EPA/600/R-96/113
                                              September 1996
 POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
     UNITED STATES POSTAL SERVICE OPERATIONS
                   MERRIFIELD, VA
                          by
    Carole O. Bell, Mary Hoel, Henry Huppert, John Nuckels
        Science Applications International Corporation
                   Newport, RI02840
               EPA Contract No. 68-C2-0148
           SAIC Project No. 01-0828-07-1717-030
                     Project Officers
                          i

                    James S. Bridges
                       .   and
                   N. Theresa Hpagland
              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 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 hi Cincinnati.
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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 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 hi 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 hnplementation of innovative, cost-effective envuronmental 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 envuronmental regulations and strategies.
                                             . .  _        _  .          _.         .j

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

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

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                                     ABSTRACT

The United States Postal Service (USPS) in cooperation with EPA's National Risk Management
Research Laboratory (NRMRL) is engaged in an effort to integrate waste prevention and
recycling activities into the waste management programs at Postal facilities. This report
describes the findings of the Pollution Prevention Opportunity Assessment of the United States
Postal Service, Northern Virginia Facilities: Engineering Research and Development (ERD),
Processing and Distribution Center (PDC) and Vehicle Maintenance Facility (VMF) located in
Merrifield, VA. This assessment was conducted during the week of January 23,1995

The mission of each of the functional areas of the ERD, PDC, and VMF, including operations
performed, processes and materials employed and the wastes and emissions generated, are
described. The Assessment Team makes recommendations concerning the procurement of office
supplies, maintenance supplies and hazardous materials; management of hazardous materials;
purchase of chemicals on EPA's 33/50 list; improvement of source separation and recycling of
paper and paper products, metals, plastics, and cooking grease; management of unwanted
equipment; and other recommendations that can lead to the elimination, reduction or improved
management of the facility's solid and hazardous waste streams and emissions to air and water.

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                          TABLE OF CONTENTS
                                                                i
DISCLAIMER	,:	l	  ii

CONTACT	iii

FOREWORD	iv

ABSTRACT	v

EXHIBITS	ix

ACKNOWLEDGEMENTS	 x

INTRODUCTION	:	1

ENGINEERING RESEARCH AND DEVELOPMENT FACILITY	.3
      2.1   FACILITY DESCRIPTION	;	3
      2.2   ERD WASTE GENERATING ACTIVITIES	i...... 3
           2.2.1  Office Space and Computer Laboratories 	!....,.. 3
           2.2.2  Model Room	4
           2.2.3  Automotive Bay		4
           2.2.4  Hazardous Waste Storage Area	 5
           2.2.5  Photoprocessing Room	 5
           2.2.6.  Environmental Laboratory	 6
           2.2.7  Metallurgical Laboratory	'....,. 6
           2.2.8  Analytical Laboratory	'	6
           2.2.9  Maintenance and Loading Dock 	7
           2.2.10 Support Buildings	8

ERD OPPORTUNITIES 	:	10
      3.1   ERD HAZARDOUS WASTE GENERATION 	:	10
      3.2   ANALYTICAL LABORATORY	'.	17
      3.3   USED OIL	21
      3.4   ALTERNATIVES TO HALON FOR FIRE PROTECTION  	;...,. 22
      3.5   RESEARCH PROJECTS	25

PROCESSING AND DISTRIBUTION CENTER (PDC) 	:	26
      4.1   FACILITY DESCRIPTION	26
      4.2   PDC WASTE GENERATING ACTIVITIES	26

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Defense Environmental Network & Information Exchange (DENIX)
http://demx.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 page, select "Library" then "Pollution
Prevention" for numerous pollution prevention articles and information.
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 POLLUTION PREVENTION INFORMATION SOURCES

 Pollution prevention information sources are widespread.  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.  OPPT also operates the Pollution Prevention Information Clearinghouse (PPIC), 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 PM EST)
 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 Contact:  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/opptintr/p2home/
 This web site provides general information on pollution prevention, pollution prevention
 initiatives, and links to other pollution prevention-related web sites.

 Enviro$en$e                                                                !
http://es.mel.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.
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http://es.inel.gov/techinfo
Select "Fact Sheets" to locate the fact sheet on Hazardous Material Pharmacies.

General sources of information about the implementation of a hazardous material pharmacy
concept can be obtained at the Joint Services Pollution Prevention Conference, held each year in
August in San Antonio, TX. Visit the AFCEE web site
(http://www.afcee.brooks.af.mil/ep/epconfr.htm) for more information.

Note: The AFCEE and PRO-ACT sites were established to support Air Force activities.
Information available from these Web Sites is public domain; however, additional information
and/or hard copies of guidebooks may not be available to non-Air Force users.

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HAZARDOUS MATERIAL PHARMACY

A hazardous material pharmacy is designed to improve the control of hazardous materials, from
requisition to disposition.  The pharmacy concept encompasses authorization of the use |of a
particular material, procurement, receipt, delivery, issue, storage, use, and disposal of hazardous
materials. Most pharmacies are operated by a multi-disciplinary team, including those from
supply, safety, industrial hygiene,  environmental, and procurement. Successful pharmacies
operate on a just-in-time basis, eliminating the tendency to over-purchase and stockpile.

Benefits of a hazardous material pharmacy include:

*  Significantly decreased material usage, storage, and disposal costs.
>  Elimination of excess or expired shelf-life items.
>  Assurance that those that order hazardous materials are authorized, trained, and have the
   proper personal protective equipment required.
>  Increased awareness and emphasis on hazardous material substitutions.
>  Availability of accurate hazardous material usage data to support a variety of regulatory and
   agency-required reporting requirements.
Hazardous material pharmacies have been widely implemented in U.S. Department of Defense
installations. If there are military installations hi your area, try contacting the environmjental or
supply function to see whether they have established a program. In addition, information can be
obtained from the following on-line sources:

U.S. Air Force Center for Environmental Excellence (AFCEE) Home Page
http://www.afcee.brooks.af.mil
Select "Products & Services" to find information on hazardous material pharmacy
implementation.

AFCEE PRO-ACT Home Page
http://www.afcee.brooks.af.rnil/pro-act/main/proact4.htm
Most of the information on hazardous material pharmacies is available through "Technipal
Inquiries." However, this information is program specific and not general in nature.

U.S. Army Acquisition Pollution Prevention Support Office
http://www.aappso.com
Information on hazardous material pharmacies is available through "Newsletters" and "Reports."

Enviro$en$e


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eventual demanufacturing by simplifying and standardizing components in the earliest stages of
the design process.

The National Safety Council's Environmental Health Center has more information on recycling
computer and electronic equipment.  In cooperation with U.S. EPA and several electronics
manufactures and recyclers, they hosted the Electronics Product Recovery & Recycling
Conference hi February 1997. They can be reached at:

Environmental Health Center
A Division of the National Safety Council
1019 19th Street, NW, Suite 401
Washington DC, 20036
http://www.nsc.org/ehc.htm

For additional commercial electronics recyclers, sources of information include trade magazines
such as Waste World, (800) 678-4545, and Recycling Today, (216) 961-4130.  State and local
recycling agencies may also maintain lists of electronics recyclers. Consult your local phone
directory for listings of companies in your area.
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COMPUTER EQUIPMENT RECYCLING

Due to rapid technological advances, computer and electronic equipment are becoming obsolete
very quickly. According to a study conducted in 1991 at Carnegie Mellon University, the
number of personal computers discarded globally by the end of 1995 was estimated at 25 million.
By the year 2001, the Carnegie Mellon researchers projected a cumulative total of 150 million
personal computers disposed in landfills world-wide.

Not only are computers and electronic equipment a source of a considerable volume of solid
waste (especially glass and plastics), they have hazardous components. A printed circuit board hi
a typical personal computer is 10 percent of the total weight. Metals, such as copper, tin, iron,
lead, nickel, and zinc, constitute approximately 29 percent of the overall weight of the printed
circuit board. There has been some concern that, due to the volume of electronics disposed ki
landfills, the metals may leach out and cause environmental contamination.

Options to reduce environmental impacts, and promote reuse and recycling include:

  Donation to charitable organizations;
>  Resale of whole units through brokers, repair houses, or directly to end-users, hi the U.S. and
   developing countries;
*  Demanufacturing, or dismantling of the product in order to reuse parts, such as hard drives or
   circuit boards; and
*  Recovering and selling materials such as steel, aluminum, copper wires, and precious metals.

One source for small- to large-scale donations to schools and community groups is the Resource
for Parents, Educators, and Publishers (P.E.P.). P.E.P includes a state, national, and international
directory of agencies that facilitate donations of used computer hardware. The web site
administrator who maintains the directories, Ms. Anne Bubnic, can be reached at (415) 382-1818
or by e-mail at abubnic@microweb.com. The directories can be accessed over the World Wide
Web at ht^)://microweb.com/pepsite/recycle/recycle_uidex.html

Another list of organizations that collect and donate computers to schools and non-profit
organizations has been compiled by a computer donation enthusiast. It is available on-line at:
http://www.wco.com/~dale/list.html

Another World Wide Web resource is produced by Recyclers World. They maintain a list of
buyers and sellers of used computer items. They accept inquiries and maintain an e-mail users
group. If you do not have internet access, Recyclers World operates a helpline at (519) 767-
2913. The Recyclers World Home Page address is http://www.recycle.net/recycle/.

In the U.S., several electronic equipment manufactures such as IBM, Digital Equipment
Corporation, Hewlett-Packard, and Unisys maintain some level of "take-back" service to their
customers. Some electronics manufacturers,  such as Digital and AT&T, are seeking to.facilitate


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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.
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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:                              ;
http://www.epa.gov/greeiriights.htinl. 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:
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) 26876014 for
specific information on U.S. Postal Service involvement hi FEMP and Green Lights Programs.

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


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

The Green Lights Program in 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.

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 in its Federal
buildings by FY 1995, when measured against a FY 1985 baseline on a Bru per gross-square-fbot
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 was one of the first to
sign up as a pilot agency for this new collaborative effort.  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.  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


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The best source of technical, policy, and substitute chemical information can be obtained through
the U.S. EPA's Stratospheric Ozone World Wide Web Home Page:
http://www.epa.gov/ozone/mdex.html.  This web site contains information on the science of
ozone depletion, substitutes for ozone depleting substances, international policy, and links to
other sources of information. It can be used as a "jumping off' point for a wide variety > of
information related to ozone depletion available on the World Wide Web.

The mailing address for the Office of Stratospheric Protection is:

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

Enviro$en$e also has access to several material substitution databases. Their World Wide Web
address is: http://es.mel.gov. Select "Solvent Substitution Data Systems" for links to several
material substitution databases including those that specialize in solvents with ozone depleting
ingredients.
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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., hi cooperation with over 140 other countries, is phasing out the production of
ozone-depleting substances. In 1985, the Vienna Convention was adopted to formalize
international cooperation in stratospheric ozone protection.  Additional efforts resulted in the
signing of the Montreal Protocol in 1987. In the United States, Title VI of the Clean Air
Amendments of 1990 address the phase out of ozone-depleting substances.

There are two classes of ozone depleting substances. Class I substances,  as defined in section
602 of the Clean Air Act, include any chemical with an ozone-depleting potential of 0.2 or
greater (based on CFC-11 having a ozone depleting potential of 1.0).  Class I substances (CFCs,
carbon tetrachloride, and methyl chloroform) were phased out of production by the end of 1995
and halons were phased out by the end of 1993.  Class II substances, hydrochlorofluorocarbons
(HCFCs), will be phased out of production and use by the year 2030.  Accelerated phase outs of
the most damaging Class II substances include HCFC-141b (by January 1,2003), and CFC-142b
and HCFC-22 (by January 1,2010).

To address the availability of approved alternatives to ozone-depleting substances, 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.

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 U.S. EPA Office of Stratospheric Protection operates the Stratospheric Ozone Hotline at
(800) 296-1996. It can be accessed between 10am and 4pm EST.  They can field any technical or
policy related questions on elimination of ozone depleting substances at U.S. Postal Service
facilities.
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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                                  >   Methyl ethyl ketone (MEK)   '.
>  Cadmium and compounds                   >   Methyl isobutyl ketone (MIBK)
>  Carbon tetrachloride.                       >   Nickel and compounds
>  Chloroform                               >   Tetrachloroethylene
>  Cyanide compounds                        >   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 of the program to reduce the 17 priority
chemicals by 33% by 1992 and by 50% by 1995.  The U.S. EPA celebrated the early achievement
of the 50% reduction goal hi September 1996 when the 1994 Toxic Release Inventory data
became available for public release. Between 1988 and 1994,33/50 Program participants
reduced environmental releases and off-site transfers of the 17 target chemicals by 757 million
pounds.  Companies and organizations participate in the 33/50 Program by submitting a letter to
EPA stating their intention to participate and outlining 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.inel.goy/partners/3350/3350.html
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APPENDICES
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                                    SECTION 9.0

                    CONCLUSIONS AND RECOMMENDATIONS
       This Pollution Prevention Opportunity Assessment report documents the processes
performed, wastes generated and current waste management practices at the USPS Engineering
Research and Development facility, the Processing and Distribution Center and the Vehicle
Maintenance Facility in Merrifield, VA. 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.  Exhibits 3.1, 5.1, 7.1 and 8.1 present a summary of the major facility-specific
and facility-wide recommendations.

       Dissemination of this report will encourage application of the pollution prevention
opportunities in USPS research and development, PDC and VMF facilities nationwide as well as
other Federal facilities with similar operations.
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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
            Software and Databases

       Another source of environmental information is the Air Force Center for Environmental
Excellence (AFCEE), Pollution Prevention Directorate located at Brooks AFB in Texas. AFCEE
produces PRO-ACT fact sheets 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/indexjxt.html.
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3.    Procure computers that meet Energy Star requirements

      Future purchases of computer equipment 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 USPS should also adopt this
standard. 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 to 75 percent. 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 hi 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.

