procurement policy.                   ;

       The full report  was submitted hi partial fulfillment of Contract No. 68-C2-0148, Work
Assignment 3-10 by Science Applications International Corporation under the sponsorship of
the U.S. Environmental Protection Agency.                                i       '      -

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