8.9   POLLUTION PREVENTION INFORMATION ON THE INTERNET

Current Conditions

      During the site visit, USPS staff indicated that they would like information on accessing
pollution prevention information through the Internet.                              ;

Pollution Prevention Opportunities

      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 the1
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 Server (WWW) 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 EPA and related organizations.  In
addition to this document the EPA's Public Information Center is available to provide assistance
                                          75

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Pollution Prevention Opportunities

1.     Become a Federal Partner in the Green Lights Program

       m many Federal buildings, approximately 25 percent of the energy consumed is for
lighting; replacement of inefficient lighting systems results in substantial energy and cost
savings. EPA 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.

       According to the New York Times of Wednesday, February 22,1995, "One of the first
Federal agencies to try this green technology was the Postal Service, which installed $300,000
worth of energy-efficient lighting in its Reno office in the early 1980s. Postal officials say that
office has saved $52,000 a year in electricity bills in the years since, more than covering the
initial costs.

        Moreover, a study of the Reno office in the late 1980s found that the better lighting
helped make the mail sorters there the most productive in the Western United States. The
officials said that the better lights helped reduce the errors the workers were making, allowing
them to achieve a productivity gain that the Postal Service calculated to be worth $400,000 to
$500,000 a year."

       See the appendices for additional information on the Federal Energy Management
Program and Green Lights. Even if the USPS chooses not to officially join the Green Lights
Program, it should still apply the principles hi order to realize the cost savings and reduce
pollution.

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. Installation of
additional motion sensors that automatically turn off the lights is another alternative. Each
kilowatt hour saved prevents formation of ah- pollutants including of 0.68 kg of carbon dioxide,
5.8 g of sulfur  dioxide and 2.5 g of nitrogen oxides.
                                           74

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                    EXHIBIT 8.4 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
Current Conditions

       The monthly energy expenditures for the ERD and Hilltop Warehouse average $25,000,
for the PDC, VMF and Prosperity and Eskridge Warehouses the monthly billing is $45,000.
Based on electric bills provided by USPS staff, the annual Merrifield facilities' expenditures for
electricity may be as high as $840,000.

       In the ERD, some attention has been given to the installation of motion sensitive lighting
in little used restrooms and computer rooms, as well as certain exterior locations.  However,
other areas present a challenge. For example, the lights in the hallways can be turned, off only at
the circuit breaker. These lights are on 24 hours a day whether the area is occupied or not. In an
ERD entryway location, USPS installed lighting that increased output in response to the amount
of ambient light. Unfortunately, these lights could not be set to distinguish between day and
night, so when the sun went down, the lights burned at full strength. Eventually these lights were
wired to timers to insure that they would be turned off at night.

       The PDC basement storage rooms, paint booth, metal shop, carpenter shop, cart repair,
and welding shops all are equipped with motion sensitive lighting.

       The Assessment Team observed that ERD and PDC staff routinely left the lights and
equipment turned on in empty offices and laboratories.
                                          73

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       The Merrifield facility should establish a formal recycling system for pine pallets.
Recyclers will repair or rebuild pallets for resale. Three pallet recyclers in the Washington, D.C.
area are:

      Valley Wood Industries Inc. (301) 488-5500                               ;
      Sheldon Wood Products Inc. (804) 566-8880                               i
      Direct Wood Products (800) 452-8333

2.      Toner Cartridges

Current Conditions

       The ERD and PDC use two laser printer toner cartridge vendors; the ERD uses both
James Collins and American Laser Recharge; the PDC uses American Laser Recharge. Several
employees at the ERD mentioned that the toner cartridges refurbished by American Laser
Recharge were of better quality.  In addition, American Laser Recharge provides prepaid mailers
to the PDC allowing them to return the cartridges through the mail. This actually provides
additional revenue for the USPS. Exhibit 8.3 below, compares the services of these two
companies.

Pollution Prevention Opportunity

1.      Select one vendor to provide toner cartridge service; negotiate a reduced price based on
       the quantity of cartridges sent for recharge.                                 ''

8.8    ENERGY

       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 and Executive Order
12902 require Federal agencies to reduce energy use.  The Energy Policy Act requires Federal
agencies  to reduce energy consumption per gross square foot 20 percent by the year 2000 and
E.0.12902 requires Federal agencies to reduce energy consumption 30 percent by the year 2005.
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 8.4.
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corrugated, USPS pays to have the corrugated collected and receives no return on the value of the
material.

       The facility receives a variety of pallets including pine, HDPE plastic, and pressboard
pallets. The PDC is currently doing an excellent job of collecting and reusing these pallets.
Postal Service employees collect wood pallets in a 30 yard open top container at the PDC
loading dock that is emptied up to four times per week. Charges include $49 per pull plus actual
landfill tipping fees averaging $115 per load. Both damaged and whole, usable pallets were
observed in this container.

       Aluminum beverage containers are collected by employees through an informal system.
Other food, beverage and paint containers are not collected for recycling.

       Merrifield staff is engaged in negotiations with several local recyclers to design and
implement a more effective recycling program.

Pollution Prevention Opportunities

1.     Multi-material recycling

       The Merrifield facilities should continue to pursue a contract for a multi-material
recycling program serving all three operations. The specifications within the contract should
include provisions for containers and processing equipment, such as balers, for paper and paper
products, where appropriate. The USPS should receive payment for recyclable paper and paper
products.  The procurement should specify both a minimum payment per ton of each kind of
paper and additional payment representing an agreed upon percentage of the  market value of the
paper grade, adjusted quarterly.  Convenient central collection points should  be established for
different paper grades.

       Recyclable scrap metal and metal food and beverage containers may be included in the
metals recycling program at the VMF or incorporated into the new procurement.  The food and
beverage containers generated by the cafeteria and both aerosol and gallon paint containers
should be included. Assistance in developing recycling options for steel and steel cans may be
obtained from  the Steel Recycling Institute, Pittsburgh, PA, (800) 876-7274.

       Local markets for recyclable plastics also are available. The Merrifield facilities generate
polyethylene terephthalate (PET) beverage containers, high density polyethylene (HDPE)
beverage containers and mail handling trays, and polystyrene (PS) and polypropylene (PP) food
service items, as well as significant quantities of polyethylene film and strapping. Mobil
Chemical Company offers a plastic film recycling program that utilizes cardboard collection
containers provided by Mobil.  When a container is filled, the lid is sealed and the box mailed to
Mobil's film recycling program in  Jacksonville, IL. For more information, contact Mobil
Chemical's Plastics Division fax line at (716) 248-4920.

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

8.6    UBBM REDUCTION

Current Conditions

       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.                 .                            ;

Pollution Prevention Opportunities                                              :

1.     To determine whether reduction or recycling is the most cost effective management
       practice for UBBM, the USPS should perform a cost-benefit 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.

2.     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.

8.7    RECYCLING

       The USPS is paying for recycling of materials that have a high market value. In addition,
substantial quantities of valuable paper and paper products are being disposed into waste
compactors, rather than diverted for recycling. The Merrifield operations are not taking
advantage of additional opportunities to source separate and recycle food and beverage;
containers, paint containers, plastic film and strapping and  other materials.

Current Conditions

       At present, recycling efforts at the Merrifield site are not coordinated among facilities and
are not operating to  the USPS's economic advantage. White paper from all three operations is
collected for recycling by Environmental Recycling Inc., but mixed office paper and
undeliverable bulk business mail (UBBM) have not been targeted for recycling. Corrugated
cardboard is collected for recycling throughout the PDC, except in the cafeteria where corrugated
is placed into the packer container for solid waste. VMF employees transport corrugated from
their building to the PDC's container. ERD employees, however, dispose of corrugated into the
trash compactor.  Although many recyclers presently are paying as much as $80/ton for
                                           69

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            the homeless or those at risk of becoming homeless are hired to help distribute the
              goods,
            needy recipients can obtain a large quantity of goods at a minimal price, and
            the amount of waste requiring incineration or landfilling is greatly reduced.

       The procedure for making a donation would be to call MAGIK and describe the items the
USPS wishes to donate. MAGIK may be able to make a direct transfer to a needy recipient mat
would allow a direct delivery to the recipient Instead of to the warehouse. However, if an
immediate match is not possible, MAGIK requests that organizations deliver the items to the
warehouse. Donations to organizations such as MAGIK may require waivers on the disposition
of accountable property. Contact GSA or USPS procurement to ensure compliance with U.S.
government procedures. For further information on MAGIK, contact Tamar Lasky at (202) 362-
4225.

8.5    PAPER WASTE REDUCTION

Current Conditions

       Personnel interviewed by the Assessment Team in purchasing, supply, laboratories and
other areas are not familiar with, and therefore do not use, the double-sided copying capabilities
of duplicating equipment. Access to white paper recycling has made employees complacent
about their responsibility to reduce paper use.

Pollution Prevention Opportunities

      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, such as:

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

     In office and laboratory settings, expand and encourage the use of electronic mail rather
      than paper memos and distribution copies.

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

     Identify opportunities to reuse paper  and paper products. 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.
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       R. Frazier. Inc.

       R. Frazier, Inc. is located in Salem, VA. The company accepts a variety of computer and
       electronic systems, such as mainframes, components, 286 systems, and telephone
       switchboards. Frazier sells certain parts for scrap metal and spare parts, while personal
       computers, monitors, and similar bits of newer hardware are typically reconditioned and
       resold through distributors. Frazier processed approximately 3,000 mainframes and
       reconditioned some 300 PCs per month in 1994. The company plans to expand the PCs
       reconditioning to approximately 3,000 per month in 1995.

       To participate in the Frazier recycling program, the ERD and PDC must develop an
       inventory unwanted material. Frazier will then assist in the logistic support for
       transporting the material. Depending on the type of material, Frazier may:

       1) Pay for the equipment
             Mainframe: 2-10 cents per Ib.
             286s: $40-$60 per unit                                           ;
             XTs:$5

       2) Pay for the freight

       3) Charge for the recycling of monitors
             Monochrome: $6 per monitor
             Color:
             $12 per monitor

2.     Donate old computers

       The ERD and PDC could participate in a local donation for reuse program such as
Movement and Acquisition of Gifts in Kind (MAGIK).  MAGIK was, and will soon be again, a
unique, non-profit clearinghouse which achieves the reuse of durable goods from the
metropolitan D.C. waste stream. MAGIK redistributed more than $17 million dollars worth of
reusable items in good and/or new condition to hundreds of non-profit organizations, including
needy individuals, shelters, public schools, libraries, and housing projects in its four year history.
Loss of government funding in 1993 caused the program to terminate. The new MAGIK will
have a slightly different structure. It will work toward becoming a self-sustaining, non-profit
business with a warehouse where goods can be donated. The items will then be resold at a
nominal cost that will cover the operating expenses of handling each donated item.

       The advantages of participating in the MAGIK program include:

            donating individuals and companies receive a charitable tax deduction instead of
             paying for disposal or warehousing of the unwanted goods,

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shipment to other Postal facilities for use; some have been donated to local schools; and others
no longer function. The computers are stored throughout the Merrifield facilities, e.g., along
every hallway in the basement of the PDQ in ERD offices and storage rooms, and at the Hilltop
warehouse. The Postal Service pays to have some of the computer equipment collected and
disposed in a local landfill during regular cleanout of the warehouse.

       Disposing of computers in landfills is an environmental concern because computers may
contain dangerous materials, such as heavy metals, that can leach into groundwater in landfills.
Some circuit boards contain high lead content, while other computer parts contain dangerous
amounts of toxic substances. Computer monitors are of particular concern because they have
high levels of lead in the glass, and mercury,  cadmium and phosphorous in the vacuum tube.

       Diverting unwanted computer equipment to a recycling company for refurbishing or sede
as scrap metal and plastic  is a cost effective alternative. The USPS will eliminate the cost of
disposing of the equipment and may actually  realize a small return on the materials. In addition,
the USPS avoids any concerns about liability associated with landfill disposal of heavy metals.

Pollution Prevention Opportunities

1.     Recycle old computers

       The ERD and PDC could send old computers to computer recycling companies for scrap
or for refurbishing. Two companies that accept old computers are Advanced Recovery, Inc. and
R. Frazier, Inc. These companies accept out-dated, unwanted computer and electronic systems
for recycling.

       Advanced Recovery. Inc.

       Advanced Recovery, which recycles out-dated computers and electronic equipment, is
       located in Belleville NJ.  The company recycles the whole unit from bolts to the entire
       plastic casing. Advanced handles approximately 400,000 pounds of computers and other
       electronic materials per month. The computers are pulled apart and stripped of metals.
   ;   The semiconductor chips are sold to parts wholesalers and computer maintenance shops.
       Functioning disc drives are used as spares; circuit boards are refined to recover precious
       metals; plastic insulation is stripped from copper cables; old microprocessors and
       memory chips end up in electronic toys; high-grade plastics are recycled; and low-grade
       mixed plastics are  incinerated for recovery of energy.

       To recycle with Advanced Recovery, the ERD and PDC must develop a list of the surplus
       equipment available and Advanced Recycling would then provide a quote.  Advanced
       Recycling will pay up to $.05 per pound for almost all electronic devices which are
       deemed obsolete or broken.  The only exception is a basic $15.00 charge for the recycling
       of the Cathode Ray Tube (CRT) and a $.05 per pound charge for scrap copier machines.

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       It is important to note that the HMICS should be designed to fit the needs of the users;
one system will not necessarily fit the needs of every area. For a HMICS to succeed, several
principles must be in place.  First, the HMICS must have the full support of USPS and Merrifield
Operations Managers. New concepts, especially innovative new programs, often meet with
resistance. The facility management must be prepared to commit funds, personnel and
equipment to make the system work. More importantly, the managers must provide leadership
and create policies stressing the importance of this concept.

       Second, the HMICS will not work unless the appropriate people are involved hi its design
and implementation.  The HMICS must be created by staff who possess in-depth knowledge of
USPS procurement specifications and operations, distribution mechanisms, inventory control,
product use, and the handling of hazardous materials and wastes. Staff members must receive
adequate training, including training in hazardous materials storage and hazardous waste
management.

       Third, the HMICS must be actively advertised and marketed. This system often meets
with resistance because-it requires a change in daily practices. To overcome this, staff members
must be informed of the reasons why the HMICS is being initiated and, more importantly, the
benefits of the system. Training the staff will greatly reduce reluctance to participate and will
ease the transition to a totally new way of doing business.

       Before considering a HMICS, Merrifield managers must address the problems associated
with separate finance numbers for each operation and the reliance on credit cards.  The Merrifield
operations may be able to establish group finance numbers for shared activities. Group finance
numbers could be established for hazardous materials management, centralizing all activities
related to the purchase, use, and disposal of hazardous materials.

       All hazardous materials acquisitions should be performed through the HMICS.  Credit
card holders should be advised that they should not purchase products containing hazardous
constituents. This will control both the type and the amount of hazardous material entering the
facilities.  Both of these issues will require research and organizational change; however, for the
HMICS to succeed they must be addressed.
8.4    DONATION/REUSE OF OLD COMPUTERS

Current Conditions

       The Merrifield ERD and PDC have significant quantities of out-dated computers in
storage. Many of the computers have been cannibalized for parts; some are earmarked for

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Requisitions and Authorization
                                      &-         '.:'   *
       Procurement of hazardous products is performed by a limited number of authorized
employees. These individuals are able to review procurement requests, authorize appropriate
purchases and coordinate distribution of materials throughout a facility. Each approved
requisition can be entered into a tracking system that follows the material from acquisition
through use.

Distribution and Collection

       Once hazardous materials are received at a facility, they come under the control of the
HMICS. The HMICS is the single point through which hazardous materials may be obtained.
Users who require hazardous materials must submit a request, which is reviewed for
appropriateness. Following the review, the staff provides the most environmentally benign
product that meets performance specifications, hi the minimum quantity necessary. Any unused
product is returned to the HMICS.  The HMICS retains unused products and makes them
available to other users or for recycling or reclamation.

Tracking and Accounting

       Regulatory requirements require facilities to closely account for all hazardous materials.
The need for accurate accounting is made more important by Executive Order 12856 which
mandates compliance with the Emergency Planning and Community Right-to-Know Act
(EPCRA). One of the principal benefits of a HMICS is its capability to provide such accounting.
The tracking system begins when a hazardous material is first ordered and continues through
receipt, issue, use and, for unused quantities, collection or return, reissue, recycling, and disposal.
This system provides a readily accessible data base that will reveal what hazardous materials are
on order or present, where they are, then* quantities, and what happens to them. Health and
safety information can also be obtained through the tracking system data base.  There are several
data-base systems that are already developed to track the materials.
                                              [
       It is important to note that all hazardous wastes generated also would be managed and
tracked through the HMICS.  This will potentially allow products determined to be waste by one
group to be used by others before disposal. This system will also allow the accurate tracking and
appropriate management of waste generated by the facility.

       The Merrifield site should establish its own Hazardous Materials Inventory Control
System to reduce the use of and improve control of hazardous materials. Ideally, one HMICS
could be established for the entire Merrifield site. However, since the ERD, PDC and VMF
currently operate independently, the USPS could establish a separate HMICS for each facility,
but coordinate record keeping to allow for transfer of materials from one facility to another to
ensure proper use and management.
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procurement mechanisms that individual employees can use to acquire products containing
hazardous constituents. Due to the nature of the procurement systems at the ERD, PDC and
VMF (see Procurement, Section 8.2), USPS exercises little control over hazardous materials
acquisition.  In the ERD alone, employees may access as many as 38 procurement mechanisms
including the procurement office, plant maintenance, stock room and 35 separate credit cards. A
common problem is that several different operations may order the same material through
different channels. Depending on usage rates, shelf life and minimum lot sizes, the potential
exists for generation of significant quantities of waste in the form of unused chemicals.  The
USPS must bear the cost and responsibility for proper disposal of excess materials during
periodic cleanups or when expired or unused materials are purged from the facility. This type of
waste represents a double cost to the USPS since the chemicals were purchased, never used, and
now must be disposed.

       It is difficult to quantify the hazardous materials entering the Merrifield facilities;since, at
present, the ERD and PDC offer no oversight of purchases of products containing hazardous
constituents and no vehicle for consolidation of records of site-wide hazardous materials
acquisitions. In addition, records relating to hazardous waste disposal are not easily accessed and
accountability for the issue and use or disposal of these materials cannot be established.
Increasingly stringent environmental and health and safety regulations and accompanying record
keeping requirements suggest that the Merrifield facilities should establish a system to manage
the acquisition and use of hazardous materials and the disposal of hazardous wastes.

Pollution Prevention Opportunities                                                !

1.     Hazardous Materials Inventory Control System

       The Hazardous Materials Inventory Control System (HMICS) is designed to reduce the
use of and improve control of hazardous materials in a facility. The U.S. Air Force and  U.S.
Navy have established a materials control system, called a Hazardous Materials Pharmacy, on
several bases throughout the United States.  These installations have achieved reductions in
hazardous materials procurement, use, and hazardous waste generation through a combination of
management controls, organizational changes  and automated information support. See the
appendices for additional information on the Hazardous Material Pharmacy concept.

       The HMICS is a three-stage approach that provides cradle-to-grave control of hazardous
materials. The HMICS provides a single point of control and management of the purchase,
distribution and use of all hazardous materials brought on site. Central control offers several
advantages.  First, waste is reduced by closely tailoring the quantities issued to the needs of the
user.  Second,  the HMICS can track inventory, reducing or eliminating shelf life expiration
problems. This saves supply dollars and reduces the risks and costs of external hazardous waste
management  Third, the HMICS can coordinate material availability across a variety of;
operations and facilitate material use or recycling to limit the generation and disposal of
hazardous waste.  The three components of the HMICS are described in greater detail below.

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 also allow for tracking of purchases of products with recycled content, as the Postal Service must
 provide bi-annual records of such purchases to the Office of Federal Procurement Policy (OFPP).
 Ideally, this new computer system would 6e used by trie central procurement office; however.,
 realistically, a new tracking system should be used by each office performing procurement
 functions.

 3.     Reduce the number of credit cards in use and develop a unified system to track credit card
       purchases, either within each operation or site-wide.

       This will reduce individual purchases of products with EPA 33/50 and other hazardous
 chemical constituents.

 4.     Purchase products with recycled content.

       The Merrifield facilities should establish preference programs and adopt specifications
 for the purchase of products made with EPA specified percentages of recovered materials.

 5.     Train procurement staff

       Changes in the procurement system will create staff training opportunities. In addition,
 staff members have requested training on Federal affirmative procurement requirements.

 6.     Chemicals on the EPA 33/50 List

       Enforce restrictions on the purchase and use of items or supplies containing the 17 listed
 chemicals until the Hazardous Materials Inventory Control System is operational (see HMICS
 below).

 8.3    HAZARDOUS MATERIALS INVENTORY CONTROL SYSTEM (HMICS)

       A Hazardous Materials Inventory Control System establishes a single point of purchase
 and issue for all products and materials containing hazardous constituents. Such a system
 eliminates redundant purchases, discourages improper storage and stockpiling of chemicals,
 encourages reuse and recycling, reduces hazardous waste generation and disposal, and facilitates
 hazardous waste disposal record keeping. At Dover Air Force Base, the hazardous materials
pharmacy manages 813 items and supports 33 shops. In its first year of operation, the pharmacy
has reduced purchases by one third and saved approximately $500,000. In addition, reduction of
 excess material saves $11,000 and shelf-life extensions produced an additional $8,000 in savings.

 Current Conditions

       Overall, the Merrifield facilities do not have adequate control over the acquisition, use,
 storage and disposal of hazardous materials. Contributing to this problem are the multiple

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Vehicle Maintenance Facility (VMF)                                             '         .

       The VMF also maintains its own procurement system to order supplies for its operations.
Within the VMF, materials may be purchased using purchase orders, credit cards, blanket
purchasing agreements and national contracts. The VMF maintains records of all purchases,
including credit card purchases; if necessary, the VMF could identify and monitor all purchases
on a monthly basis.

       Purchase orders are used for local purchases. Each purchase order must be approved by
the Vehicle Supplies Supervisor, to certify payment and control the quantity of hazardous
materials on site. All hazardous materials bought with purchase orders must have an MSDS and
be entered into the Hazardous Materials Database. Approved purchase orders are then sent to the
accounting office. Orders under $700 are paid by money order; orders over $700 are paid with a
treasury check.  A computerized cash log is used to monitor the purchase orders.
                                                                              i
       The VMF has eight credit cards; however, only the supply storekeeper, the tool clerk and
the parts clerk use the cards on a regular basis.  Each credit card purchase must receive written
approval from the shop supervisor and be entered into a credit card log.  The log includes
information about the item purchased, the vendor and the cost. This is a manual system.

       Bulk purchasing agreements allow the VMF to set up pre-approved accounts with
specific vendors for certain items. When orders are filled, the amount is debited from the
account. Materials frequently procured through bulk purchasing agreements include oils and
lubricants. National contracts are currently used for repair parts and brake fluid only.

Pollution Prevention Opportunities

1.     Establish a centralized procurement system

       The Merrifield facilities should establish one central procurement system for those
products, such as cleaning supplies and paper and paper products, utilized throughout the entire
complex.  Purchase orders from each facility could be channeled through a central procurement
office. This would eliminate wasteful duplication of purchases and inconsistent procurement
standards and provide for the benefit of economies of scale.  A barrier to the feasibility iof this
recommendation is the USPS system of separate finance numbers for individual facilities.  To
overcome this barrier, the Merrifield facilities may be able to establish group finance numbers for
the three organizations. A new system for distribution of materials would also have to be
developed.

2.     Install new tracking software

       The Postal Service should develop or purchase new computer software that simplifies
material tracking and allows for monthly procurement summary reports. The program should

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 Current Conditions

 Processing and Distribution Center (PDC)
                                                '"'
       The PDC includes two divisions: PDC and Customer Service; each division maintains a
 separate procurement system.  The PDC has a purchasing office that procures materials solely for
 PDC functions. In addition, ten PDC employees have credit cards which allow them to utilize
 multiple suppliers. There is no system in place to track the credit card purchases.

       Materials that the PDC purchasing office typically orders include custodial supplies
 (cleaners, detergents, insecticides) paper and paper products (computer paper, photocopy paper,
 toilet tissue), trash bags and paint, as well as degreasers and machine parts. Purchasing Office
 staff informed the Assessment Team that the PDC had sent a memo to all buyers and suppliers
 informing them that the Postal Service would no longer purchase products containing the 17
 chemicals on EPA's 33/50 list.  Despite the memos, however, a variety of materials containing
 these 17 chemicals were found throughout the facility.

       The Customer Service Division has a separate procurement system, acquiring supplies for
 its offices in the PDC as well as the Northern Virginia district offices.  The supplies are stored hi
 the Prosperity Street warehouse across the street from the PDC. The warehouse is stocked
 primarily with paper and paper products. The  warehouse also stores office supplies, such as pens
 and pencils, as well as computer equipment. Two employees are located hi an office within the
 warehouse; they are responsible for ordering supplies after receiving authorized request forms.
 Again, several Customer Service employees have credit cards to purchase supplies. Some offices
 use a computer tracking system for the purchases made with their own credit cards. None of the
 supplies found hi the Supply warehouse contained recycled material.

Engineering Research and Development (ERD)

       The ERD appears to have the most complex procurement system within the Merrifield
facilities. Supplies can be obtained through the procurement office, plant maintenance
supervisor, stock room personnel, or credit cards.  The procurement office can order anything
under $100,000, including computer equipment, software, cancelling machines, nuts, bolts, wire,
cleaning supplies, office supplies, hazardous materials, and material for satchels. The plant
maintenance supervisor orders supplies for plant maintenance, including cleaning supplies, paper
products (towels, toilet tissue, toilet seat covers), handsoap, gum remover and trash bags. The
stock room personnel order approximately $2,000 - $3,000 worth of office supplies from GSA
each month. Exact figures are not available because GSA automatically bills the Postal Service
and cost figures are not sent to ERD. Office supplies typically include computer paper (20 boxes
of 2500 sheets per month), photocopy paper (400 reams per month), envelopes, computer disks
(1,000 disks per month), pens, pencils, tape and glue. Only the photocopy paper contains
recycled content. For all other purchases, credit cards are used. ERD has issued 35 credit cards
to facility employees, and does not keep centralized records concerning credit card purchases.
                                          60

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EXHIBIT 8.2 EPA MINIMUM RECOVERED CONTENT LEVELS
Category/Product
Percent Recovered Content
Paper ,
High grade bleached printing and writing paper
Mimeo and duplicator paper
Computer paper
Envelopes
20%
20% :
20%
20%
Tissue Products
Toilet tissue
Paper towels
Paper napkins
Facial tissue
20-100%
40-100%
30-100%
10-100%
Unbleached packaging
Corrugated boxes
25-50%
Vehicular Products
Lubricating Oil (re-refined oil)
Tires
25%
retread tires
Construction Products
Fiberglass (glass cullet)
Cellulose loose-fill and spray-on (postconsumer paper)
Structural fiberboards
Laminated paperboards
Cement and Concrete (coal fly ash)
Cement and Concrete (ground granulated blast furnace slag)
Polyester Carpet Face Fiber (PET resin)
Patio blocks (rubber or rubber blends)
Patio blocks (plastic or plastic blends)
Floor tiles (rubber)
Floor tiles (plastic)
Transportation products
Traffic cones (PVC, LDPE, Crumb Rubber)
Traffic barricades (HDPE, LDPE, Pet Steel)
Traffic barricades (Fiberglass)
Park and Recreation Products
Playground surfaces (rubber or plastic)
Running tracks (rubber or plastic)
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 '
Paper-based hydraulic mulch (postconsumer recovered paper)
Wood-based hydraulic mulch (recovered wood and/or paper)
100%
100%
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
20-100% ;
25-100%
25-80%
25-50%
80%
10-100%
                        59

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 identification number.  It is not possible, for example, to do a summary report of items ordered
 for a month. According to Merrifield procurement managers, a number of attempts have been
 made to acquire a new tracking system; however, these attempts have bogged down in the USPS
 approval chain.

       The decentralized nature of the procurement system at the Merrifield facility leads to
 inconsistent purchasing practices and procurement standards. For instance, the PDC procures
 toilet paper with recycled content, while the ERD does not. Further, both the PDC and VMF
 have cleaning product dispenser units which measure exact amounts of product for use, while the
 ERD does not have such systems. Since these systems reduce the quantity of cleaning products
 purchased and used and save money, it is difficult to understand why they were not purchased for
 all operations at one time.

       The United States Postal Service Waste Reduction Guide (AS552, February, 1992, p.  32)
 directs Requiring offices to  "review purchase specifications to eliminate prohibitions or
 limitations on use of recovered materials." In addition, specifications should be modified 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 Materials (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 papers, re-refined oils, engine coolant, trash bags, toner cartridges,
 binders and desktop accessories. The guidelines provide information about the recommended
percentage of recovered material, product availability and performance, and specification
 language.

       In Executive Order (E.G.) 12873, October 22,1993, President Clinton directs agencies to
develop and implement affirmative procurement programs for all EPA guideline items and
ensure that these programs require that 100 percent of their purchases of products meet or exceed
the EPA guideline standards. Although the USPS is not an Executive Agency, it is Postal
Service policy to adhere to Executive Orders whenever feasible. Exhibit 8.2 presents selected
products for which EPA has established minimum recovered content levels.

       Neither the ERD nor the PDC is able to document successful implementation of EPA
procurement guidelines for products manufactured with recovered content. In addition, neither
facility can demonstrate successful elimination of the 17 products on EPA'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.

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8.1    SITE-WIDE CLEAN-UP EVENT

       The operations at the Merrifield facility would benefit from an overall cleanup of wastes,
recyclables, and unused and unusable products and equipment. There will be costs associated
with waste transportation and disposal of wastes generated from such an event. However,
following the cleanup, each operation will be in a better position to initiate changes in the:

       purchasing of supplies, equipment and materials,
       management of both hazardous and non-hazardous products,
       tracking of use and disposal of materials, products and equipment,
       efforts to reduce waste generation,
       kinds of materials separated for recycling, and
       mechanisms for processing and sale of recyclables.                         ',
                                                                             r
8.2    PROCUREMENT

       Procurement at the Merrifield facilities is a complex, de-centralized activity, utilizing a
variety of avenues for the purchase of products and materials. Each operation, the ERD, PDC
and VMF, has its own procurement system and, within each system, there are several instruments
for procurement of goods and services. ERD, for example, has as many as 38 separate
procurement agents including the procurement office, plant maintenance supervisor, stock room
staff and 35 separate credit card holders.  Because of the de-centralized nature of USPS
procurement functions, there is no simple mechanism to consolidate purchasing and/or
procurement record keeping throughout the Merrifield facilities. Procurement tracking also is
complicated by the use of credit cards and outdated, inefficient software for procurement record
keeping.

       Credit cards were introduced into the procurement system in 1989 to remove layers of
bureaucracy and to allow employees some independence hi their purchasing. Under the new
Federal Acquisition Streamlining Act, authorized Federal employees may make credit card
purchases up to $2,500. At Merrifield, a request form must be completed and approved by a.
manager. Following this approval, any material or product can be purchased on a credit card.
However, the Merrifield facilities have not instituted a system to track these credit card
purchases. On a monthly basis, the statements are simply reconciled and filed.  If information
regarding a specific purchase or product is needed, it cannot easily be recalled.  Some offices use
a computer to track their credit cards; however, this is not a common practice.        :

       Each Merrifield facility maintains a separate procurement office and a separate
computerized ordering/tracking system.  Some results of the lack of coordination between the
facilities on procurement matters are duplication of purchases and inconsistent procurement
standards.  Procurement record keeping systems are extremely inefficient, with no easy method
to search for purchases within a specific tune frame or class of materials. To search the records,
specific keywords must be used, such as the distributor or vendor's name or specific item

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                                 SECTION 8.0
            SITE-WIDE POLLUTION PREVENTION OPPORTUNITIES
      This section describes pollution prevention opportunities that have the potential to affect
waste generation and waste disposal quantities and costs at multiple operations on the Merrifield
site.  Exhibit 8.1 presents the site-wide waste generation issues and potential pollution prevention
opportunities.

  EXHIBIT 8.1 MERRIFIELD WASTE SOURCES AND POLLUTION PREVENTION
  OPPORTUNITIES
Waste or Waste Source
Procurement
Material Control and Distribution
and Waste Management
Computer Equipment
Paper Waste and UBBM
Toner cartridges
Energy
Source
All operations
All operations
All operations
All operations
All operations
All operations
Pollution Prevention Opportunities
Centralize procurement
Establish material tracking system
Reduce credit card purchases
Purchase products containing recycled
content
Eliminate purchase of products with EPA
33/50 chemicals
Establish Hazardous Materials Inventory
Control System (HMICS)
Repair broken equipment
Recycle obsolete equipment
Perform duplex copying
Use electronic mail
Limit distribution lists
Reuse envelopes, paper and packing
materials
Recycle paper and UBBM
Return for remanufacture
Purchase remanufactured cartridges
Establish lights out policy
Use motion sensitive lighting where
appropriate
Procure Energy Star compliant computer
equipment
                                       56

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Pollution Prevention Opportunities
                                                                             I
1.      Re-refined motor oil

       EPA finalized the Procurement Guideline for Lubricating Oils Containing Refined Oil,
40 CFR Part 252, 53 FR 24699 (June 30,1988). The VMF should rewrite procurement
specifications for re-refined motor oil.  Several other VMFs have converted to re-refined oil and
have been pleased with the product.  Sources of re-refined lubricating oil include:

Great Northern Petroleum Inc.
5 Churchill Drive
York, PA 17403
Phone:       (717) 741-3839
Fax:         (717)741-0931

Safety-Kleen Oil Recovery
6325 Joliet Road
Countryside, IL 60525
Phone:       (312)229-1500
Fax:         (312) 229-0666

Enviropur Waste Refining & Technology, Inc.                                    :
7601 West 47th Street
McCook, IL 60525
Phone:       (708) 442-6000 ext. 1220
Fax:         (708) 441-6027

2.      Synthetic oil
                                             I                                '
       The VMF should consider using synthetic oil in the vehicle engines to reduce oil usage
and labor time. Synthetic oils are graphite-based lubricants that can be used to replace petroleum
derived lubricants.  Synthetic lubricants are more resistant to thermal breakdown than petroleum
lubricants and last longer under normal operating conditions Synthetic oils adhere better to
engine parts and provide better lubrication during initial engine start-up. Manufacturers' test
results show that synthetic oils last up to 15,000 miles under normal operating conditions, protect
engine oils better than conventional oils, and improve fuel economy and extend engine life. The
cost of synthetic oil is approximately eight tunes greater than the cost of conventional oil;
however, the reduced labor costs and increased engine lifespan balance the additional costs.
                                          55

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some fresh coolant with the recycled product.  The recycling unit generates spent filters which
may be a hazardous waste due to metals content.  Distillation systems reportedly attain higher
levels of cleanliness than filtration system because distillation removes more of the
contaminants, particularly the metals.  The distillation unit does not generate any additional
wastes.  Exhibit 7.4 presents a cost-benefit analysis for an antifreeze distillation unit.  The
$1.87/gallon cost for running the antifreeze unit is provided by the manufacturer, Finish
Thompson, and includes electricity, water and chemicals for a 15 gallon run of 50/50 used
coolant.

   EXHIBIT 7.4  COST/BENEFIT ANALYSIS: ANTIFREEZE DISTILLATION UNIT
Capital Costs
Finish Thompson Inc. Coolant Quick Changer
Transportation
Installation
Total Capital Costs
Operating and Maintenance
Costs
Purchase cost ($2.00/gal)(60 gallons assuming 10 percent fresh antifreeze is added)
Treatment cost ($1.87)(600 gallons) . ' .
Disposal cost (.10)(600 gal)(l
Avoided Costs
American Fluid Technologies

drum/50 gal)($125/drum)
Total O&M Costs

contract
Total Avoided Costs
Net Annual Benefit = Avoided Costs - O&M

$1,325
$ 100
none
$1,425

$ 120
$1,122
$150
$1,392

$1,463.75
$1,463.75
$ 71.70
7.6    ENGINE OIL
Current Conditions
       The VMF maintains predominantly larger trucks and expects to get 300,000 to 400,000
miles from each engine.  The VMF staff believe that to obtain this performance, the VMF
needs to use virgin high-grade oil in its vehicles.  Last year, the VMF generated 2,625 gallons
of waste oil which was collected by the Eastern Oil Company.
                                           54

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vehicles (LLVs), and passenger vehicles, are washed per week.  Each vehicle is initially
rinsed using a garden hose to remove excess dirt. Then, the vehicle is manually washed using
a brush and soap and water from a bucket. Following this step, the vehicle is washed with a
pressure washer. Finally, the vehicle is rinsed again with the garden hose to remove the soap.
The wash rack employs two types of soap: ZEP Formula 300 for the manual brush washing
and Film Fyter soap in the pressure washer.  The soaps are purchased hi bulk.
Approximately, 400 gallons of ZEP 300 are used annually.

Pollution Prevention Opportunity

1.     Install recirculating water system

       The VMF should improve the wash rack and install a water recirculation system. In
FY 95, the USPS intends to upgrade the VMF wash rack to install a recirculating water
system for the pressure washer.  Current plans call for a contractor to close the existing pipe
to the oil/water separator and install a link to a collecting sump.  From the sump, the water
will be pumped to a reclamation unit which will filter the water and then direct it back to the
pressure washer.

       To  add to the efficiency of the recirculating system,  the VMF should upgrade the
current garden hose and nozzle to a more efficient system.  These technologies will greatly
reduce the  water usage and amount of water released to the sanitary sewer.

7.5    PURCHASING ON-SITE ANTIFREEZE RECYCLING UNIT

Current Conditions

       The VMF generates large quantities of used antifreeze from its vehicle  maintenance
activities.  As policy, the VMF flushes out the antifreeze system in each vehicle once every
three years. The VMF generates about 600 gallons  of waste antifreeze per year or 90 gallons
every two months.  The antifreeze is collected in 55 gallons drums and stored  for recycling.
The VMF contracts American Fluid Technologies to come on-site and recycle  the antifree2:e.
In 1994, the VMF paid $1,463.75 to recycle the antifreeze.  In addition,  the VMF purchases
two  55 gallon drums of fresh antifreeze as makeup at a cost of approximately  $200.

Pollution Prevention Opportunity

1.     Purchase on-site antifreeze recycling unit

       The VMF should consider purchasing an dn-site antifreeze recycling unit.  Antifreeze
recycling technology has improved over the past few years. There are two types of recycling
technologies; filtration systems and distillation systems. Filtration systems  rely on a series of
fine mesh filters to remove suspended matter from the coolant. The pH  is  adjusted and new
inhibitor is added to restore the properties of the coolant.  It may still be necessary to mix


                                           53

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Pollution Prevention Opportunities
                                     S..            r
I.     Move the Aqueous Parts Washer

       The VMF should move the aqueous parts washer from the wash rack to a more
central, easily accessible location in the facility.  It should also be hooked up to a water
supply system to eliminate the need to add water manually.  The VMF should also contact the
parts washer supplier to determine whether there are devices that can be used to hold smaller
parts hi place during machine use. If the aqueous parts washer is too big for VMF needs,
perhaps this machine can be moved to the ERD model shop and a smaller machine can be
purchased and installed in the VMF.  The shop supervisor should encourage the use of the
aqueous parts washer to reduce the use and disposal of hazardous materials.

2.     Drain Parts Longer to Reduce Dragout Losses

       Workers should be instructed to allow cleaned parts to drain completely prior to
removal. This will reduce solvent dragout with the parts and reduce solvent losses.

7.3    HAZARDOUS MATERIALS STORAGE

Current Conditions

       The VMF stores some bulk hazardous materials, including detergent and antifreeze, hi
the wash rack room.  These materials are stored on pallets; however, they are not protected
from exposure to the water from the washing operations. Some of the drums were rusting,
and any spills from these drums could potentially flow into the wash rack dram.  The drain is
connected to a oil/water separator, but this will not separate the hazardous materials.

Pollution Prevention Opportunity

1.     Move Hazardous Materials Storage

       The VMF should either move the bulk hazardous materials from the wash rack or
install, a barrier, such as a wall, to protect  the materials from  exposure to the water.  This will
keep the drums dry and prevent rusting which could potentially lead to a spill or leak. In
addition, as a temporary measure, the drums should be bermed to further reduce potential for
hazardous materials to reach the wash rack drain.

7.4    WATER RECIRCULATING  SYSTEM FOR WASH RACK

Current Conditions

       The VMF contains a wash rack which is used to wash the vehicles following
maintenance activities.  Approximately 30 vehicles of all types, including trucks, long life


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3.     Paint can reduction and recycling

       Paint is presently purchased in gallon metal containers, and empty cans are drained and
thrown in the trash.  It may be possible to order paint in 5 gallon reusable plastic pails.  Empty
pails would be picked up by or returned to the supplier. Since the VMF uses a limited number of
colors, buying hi bulk may prove feasible. The existing paint supplier should be contacted to
determine whether they offer bulk purchases in reusable containers. Only those colors that are
used on a regular basis should be bought in bulk. It is unwise to purchase paint in bulk if the
product is likely to dry out or expire prior to being consumed.

7.2    AQUEOUS PARTS WASHER

Current Conditions

       The VMF has one aqueous parts washer which is intended to be used to clean automotive
parts. The parts washer is currently located in the wash rack, at the far end of the building.  This
location means that employees may get wet while using the equipment. The VMF recently
installed an electrical outlet for the parts washer and is waiting to install plumbing. Until the
plumbing is installed, water must be added to the machine manually. In addition, employees
complain that smaller parts are thrown around inside the parts washer because of the pressure.
Because of the location and the other factors, the aqueous parts washer is not frequently used by
VMF staff.

       Instead, solvent sinks are used to clean the parts. The VMF has four solvent sinks: three
new ZEP sinks and one Safety Kleen sink. Previously, all four sinks were serviced by Safety
Kleen. The previous Safety Kleen sinks did not contain filtration systems and required a regular
solvent change-out every six weeks. During FY 94, the VMF generated 891  gallons of solvent
and paid $3,844 to dispose/recycle this solvent.

       The ZEP sinks contain petroleum naphtha solvent and have a filtration system.
According to the shop supervisor, the only waste from the ZEP sinks are the filters, which must
be changed when they are spent. It is estimated that the ZEP sinks will generate approximately
five filters per sink per year.  Disposal costs are estimated at $65-70 per year. The solvent is not
emptied from the sinks; instead it is filtered and fresh solvent is added when needed.
Approximately 20 gallons of solvent is expected to be added to the ZEP sinks each year. The
solvent costs $8-$9 per gallon.  The new Safety Kleen sink also has a filtration system; however,
the entire contents, 30 gallons of solvent, must be changed-out once every two years.
                                           51

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      The parts washer recycles the cleaning medium,
      VOC emissions are reduced as much as 75-90 percent compared to a solvent sink,
      The washing cycle (labor cost) decreases to 30^60 seconds versus 5-20 minutes for
       manually cleaning,
      The gun washer uses less solvent both because it reduces solvent loss from evaporation
       and because of the shorter cleaning cycle,
      The spray guns are cleaned more effectively with the gun washer, and
      Worker exposure to toxic substances is decreased.

       A cost benefit analysis for the installation of a paint gun washer station was performed
for the Buffalo, NY VMF and is presented in Exhibit 7.3. The assumptions on which the
analysis was based included: virgin solvent costs of $8 per gallon and a time commitment of 30
minutes per day to effectively clean the paint gun. The analysis indicated a three month payback
period.

     EXHIBIT 7.3  COST/BENEFIT ANALYSIS: PAINT GUN WASHER STATION
Capital Costs
Mini PRO Wash
Transportation
Miscellaneous parts
Total Capital Expenditures
Annual Operating Costs
Miscellaneous replacement parts
Avoided Costs
Avoided solvent purchase (50 percent reduction)
Labor savings (75 percent reduction)
Disposal Costs
Total Annual Avoided Costs
Net Annual Benefit (NAB) = Avoided Costs - O & M
Pay Back Period = Capital Costs/NAB

$995
100
100
$1,195
$100
$1,560
2,437
827
$4,824
$4,724
3 months
2.     Templates for windows and other parts

       The Postal Service currently uses paper and masking tape or a plastic peel-off masking
material good for only one use. Both of these masking systems generate large quantities of
waste.  To reduce paper and tape usage, USPS staff could develop plastic templates for
commonly covered vehicle parts, such as windows. These templates could be reused for
numerous paint jobs thereby eliminating paper and tape usage and associated wastes.
                                          50

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the best approach, for now, is to use a water-based primer and a low VOC color top coating. The
acrylic paints previously in use emitted approximately seven pounds of VOC per gallon. The
Buffalo VMF estimates that if they use a water-based primer and low VOC color top coat paint
(i.e., three pounds of solvent per gallon), then they will reduce VOC emissions by nearly 60
percent.

       The GSA Supply Catalogue lists a variety of low VOC coatings for properly prepared
metal surfaces.

Electrostatic spraying

       Electrostatic spraying involves using an electrical transformer capable of delivering up to
60,000+ volts to create an electrical potential between the paint particles and the surface of the
vehicle. These charged paint particles are thus electrically attracted to the surface, increasing
transfer efficiency. Each electrostatic gun costs between $3,000 and $5,000 (including gun,
power cable, and power supply).  The compressor, hoses, and ah- regulator for each system can
cost an additional $2,000 to $3,000.

Plural paint application system

       For the paint to set properly, the paint must be mixed with a reducer.  If too much paint
has been mixed and there is excess paint, the excess must be disposed as waste since the mixed
paint and reducer must be applied within three to four hours before it sets. A new commercially
available spray gun mixes the two part paint hi a mixing manifold near the spray gun. This
eliminates the need to mix two part paint in a container. The only waste from this system is the
paint in the spray gun, manifold and tubes from the manifold to the spray gun. This system can
greatly reduce the amount of waste from paint mixing operations.

Paint mixer system

       The amount of paint needed for a job and the mixture of paint thinner is measured by the
painter using best professional judgment. An inexperienced painter may produce improperly
formulated paint and/or excess paint which must be disposed. Commercially available paint
mixers accurately measure and weigh the amount of paint that needs to be mixed, according to
manufacturer's specifications. Paint mixing  equipment carries a capital cost in the range of $250
to 400 dollars and is easy to install. Benefits are immediate because technicians always prepare a
perfect batch of paint ha the exact quantity needed.

Paint gun -washer station

       Paint gun washer stations provide a more efficient means of cleaning spray guns. HVLP
guns require better cleaning than conventional guns and gun washers can make a difference in
maintaining their high performance.  The advantages of a gun washer system include: ;

                                           49

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    EXHIBIT 7.2  COST/BENEFIT ANALYSIS: HVLP PAINT APPLICATION
                                      SYSTEM   ,
                          Capital Costs
  HVLP System
         Installation (labor 1 hr. @ $25/hr)
         Training (20 hrs. implementation/start-up cost @ 25/hr)

                Total Capital Expenditure	
    $ 385

       25
      500

    $ 910
  Annual Operating and Maintenance Costs

         Misc. replacement parts
         Energy requirement (approximately equivalent to existing levels)
         Labor (approximately equivalent to existing levels)

 	Total Annual Operating and Maintenance Costs
    $ 100
     none
     none

    $ 100
  Annual Avoided Costs
         Avoided Paint Purchase by 50 percent (0.5 x 12,304)
         Paint Filters (half as many filters are needed $2,348 - $1,174)
         Disposal Cost Reduction (30 percent less waste paint is generated)

                Total Annual Avoided Costs
    $6,152
     1,174
      195
                                                                             $7,521
                Net Annual Benefit (NAB) = Avoided Costs - O&M

                Pay Back Period = Capital Costs/NAB
    $7,421

1.4 months
Water-based coatings

       There are a number of alternative low VOC emitting paints or coatings available.  These
include water-based electrocoating, water-based non-electrocoating, two component high solids,
single component high solids, and isocyanate free paint. Water-based coatings are formulated
with water instead of organic^ solvents. The average solvent based coatings release five to six
pounds of solvent per gallon. Water-based coatings emit between 0.5 and 3.4 pounds of solvent
per gallon. Water-based coatings also clean up with soap and water, totally eliminating organic
solvent clean up waste.  Water based non-electrocoatings are most compatible with VMF
operations and offer the USPS the greatest opportunity to significantly eliminate paint-related
hazardous waste.

       The Buffalo VMF has investigated water-based paints and found that water-based
primers meet performance standards.  However, water-based paints used for color top coatings
do not have the durability that automotive use requires. The Northeast area has determined that
                                            48

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Pollution Prevention Opportunities

1.     Build a new paint booth

       The Merrifield VMF should build a new, sophisticated paint booth to replace the out-
dated booth currently in use.  The new paint booth should employ several pollution prevention
technologies to reduce waste generation from this activity. A description of these technologies is
provided below.

HVLP spray guns

       High-volume, low-pressure (HVLP) paint application equipment involves the use of a
turbine to generate and deliver atomized air.  The turbine draws hi filtered air which is driven at
up to 10,500 revolutions per minute producing a high volume of warm, dry atomizing air
delivered to the spray gun at less than seven pounds per square inch (psi). This low-pressure air
gives greater control of the spray, reducing overspray and paint fog. The primary advantage of
an HVLP system is reduction in VOC emissions. Secondary advantages include reduction hi
paint overspray and associated reduction hi raw material costs since less paint is needed to cover
the same area.  In addition, because less overspray is collected hi the paint filters, fewer
replacement filters are needed.  A basic one-gun HVLP system costs $400.

       A cost benefit analysis of an HVLP paint application system was performed for the
Buffalo, NY VMF and is presented in Exhibit 7.2. This analysis assumed paint purchase costs of
$12,304 for 600.5 gallons of paint and $592 per year hi disposal costs for 277.3 gallons of paint
waste and thinner.

       The Buffalo VMF purchased two HVLP  guns at a cost of $400 each. According to
progress reports, staff acceptance of these low pressure guns has been excellent.  After the
training period, the painter has not wanted to use the old high pressure paint guns. Paint jobs are
better with more gloss due to thicker coating than was possible with the conventional spray guns.
During a four month test, the Buffalo VMF used 20 percent less paint resulting hi savings of
$1,332.                                                                        ;
                                           47

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      EXHIBIT 7.1 VMF WASTES SOURCES AND POLLUTION PREVENTION
                                 OPPORTUNITIES
Waste
Corrugated Cardboard
Mixed paper
Cleaners, degreasers and paints
with ozone depleting or EPA 33/50
chemicals
Spent solvent
Paint, paint cans, paint filters
Wash Rack Water
Antifreeze
Waste Oil
Metal
Oil Filters
Tires
Source
Materials delivery
Office
Shop floor
Shop floor
Paint booth
Wash rack
Shop
Shop
Shop
Shop
Shop
Pollution Prevention Opportunities
Use reusable containers
Recycle old corrugated cardboard
Double sided copies
Reuse paper and envelopes
Recycle
Deplete existing stock of materials and
replace with non-ODC containing
substitutes.
Replace with aqueous or semi-aqueous
substitute that does not generate a
hazardous waste.
Move aqueous cleaner
Construct new paint booth with better
painting technology
Install water recirculating system
Purchase on-site recycling unit
Use rerefined motor oil or synthetic oil
Recycle
Recycle
Use recapped tires
      In FY 94, the paint shop generated 632 pounds of hazardous waste, including paint,
solvents and paint filters. The VMF paid Safety Kleen, the hazardous waste contractor, $1,029
to dispose of these wastes.

      The Merrifield VMF is planning to construct a new paint booth hi the near future.
Currently, the shop supervisor is consulting with a local engineering firm regarding the
requirements for the new booth. Once the new paint booth is completed, repair and painting
activities are expected to increase significantly.
                                         46

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                                     SECTION 7.0

                 VMF POLLUTION PREVENTION OPPORTUNITIES
       This section describes the pollution prevention opportunities for the VMF. Exhibit 7.1
summarizes the wastes generated in VMF operations and potential pollution prevention
opportunities.

7.1    PAINT BOOTH

Current Conditions

       The paint booth at the VMF is out-dated and in need of upgrading. The current paint
booth is a separate room with an old fresh air system which draws in and heats outside ah- prior
to pumping it into the paint booth.  Then, an updraft sucks the air through dry filters, after which
it passes through ducts and finally exits through a vent on the roof. The paint technician uses a
respirator during painting activities; however, other personnel protective equipment (PPE), such
as coveralls, are not in use. There are six 28" x 28" filters in the paint booth.  The filters are
changed an average of once every 2 months; if the workload is heavy, the filters are changed
monthly. When spent, the filters are placed in a drum for disposal as hazardous waste.

       Most of the work conducted in the shop is minor body work and spot painting to repair
scratches and dents. The paint shop handles approximately five of these repair and paint jobs per
week.  Two staff positions are assigned to the paint shop; however, only one employee currently
works there. This person is responsible for both the body work and the painting. On occasion,
entire vehicles are painted in the paint booth. In 1994, a total of five vehicles were painted in the
booth, while others were sent to a local body shop for painting.

       Monthly consumption of paint, reducer, and primer is approximately  20 gallons. The
paint is purchased in gallon containers from a local supplier, and stored on site.  The paint booth
is equipped with a conventional hand-held spray gun, which has a transfer efficiency of 35
percent. This rate of transfer means that approximately 65 percent of the coating fails to deposit
on the vehicle, resulting  in product loss and VOC emissions. The paint booth also has a spray
gun cleaner, but it is not  clear whether the machine is used on a regular basis.
                                          45

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include solvent-based paint, solvent, paint filters, rags, and paint mixers. In 1994, the paint shop
generated 632 pounds of hazardous waste,

6.2.3  Wash Rack

       The Wash Rack is used to clean the vehicles after maintenance activities.  Approximately
30 vehicles, ranging in size from passenger vehicles to trucks, are washed per week.  The
vehicles are first rinsed using a garden hose to remove excess dirt. Then, the vehicle is manually
washed using a brush and soap and water from a bucket.  Following this, the vehicle is washed
with a pressure washer. Finally, the vehicle is rinsed again with the garden hose to remove the
soap. The wash rack uses two types of soap: ZEP Formula 300 for the manual brush washing
and Film Fyter soap in the pressure washer. Approximately, 400 gallons of ZEP Formula 300
are used annually.  VMF staff was unable to quantify water use for the wash rack. The wash rack
generates wastewater containing dirt, grease, oil, and soap; the wastewater drains to the sanitary
sewer.

6.2.4  Administrative Offices and Supply Room

       The administrative offices and supply room are located in the middle of the VMF. The
significant wastes from these areas include paper (computer and white paper), corrugated
cardboard, packaging materials and food wastes. The administrative offices have paper recycling
containers, and the custodial staff collects the paper and takes it to the central white paper
collection area in the PDC.
                                          44

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ZEP sinks are the filters which must be changed when they are spent. It is estimated that the
VMF will generate approximately 15 filters annually from the three ZEP sinks. Approximately
20 gallons per year of solvent are expected to be used to add to the ZEP sinks as a result of
dragout and evaporation from the sinks. The Safety Kleen sink also has a filtration system;
however, the solvent must be changed-out once every 2 years. This sink contains 30 gallons of
solvent.

Fluid Replenishing/Top-ofFs

       Shop personnel replenish or replace antifreeze, transmission fluid, and brake fluid. As a
policy, the VMF flushes out the antifreeze system of each vehicle once every three years.
Antifreeze is recycled off-site.

Battery Maintenance

       The VMF maintains a battery room used only for storage. Staff does not charge batteries
or fill them with sulfuric acid. The VMF has a contract with a local vendor who provides a one-
to-one exchange for the batteries.

Air Conditioning Re-Charge.                                                     ;

       Approximately 200 vehicles are equipped with air conditioning and are serviced on an as-
needed basis. The VMF has two recycling/recovery units: one for R12 coolant and the other for
R134. All maintenance technicians are certified in the use of these machines.

Tire Recaps                                                                    ;

       The VMF recaps many tires for reuse.  In 1994, 732 used tires were generated and
approximately 286 were recapped. The used tires were placed in the metal recycling container to
be collected by Metal Pro.

Floor Cleaning

       VMF staff use buckets and mops to clean the floors on a spot cleaning basis; a general
wash down of the facility is not a common practice. The floor cleaning detergent is ZEP
Formula 50, which is a linear alkali soap. The soap is stored in a 100 gallon above-ground
storage tank in the wash room.

6.2.2  Paint Shop

       The Merrifield VMF maintains a body shop and paint shop to repair  minor dents and
scratches.  The paint shop handles approximately five repair and paint jobs per week. On
occasion, entire cars are painted in the paint booth. The wastes generated from the paint shop

                                           43

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     EXHIBIT 6.1 VMF WASTE GENERATION AND RECYCLING ACTIVITIES
Waste
Category
Waste Oil
Antifreeze
Paint waste
Parts Solvent
Metal
Oil Filters
Batteries
Tires
Soiled Rags
Aluminum
Unit of
Measure
Gallons
Gallons
Pounds
Gallons
Tons
Number
Number
Number
Number
Tons
Total Waste
Stream (FY 94)
2625
600
632
891
4.76
2903
315
732
9360
0.05
Amount
Recycled
2625
600
0
891
4.76
2100
100
286
9360
0.05
Vendor
Eastern Oil Company
American Fluid Technologies
Safety Kleen
Safety Kleen
Metal Pro
Rway Services
Not available
Metal Pro
Textilease
Metal Pro
Oil Change

       Scheduled oil changes depend on the size of the vehicle and the miles driven.  The half
ton trucks are on either a 17 week or 26 week schedule depending on the mileage. The heavy
fleet is changed eight tunes per year, while administrative cars are changed three times per year.
The Merrifield VMF performs about 3,500 routine services a year, each requiring an oil change.
About 60 percent are performed in-house; the rest are contracted out.

       The service bays are equipped with an overhead distribution system for oil and other
lubricants. These materials are purchased in bulk and stored in the bulk storage room. The VMF
also has several mobile oil evacuation systems that collect the oil from the vehicles.  The
evacuation systems can then be moved to a sump which pumps the used oil to a storage tank.
There is very little oil loss from these systems.

       Oil filters are hot drained and collected for recycling by Rway Services. In 1994, Rway
recycled 600 pounds of steel and 106.8 gallons of oil from the oil filters.

Parts Cleaning ..

       Shop mechanics clean parts in one of four solvent sinks or in an aqueous parts washer,.
The shop has three ZEP sinks and one Safety Kleen sink. The ZEP sinks contain petroleum
naphtha solvent and have a filtration system to clean the solvent. The solvent is not emptied
from the sinks; it is filtered and fresh solvent is added when needed. The only waste from the
                                          42

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                                     SECTION 6.0

                    VEHICLE MAINTENANCE FACILITY (VMF)
       This section provides a description of the operations performed by the vehicle
maintenance staff and the handling of wastes and emissions generated by these activities.

6.1    FACILITY DESCRIPTION

       The Merrifield Vehicle Maintenance Facility (VMF) is responsible for vehicle
maintenance activities for the Northern Virginia region. The facility employs 45 staff to
maintain approximately 2,903 postal service vehicles, ranging in size from passenger cars to
tractor trailers.

       The Merrifield VMF, constructed in 1972, is a 31,000 square foot building located to the
south of the PDC. The VMF includes maintenance bays, a battery room, a bulk storage room,
wash rack, paint room, supply room, and administrative offices.  In addition, the VMF has a
20,000 gallon underground storage tank for gasoline and a 16,000 gallon underground storage
tank for diesel fuel. The loading and fueling systems are equipped with stage 1 and stage 2 vaipor
control systems.

6.2    VMF WASTE GENERATING ACTIVITIES

       The functional areas of the VMF, i.e., the service bays, wash rack, paint shop,
administrative offices and supply operations, generate a variety of wastes. These wastes include
used oil, antifreeze, parts solvent, metal, oil filters, batteries, tires, soiled rags, paint solvent, and
solvent-based paint. In addition, the VMF has an active recycling program for many of these
materials. Exhibit 6.1 provides a summary of the waste quantities, recycling quantities and
recyclers. It should be noted that the VMF supervisor has developed a well organized system to
track materials, MSDS, waste generation and recycling quantities.

6.2.1  Service Bays
                                                                              i

       The vehicle maintenance activities conducted in the service bays include fluid changes
(oil, transmission, brake, radiator, etc.), filter changes, battery maintenance, tire replacements.,
and tune-ups. Each of these processes and the wastes generated are described below.
                                          41

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5.4    MAIL HANDLING TRAYS

Current Conditions

       In the basement room where the paint booth previously was operating, USPS employees
use brushes and rollers to paint red stripes around the rim of corrugated HDPE plastic mail
handling trays.  The trays with the red rims are used for internal routing of mail.

Pollution Prevention Opportunity

1.     Change purchasing specifications

       Specify a red rim or even red trays in purchasing specifications for HDPE plastic mail
handling trays.  This will eliminate exposure of employees to VOCs as well as the generation of
paint cans, brushes, rollers, and rags as wastes.
                                           40

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     EXHIBIT 5.4 PRODUCTS USED CONTAINING EPA 33/50 CONSTITUENTS
Product Name
State SSD
State SOS
State DRI
State PEN
Mechanics
Choice
Use
Degreaser
Graffiti Remover
All purpose
penetrant
Penetrating oil
Electric contact
cleaner and motor
degreaser
Constituent of Concern
1,1,1 -trichloroethane
Xylene
Methyl ethyl ketone
Perchloroethylene
1,1,1-trichloroethane
Perchloroethylene
Perchloroethylene
Potential Substitute
1. Enviro Klean, Formula 1000, Allied
Enterprise Inc
16 oz canNSN: 6850-01-061-5493
1. X-Caliber, Inland Technology
1-800-552-3100
1. Break Free CLP
Break Free Inc.
(714) 953-1900
2. Pen-T (22) Super Penetrant
Ecolink/Sentry Chemical Co.
(800) 886-8240
1. Electro-wash 2000, Chemtronics,
Inc., General purpose electronics
precision cleaner, No ODCs. Safe on
most plastics. 12.5 oz aerosol
NSN: 6850-01-393-9054
Pollution Prevention Opportunity

1.     Change Purchasing Specifications

       Change purchasing specifications to require substitute products that do not contain the
target chemicals. Once current stock is exhausted, substitutes should be purchased. One federal
supply list of alternative products is the Defense General Supply Center (DGSC) List of
Environmentally Preferred Products (October, 1994). For example the DGSC lists Enviro Klean,
Formula 1000 manufactured by Allied Enterprises, Inc. as a possible replacement for 1,1,1
trichloroethane. This is a low VOC, non-CFC aerosol spray for degreasing various industrial
parts and equipment.  This product comes in a 16-ounce can for $4.00; the National Stock
Number (NSN) is 6850-01-061-5493.  DGSC also publishes bi-monthly Hazardous Technical
Information Series Bulletins on new environmentally-preferable products. To be placed on the
mailing list, write to Defense General Supply Center, DGSC-SHS/HTIS, 8000 Jefferson Davis
Highway, Richmond, VA 23297-5670. For parts that are detachable, a hot water/detergent wash
can also clean parts effectively.

       Additional pollution prevention sources of information are provided in the appendices.  In
addition, there are several sources of information on the Internet. See Section 8.9 for a
discussion of Internet Resources.
                                          39

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truck or forklift. If the drums are left open, rain will enter the waste drum creating a risk of a
chemical reaction and increasing the volume of hazardous waste requiring disposal. In addition,
open access to the hazardous waste drums may allow non-hazardous waste to be inadvertently
mixed with hazardous wastes or for incompatible wastes to be mixed causing potentially
dangerous consequences. Accumulation of hazardous wastes should be conducted in a safe and
secure area.  Containers of hazardous waste must be properly labeled and kept closed at all times
except for adding and removing waste. All reasonable and appropriate safety precautions must
be enforced to prevent spills, leaks and other accidents.

3.     Solvent Parts Cleaner

       Eliminate at least one of the  solvent parts cleaners or replace them with a non-petroleum
based or aqueous-based cleaning system. At a minimum, keep the lids on the parts cleaner when
not in use to prevent solvent loss to the atmosphere. Although service contracts add an element
of convenience for the PDC, they also tend to encourage waste generation. Providers of full
service parts washing systems do not evaluate the useful life of the solvent used; they charge to
pick up the waste material every six weeks, whether or not the solvent has reached the end of its
useful life.  This results in the unnecessary generation of regulated wastes. Waste generation
would be reduced significantly if the system was maintained on a schedule based on the useful
life of the product used.  The USPS  has already conducted an evaluation of six parts cleaning
systems and compared them to the standard solvent-based cleaning system.  See Exhibit 3.5
which summarizes the results of this study. For a more complete description of the study please
see Environmental Compliance Model Vehicle Maintenance Facility, United States Postal
Service, Northeast Area, Hartford, CT: Vehicle Maintenance Alternative Technologies
Demonstrations and Evaluations, February 28, 1994.

5.3    CHEMICALS ON THE EPA 33/50 LIST

Current Conditions

       The PDC currently uses aerosol cans of solvents and degreasers containing chemicals on
the EPA 33/50 list. These solvents are typically used for small component cleaning operations
for electronic equipment, and degreasing. Exhibit 5.4 provides five examples of products in the
PDC stock room. There were numerous other products found throughout the PDC and ERD that
contained constituents on the EPA 33/50 list. The PDC procurement department  stated that they
informed distributors that they were no longer to supply products that contained the ODCs or
EPA 33/50 chemicals. However, no one followed up to determine whether suppliers actually
complied with this request.
                                          38

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   EXHIBIT 5.3  PDC HAZARDOUS WASTE DISPOSAL DURING 1993 AND 1994
Date- Manifest #
03/02/93-22203
4/15/93-20144
5/93 - 10802
07/08/93 - 05579
08/16/93 - 08440
09/30/93 - 87065
10/08/93 - 34684
11/05/93-84066
11/10/93-74588
12/16/93 - 79488
12/30/93 - 80002
02/02/94-40206
03/15/94-10587
03/23/94-44095
06/03/94-31311
07/18/94-81187
08/04/94-36955
08/30/94 - 13920
Quantity Disposed Per Manifest
53.6 Ibs. Waste Combustible Liquid (D001)
53.6 Ibs. Waste Combustible Liquid (D001)
46.9 Ibs. Waste Combustible Liquid (D001)
46.9 Ibs. Waste Combustible Liquid (D001)
53.6 Ibs. Waste Combustible Liquid (D001)
53.6 Ibs. Waste Combustible Liquid (D001)
444 Ibs. RQ Waste Flammable Liquid (D001)
1680 Ibs. RQ Waste Flammable Liquid (D001)
3 12 Ibs. RQ Paint Related Material (F005)
60.3 Ibs. Waste Combustible Liq. (D001)
60.3 Ibs. Waste Combustible Liq. (D001)
467 Ibs. Waste Combustible Liquid (DO 18)
480 Ibs. Waste Flammable Liquid Corrosive (D002)
453 Ibs. Tetrachloroethylene (F001)
879 Ibs. Waste Oil
53 .6 Ibs. Waste Combustible Liq. (DOO 1 )
53.6 Ibs. Waste Combustible Liq. (D001)
392 Ibs. Hazardous Waste, Liquid (D005)
60.3 Ibs Waste Combustible Liquid (D001)
60.3 Ibs. Waste Combustible Liquid (D001)
392 Ibs. Hazardous Waste, Liquid (D005)
60.3 Ibs. Waste Combustible Liquid (D001)
Contractor
Safety Kieen
Safety Kleen
Safety Kieen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kieen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
individual responsible for hazardous waste management. Management of all hazardous materials
and wastes by one individual would allow better tracking of hazardous wastes. A more
coordinated hazardous waste management system will allow the facility staff to better identify
sources of waste generation and target source reduction efforts in those areas.

2.    Set Up a More Secure Hazardous Waste Storage Area

      The PDC hazardous waste storage area should be moved to a secure location. At the
loading dock the hazardous waste drums and containment device may be accidently struck by a
                                         37

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elected not to establish such a program and outlawed feeding food scrap to swine. As a result,
this pollution prevention option is not viable for the Merrifield facility.
                                      e-t         $*   ~*-
       No permit is required to compost leave and yard trimmings. To compost food wastes
combined with vegetative materials, the Postal Service would be required to obtain a permit from
the state of VA. However, according to Russ Mcllvoy of the state Solid Waste Permitting
Office, the compost regulations are designed for large municipal facilities not for small facilities
wishing to process food waste generated on site. A variance to the regulations may be granted if
the applicant demonstrates that technical conditions make strict application impossible or that
strict application of the regulations) will result in unique hardship.  As long as granting the
variance will not result in unreasonable risk to public health or the environment, requests for
variance from the requirements would be favorably received.

5.2    PDC HAZARDOUS WASTE GENERATION

Current Conditions

       Based on hazardous waste manifests provided by PDC personnel, the PDC generated
approximately 5,143 pounds of hazardous waste hi 1993 and 1,072 pounds in 1994. Exhibit 5.3
presents a summary of the hazardous waste manifests provided by the PDC staff. The types of
hazardous waste generated include spent solvent from two solvent parts cleaners as well as
paints, inks, and oils. One solvent parts cleaner, located on the main PDC sorting floor in the
maintenance cage, was actively used by the staff and its lid was closed. The second parts cleaner
was located in the machine shop in the basement and appeared to be rarely used.  The cover of
the sink was open and the sink was being used as a staging area. The sink contained paper and
miscellaneous parts. According to the PDC procurement department both solvent sinks are under
a service contract that removes and disposes of the solvent every six weeks.

       The hazardous waste storage area is adjacent to the loading dock. The hazardous waste
storage consists of two 55 gallon drums on a spill containment device. One drum was closed and
appeared to be fulL The second drum was open and had a funnel inserted in the top. The funnel
had a lid but during the assessment the cover was half off. The hazardous waste storage area is
open to the weather and employees have unlimited access to the drums.  PDC staff are hi the
process of designing a more efficient and secure system.

Pollution Prevention Opportunities

1.     Establish Individual(s) Responsible for Hazardous Waste Management

       Coordinate all hazardous waste generation and management under one individual who is
responsible for all hazardous waste disposal. In 1993 and 1994 more than eight different
individuals signed hazardous waste manifests. Several of these people clearly did not have any
experience in hazardous waste management. Manifests should always be signed by the

                                          36

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       Additional staff time, soap, delimer/descaler, wastewater and energy costs for dishwasher
operation were not calculated into the analysis because this information was not available.
However, these costs will not significantly alter the perception that eliminating disposables will
provide significant economic benefit and reduce cafeteria waste disposal by as much as 70
percent.

2.     Additional waste prevention opportunities for the cafeteria include:

     Combine the corrugated packaging and pallets for recycling with the same materials at
       the PDC loading dock.

     Separate metal food and beverage containers and place hi the metals recycling container
       attheVMF.

     Separate glass and plastic food and beverage containers and establish a recycling option
       for these materials.                                                       ;

     Contract with a grease recycling service for grease collection and reuse. The following
       companies will provide grease recycling collection and processing services hi Northern
       VA:

       -ValleyProtein  (703)877-2590
       - Darling Delaware Co. (201) 465-1900

     Specify that beverage make-up syrups be  delivered hi refillable metal canisters rather
       than disposable bag-in-box.

       Through a combination of reuse and recycling, the cafeteria waste stream, with the
exception of food scraps and food-contaminated paper, such as napkins, could be diverted from
disposal. This would reduce the quantity of cafeteria waste being disposed by as much as 85 to
90 percent. Waste collection and disposal fees could be reduced by at least $6,500 per year. If a
local composting site for food and paper becomes available, there would also be the option of
diverting food and napkins for composting. If composting were included, the cafeteria could
potentially divert 100 percent of its waste from disposal.

       Selling or providing the food waste to local swine farmers is one alternative disposal
option for food wastes considered by the Assessment Team. The Federal Swine Health
Protection Act (Title 9 CFR) gives states the option to admhiister programs to allow scraps to be
fed to swine.  Any state wishing to allow such a program option must comply with Federal
standards for licensing food waste generators, inspections of generators and recipients, testing of
the food waste, cooking of food waste according  to protocol, and storage standards.  Virginia
                                           35

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Restaurant Specialty
Waynesboro, VA
Phone:(800)345-4601, (703) 943-7025

       Following are quotes for durable, plain white, commercial china dishware, plastic
dishware, and medium weight flatware.

                             RESTAURANT SPECIALTY
Item
Dinner Plate (9 3/4")
Salad Plate (6 1/4")
Soup Bowl (3 1/2")
Mug
Drinking glass (12 oz.)
Dishes subtotal (40 dozen)
Teaspoon
Soup spoon
Dinner fork
Knife
Flatware subtotal (40 dozen)
Total
China/Glass (perdoz.)
$ 33.60
15.00
21.60
22.02
13.28
$4,220
8.40
7.70
7.70
' 6.72
$1,220.80
$5440.80
Plastic (per doz.)
(10") $ 32.03
(9") 22.70
14.66
37.29
9.62
$4,652





$5872.,80
       The purchase price for 40 dozen (480) sets of reusable dishes and glassware ranges from
$3,074 to $4,652; 40 dozen sets of flatware is an additional $994 to $1,220.80. Total cost for
dishes, flatware and one size drinking glasses ranges from a low of $4,068 to a high of $5,872.
Based on current annual procurement costs for disposables of $17,685.25, even if all of the
dishes and flatware were replaced once each year, the cafeteria would save from 66 to 77 percent
of the current cost of disposables. Savings in purchasing costs range from $11,813 to  $13,617.

       The change to reusable food service materials would potentially reduce waste generation
by as much as 70 percent. This means that the six cubic yard container could be replaced with a
smaller container and that the containers could be pulled less frequently. The PDC would avoid
$5,416 hi annual disposal costs. By requiring reusable food service, the Postal Service will
reduce  both the waste generated from this operation and the costs associated with disposal of that
waste.
                                          34

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                        EMPIRE RESTAURANT SUPPLY
Item
Dinner Plate (9")
Salad Plate (7 1/4")
Soup Bowl (3 1/2")
Mug
Drinking glass (12 oz.)
Dishes subtotal (40 dozen)
Teaspoon
Soup Spoon
Dinner fork
Knife
Flatware subtotal (40 dozen)
TOTAL
China/Glass (per doz.)
$ 20.50
11.50
17.50
19.50
10.60
$3,184
3.85
5.60
5.60
9.80
$994
$4,178
Plastic (per doz.)
$ 20.40
15.25
12.40
18.30
10..50
$3,074





$4068
Restaurant Equipment International
Alexandria, VA
Phone: (703)370-1301      .                                             ;

      Restaurant Equipment International provided quotes for a plain white, rolled edge,
commercial china dishware. They do not sell plastic dishware, flatware or glasses.

                 RESTAURANT EQUIPMENT INTERNATIONAL
Item
Dinner Plate (9 3/4")
Salad Plate (7")
Soup Bowl (3 1/2")
Mug
Dishes total (40 dozen)
China/Glass (per doz.)
$ 32.95
27.35
28.00
19.41
$4,308
                                       33

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   EXHIBIT 5.2 WEEKLY PURCHASES OF DISPOSABLE FOODSERVICE ITEMS
Item
20 oz, polystyrene (PS) cups
12 oz. PS cups
8 oz. PS cups
12 oz. PS soup bowl
3 oz. PS bowl
9 inch PS plates
6 inch PS plates
PS clamshells
Polypropylene (PP) forks
PP knives
PP spoons
Plastic straws
Plastic cup lids (3 sizes)
Sandwich wraps
Paper napkins
TOTAL COST/WK
TOTAL COST/YR
Cost Basis
$14.46/1000
$16.66/1000
$11.58/1000
$15.00/1000
$12.50/1000
$17.84/500
$17.24/1000
$39.99/500
$6.87/1000
$6.87/1000
$6.87/1000
$18.09/5000
$7.75/1000
$5.00/1000
$25.75/10,000


Quantity
5,000
3,000
2,500
250
100
2,000
1,500
750
3,000
1,500
1,500
10,000
9,000
1,000
60,000


Cost
$72.30
49.98
28.95
3.75
1.25
71.36
25.86
59.98
20.61
10.30
10.30
36.18
23.25
5.00
154.50
$573.57
$29,825.64
Empire Restaurant Supply
New York City, NY
Phone: (212)226-4447

      Empire Restaurant Supply provided quotes for durable, off-white, commercial china
dishware, plastic dishware, and medium weight flatware.
                                       32

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Pollution Prevention Opportunities

1.     Provide reusable dishware and cutlery for all meals and snacks consumed in the cafeteria.
       Offer a limited number of disposables for take-out only.

       The greatest deterrent to the substitution of reusables for disposables is the allocation of
space for and the capital cost of purchase and installation of a dishwasher.  Since the PDC
cafeteria has a fully functional commercial dishwasher of appropriate capacity on-site, this is not
an issue. The cafeteria manager indicated that little additional staff time would be needed to
operate the equipment if reusable dishes and cutlery were used. The dishwasher is used daily to
clean the reusable plastic trays.

       The cafeteria manager and others indicated that the cost of replacing dishes and cutlery
removed from the cafeteria by employees would be prohibitive. However, the weekly cost of
purchase of disposable food service items is $573.57.  Annual cost to purchase disposable
dishes, cutlery, napkins and straws is $29,825.64. Exhibit 5.2 summarizes current weekly
purchases of disposable foodservice items. Since these disposables represent approximately 70
percent of the waste generated, weekly disposal costs for these materials can be estimated at
$104.16 for an annual disposal cost of $5,416.32. Total annual purchase and disposal costs for
disposable food service is $35,241.96.                                             :

       For the purposes of this analysis, it was assumed that the cafeteria would continue to
purchase disposable plastic straws, paper napkins and sandwich wrappers, that 10 percent of the
food service would be disposables for take-out and that the cafeteria would replace 90 percent of
the disposable plates, bowls, glasses and cups with permanent, reusables. Using these
assumptions, the purchase of straws, napkins, sandwich wrappers and 10 percent of the
disposable dishes and cutlery would cost approximately $233.47 per week or $12,140.39 per
year.  The anticipated savings between current procurement cost and predicted future cost for
disposables is $17,685.25.

       The Assessment Team contacted three restaurant supply houses to determine the cost to
purchase restaurant quality reusable china or plastic dishes, glass and plastic tumblers and
stainless steel cutlery. The estimates were based on forty dozen (480 pieces), a quantity that
seems adequate based on estimates of current cafeteria use.  The firms contacted include Empire
Restaurant Supply of New York City, NY; Restaurant Specialty in Waynesboro, VA; and
Restaurant Equipment International in Alexandria,. VA.
                                           31

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          EXHIBIT 5.1 PDC POLLUTION PREVENTION OPPORTUNITIES
Waste
Corrugated Cardboard
Mixed paper
Cleaners, degreasers and paints
with ozone depleting or EPA 33/50
chemicals
Pallets
Spent solvent
Computer equipment
Hazardous waste
Polystyrene food service (cups,
bowls, plates etc.)
Polypropylene cutlery
Glass food and beverage containers
Aluminum beverage containers
Steel food cans
Grease
Source
Materials delivery, mail
sorting
Office and shops
Sorting floor and shops
All areas
Sorting floor and shops
All areas of PDC
All Areas
Cafeteria
Cafeteria
Cafeteria
Cafeteria
Cafeteria
Cafeteria
Pollution Prevention Opportunities
Use reusable containers
Recycle old corrugated cardboard
Double sided copies
Reuse paper and envelopes
Recycle
Deplete existing stock of materials and
replace with non-ODC containing
substitutes.
Reuse or recycle
Replace with aqueous or semi-aqueous
substitute that does not generate a
hazardous waste.
Sell for scrap or donate equipment.
Set up a secure waste collection area.
Replace with permanent dishware
Replace with reusable cutlery
Recycle
Recycle
Recycle
Recycle
       The cafeteria has no recycling program and does not source separate any materials.  The
potential for polystyrene recycling for this facility was investigated. However, neither the
Polystyrene Packaging Council nor local haulers had any polystyrene recycling programs in
place in northern VA. An on-site commercial dishwasher is used only for trays.  Towels and
aprons are rented from a linen service for a monthly fee of $80.50; employees are responsible for
cleaning personal uniforms.
                                         30

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                                     SECTION 5.0

                                PDC OPPORTUNITIES


       This section describes the pollution prevention opportunities for the PDC. Exhibit 5.1
summarizes the wastes generated in PDC operations and potential pollution prevention
opportunities.

5.1    CAFETERIA

Current Conditions

       A full service cafeteria, operated by Swan Caterers, is located on the main floor of the
PDC. Hot meals, hot and cold sandwiches, salad bar, assorted drinks and snacks are available 24
hours a day, six days a week. The cafeteria, which daily serves approximately 1,000 persons, but
only 200 full meals, is not a profitable operation. Although employees eat in the cafeteria
facilities or break rooms, most bring food from home or use the vending machines.  Daily
cafeteria revenues average $1,700.  The cafeteria manager indicated that the cafeteria operations
are tied to the contract for vending machines. If a company wants the lucrative vending machine
contract, they must also operate the cafeteria.

       All pans and utensils employed in the food preparation area are durable and reusable.
With the exception of rigid plastic trays, however, the cafeteria uses only disposable items for
customer service. The contract between USPS and Swan Caterers, however, specifies that the
contractor will provide " Chinaware and dishes," "Glassware," and "Silverware."  Wastes from
the cafeteria include disposable food service items: expanded polystyrene plates, cups and bowls,
polypropylene cutlery, plastic drinking straws and lids, paper napkins and aluminum sandwich
wrappers. Employees also may discard 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. Carbonated beverages are dispensed from bag in box containers. In addition,
beverages are sold hi aluminum cans and glass and plastic bottles. Deliveries of food and food
service products generate pallets, corrugated boxes and packaging; food preparation contributes
steel cans, plastic and glass jars, cooking grease and additional discarded food.

       All cafeteria waste is placed into a six cubic yard packer/container in the receiving bay.
The PDC contracts Waste Management Inc. to empty the container four times per week.  The
annual fee is $7,737.84 ($644.82/mo. or $148.80/week) which includes all landfill disposal
charges.
                                          29

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wastes generated by the cafeteria include food wastes, corrugated cardboard, polystyrene plates,
bowls and cups, #10 steel cans, kitchen grease, and paper.  The cafeteria has a six cubic yard
compactor that is collected four times per week.  There is no recycling currently occurring in the
cafeteria.

4.2.6  Offices

       Substantial amounts of paper and paper products are generated by the office staff.
Recycling programs for white office paper and aluminum beverage cans are in place throughout
the office operations.

4.2.7  Facility Maintenance

       Facility Maintenance activities include: Metal Shop, Carpenter Shop,. Cart Repair, and
Welding Shops. Each of these activities generates wastes related to the mission performed.  The
metal shop generates scrap metal. The cart maintenance area generates significant quantities of
metal and canvas.

4.2.8  Paint Booth

       The paint booth, located in the basement, was used  to perform spray painting of postal
equipment; however, spray painting activities have been discontinued because of concerns about
adequate ventilation.  The only painting now occurring in the paint booth is the roller painting of
red stripes at the top of the corrugated plastic bins used for internal mail routing. The painting
activities generate steel cans, paint, solvents, brushes, rollers, and rags.

4.2.9  Maintenance Supply/Parts Room

       The maintenance supply room is the storage area for parts, tools  and cleaning and
maintenance supplies. Workers can request equipment and supplies as needed from the supply
room. This room contains three flammable materials cabinets that hold an assortment of
cleaners, degreasers, lubricants, and oils. The Assessment  Team noted that a container of
alkaline drain cleaner had leaked  its contents onto the top shelf, creating the possibility that this
product might come in contact with incompatible products  below.  The assessment also noted the
presence of five products containing chemicals on EPA's 33/50 list; these included degreasers,
penetrating oils, and a graffiti cleaner.  See the appendices  for a list of the chemicals targeted for
reduction or elimination in EPA's 33/50 program.

4.2.10 Battery Room

       The battery room, located on the main floor of the PDC, is used for recharge and storage
of batteries used hi the PDC. Acid filling and removal and disposal of dead batteries is handled
by an outside contractor.

                                           28

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density polyethylene plastic (HDPE) trays, shrink wrap, stretch wrap, plastic and metal bands
and paper wastes are generated during the unloading and internal movement of the incoming
mail. Pallets (wood, wood composite and plastic) are used throughout the facility.

       Part of the dock area is designated for waste accumulation. Postal Service employees
collect wood pallets in a 30 cubic yard open top container that is pulled up to four tunes per
week.  Charges include $49 per pull plus actual landfill tipping fees averaging  $115 per load.
Both damaged and whole, usable pallets were observed in this container. Corrugated cardboard
is collected in a 30 cubic yard open top container and in gay lord containers in a trailer. The
container for corrugated cardboard is pulled for recycling every day. The Postal Service pays
$40 per load for the corrugated recycling. The loading dock also is the site of a 40 cubic yard
trash compactor owned by the Postal Service. The compactor is pulled three times each week by
Waste Management of Northern Virginia. Waste Management charges $79 per pull plus actual
landfill tipping fees which average $200 per load. Mixed waste, plastic film and strapping, and
cardboard were observed in the compactor.

4.2.2  Hazardous Waste Storage Area

       The hazardous waste storage area also is located at the loading dock. The hazardous
waste storage consists of two 55 gallon drums, one of which is topped with an open funnel,
located on a containment device. It was unclear what wastes were put in the drums as no waste
inventory was present. In addition, the funnel top was partially open allowing rain to enter the
drum.  Employees have unlimited access to the drums.

4.23  Mail Sorting Floor

       The mail is moved from the unloading dock to the sorting floor.  The wastes generated
from the mail sorting floor operation include: rubber bands, paper including computer printouts,
corrugated  cardboard boxes and cover sheets, damaged corrugated cardboard and HDPE plastic
trays, canvas mail bags and canvas transport dollies.

4.2.4  Maintenance Cage

       The maintenance cage hi the center of the sorting floor houses a solvent sink containing
petroleum naphtha. The Postal Service contracts with a commercial service that leases and
maintains the solvent sink, removes spent solvent,; and replenishes the sink with fresh solvent at
scheduled intervals.

4.2.5  Cafeteria

       Swan Caterers has the contract to operate the cafeteria and all of the vending machines in
the PDC. The Postal Service is responsible for waste disposal. The cafeteria has a commercial
dishwasher that is used to wash the reusable plastic trays used in the cafeteria.  The principal

                                           27

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                                    SECTION 4.0

                PROCESSING AND DISTRIBUTION CENTER (PDC)
       This section describes the specific operations performed at the PDC and the wastes and
emissions generated by those operations.

4.1    FACILITY DESCRIPTION

       The Processing and Distribution Center (PDC) is responsible for the handling and
distribution of regular and bulk mail in the northern VA area. The PDC has one support
building, the Prosperity Warehouse, where office and reproduction supplies are stored.

       The Merrifield PDC building was built in 1972 and is owned by the United States Postal
Service.  The PDC consists of a 443,000 square foot facility that incorporates a mail processing
floor and a basement containing storage areas, machine shops, and equipment maintenance and
repair facilities. The PDC also contains many ancillary rooms including battery shops,
Undeliverable Bulk Business Mail (UBBM) operations, and a public Post Office (Customer
Service Center). Loading docks for mail trucks are located on the south, east and west sides of
the building.

       The Merrifield PDC is occupied 24 hours a day, seven days a week, 365 days a year. The
number of craft employees (e.g. mail handlers) is 1,695. During the month of December,
approximately 300 to 400 additional temporary employees are on-site. There are 391 office and
supervisory employees, 173 individuals responsible for building maintenance and 108 motor
vehicle service employees who move the mail from trucks to the sorting floor.  Daily mail
processing volume of the PDC is approximately six million pieces.

4.2    PDC WASTE GENERATING ACTIVITIES

       Five functional areas of the PDC generate a majority of the facility's solid waste: the
offices, the loading docks, the mail sorting floor, maintenance and repair operations, and the
cafeteria.

4.2.1   Loading Docks

       Mail is delivered to the PDC aboard trucks in package lots.  The mail lots are unloaded
onto the dock and transferred inside the processing area where the mail is sorted, processed,
repacked and sent to its final destination,  Corrugated cardboard boxes and trays, corrugated high

                                         26

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High expansion foam systems: High expansion foam systems provide contact cooling and do not
require an air-tight enclosure.  On the other hand, foam is electrically conductive, does not
rapidly fill a volume, and may result in corrosion of equipment.

Dry chemical systems: Although effective in extinguishing electrical fires, dry chemical systems
often leave harmful residues on computer equipment and render them inoperable. The use of a
dry chemical system should be contingent upon frequent backups of important data and
redundancy of computer assets.

3.5    RESEARCH PROJECTS

       While many of the pollution prevention opportunities identified above can be
implemented with little research, other opportunities were identified that require the ERD to
initiate research into their feasibility. Some potential areas of research that may have significant
impacts on the wastes generated by the USPS include the following:

      less toxic paints for mailboxes and other USPS equipment,
      alternative materials for mailboxes and other equipment that might eliminate the need to
       paint and repaint, and
      long-life substitutes for corrugated plastic and paper mail transfer trays.

       This research should emphasize life-cycle costing to determine whether higher initial
costs may be mitigated over the life of the product.  If research identified substitute materials that
meet performance specifications, significant waste reduction could be accomplished both at the
Merrifield operations and throughout the USPS.
                                           25

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      Availability of manual fire suppression equipment
      Fire department response time

       According to a report on halon substitution prepared by the United Kingdom Department
of the Environment, fires rarely start in electronic equipment rooms. Instead, fires are more
likely to start in adjacent storage or work areas and then spread. USPS should design a fire
protection strategy to take into account fires that may spread into the computer equipment room
and laboratories, as well as fires that start in the rooms themselves.

       Elements of an effective fire protection strategy are presented below in the order of
environmental preference.

Reduce risk of losses: Maintain back-ups of data in a remote location, limit the size of the facility
as much as possible, and ensure that adequate contingency arrangements are in effect.
Early detection: Couple early detection systems with a rapid and guaranteed response by the fire
department and an automatic sprinkler system.

Halon discharge override: Install a manual override switch which stops the discharge of halon hi
the event of an accidental triggering of the halon  1301 system.

Cabinet protection: Limit halon discharges to equipment cabinets themselves or provide in-
cabinet detection systems coupled with automatic isolation of the power supply and sprinkler
systems.

4.     Replace Halon 1301

       Once USPS Merrifield has developed an acceptable replacement strategy, it should
replace the existing halon system with a suitable alternative. The USPS should task the fire
system maintenance contractor to evacuate the current halon system and collect the halon 1301
for recycling.  The collected halon must be turned over to the DLA hi accordance with
appropriate DLA procedures. The following alternatives would provide adequate fire protection
intheERD.

Carbon dioxide systems: Carbon dioxide systems are an alternative when total flooding is
absolutely necessary. Disadvantages of carbon dioxide systems are the potential hazard to
personnel and the possibility of secondary damage from thermal shock.

Automatic sprinkler systems: Water or foam sprinkler systems are available which either spray,
sprinkle, or mist. The disadvantage of relying solely on water sprinklers is the risk of water
damage to computer equipment.
                                           24

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Pollution Prevention Opportunities

1.     Cease Discharge Testing

       Until the USPS identifies a suitable replacement for the halon 1301 systems in place in
the building, the ERD should not conduct discharge testing of the current systems. This
unnecessary release of halon into the atmosphere represents a significant loss of stored halon. In
lieu of periodic discharge tests, the halon systems should be inspected by a qualified fire
equipment Inspector.

2.     Perform Regular Preventive Maintenance

       Another significant loss of halon hi fixed systems is through leaks in valves and
discharge lines. The ERD should  conduct regular preventive maintenance to insure that all halon
systems hi place are intact and free of leaks. Cylinders used to store excess halon should also be
inspected and stored in a safe manner.  Cylinders not hi use should be fastened securely to a
permanent fixture such as a post or wall, and protective caps should be placed over the valves.

3.     Implement Fire Protection Measures
                                              '                                 i
       In developing an alternative to halon 1301 fire suppression systems, USPS Merrifield
must examine other fire protection measures such as: fire protective enclosures; smoke control
systems; manual fire fighting equipment; provision of high ignition resistance, low flammability
cable and wire insulation, furnishings, and interior,finish; and "smoke resistant" electronics
components. The ERD can reduce its total fire risk by such methods as:  performing preventive
maintenance on computer equipment, building redundant facilities, backing up records and other
media, and preparing adequate post-fire reclamation procedures and contingencies before a fire
takes place. By taking these considerations into effect, USPS Merrifield will ensure an
acceptable level of fire protection, even though it may be replacing halons with a less effective
chemical substitute. Specific fire  safety features for electronics systems recommended by the
Montreal Protocol 1991 Halon Technical Options Committee are presented hi Exhibit 3.7.

              EXHIBITS.? FIRE PROTECTION MEASURES

       Redundancy
       Use ignition resistant wire, cable, and electronic components
       Minimize ignition source severity from external sources
       Measures to slow rate of fire development
       Measures to lower rates of smoke production
       Components hardened to the effects of heat and smoke  ,
       Low smoke corrosivity
       Isolation of HVAC system
       Fire resistive compartment boundaries
       Detection and alarm systems
       Full-time manning
       Training of staff

                                           23

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separator may be the most cost effective option. To avoid any accidental release to the sanitary
sewer system the drains in the Automotive Bay should be sealed, or at a minimum, diked.

3.4    ALTERNATIVES TO HALON FOR FIRE PROTECTION

       Although halon has excellent fire extinguishing properties, halons deplete stratospheric
ozone, a substance critical hi protecting the earth from the harmful effects of ultraviolet radiation.
The international community acted to reduce the use of halons with the Montreal Protocol On
Substances That Deplete the Ozone Layer which set January 1,1994 as the phaseout date for
production and import of halons.  The phaseout of production has made the identification of
current uses of halons and acceptable alternatives to halons extremely important. Halons are
used in many applications for fire protection including onboard aircraft, military vehicles,
electronics equipment systems, electrical plant areas, control rooms, archival storage areas,
cultural heritage areas, flammable hazards storage areas, and offshore oil and gas installations!.
Like many computer equipment facilities, the ERD is protected by a halon 1301 fire suppression
system. The following discussion describes the ERD's current fire protection system and
recommends alternatives to halon.

Current Conditions

       Halon fire suppression systems at the ERD provide a high level of fire protection, with
minirnal secondary damage and minimal disruption to resumption of operations in the event of a
fire. The USPS conducted a survey of existing stores of halons at USPS facilities in October,
1993. The results of this survey indicated that the ERD employs 4,666 pounds of halon 1301 in
six areas and stores 3,185 pounds of halon 1301 hi cylinders as a backup supply.

       The halon systems are hi place in computer rooms and storage areas for computer
equipment. The computer equipment protected by the halon systems is used in non-critical
engineering design functions for the Postal Service. The Postal Service must address both the
short term and long term issues associated with providing adequate fire protection for the ERD
building. In the short term, the Postal Service must cease any discharge testing of equipment,
regularly inspect and maintain its existing halon 1301 systems, and implement the fire protection
measures outlined below. These steps will insure that the long term impact on fire protection for
the Engineering building will be minimized. Long term supplies of halons are uncertain.
Although significant expenditures may be required, the USPS should plan complete halon 1301
phase out and identify its long term fire protection needs at the ERD and implement a fire
protection strategy that anticipates the removal of the existing halon systems. In the long term,
the Postal Service must identify a suitable substitute for the  halon 1301 systems in place and,
after installing the new systems, properly transfer any remaining halon 1301 to the Defense
Logistics Agency (DLA) for banking.
                                          22

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4.     Perform Regular Maintenance on Limestone Tank and Pit

       Empty the water from the limestone tank pit and determine the source of the water.
Contact with standing water may cause an increased rate of tank corrosion.  Set up a more
frequent maintenance schedule to inspect the tank. Reinforce the procedures that allow only
acidic or neutralized wastes to be managed via the limestone tank.  Other wastes should be stored
hi appropriate waste containers prior to disposal.

33    USED OIL

Current Conditions

       The ERD currently generates used oil from the model shop and small amounts from the
automotive bay, as well as oil from the standby generator.  In the model shop, maintenance on
the machines, including oil changes, does not occur on a scheduled basis. Cutting fluids on
several machines were aqueous-based while others were oil-based. A waste oil collection drum
was located hi one corner of the room. The drum sat atop a brand new plastic spill containment
tray. In the past any used oil generated has been sent to the VMF used oil tanks. In the
automotive bay, small quantities of used oil are occasionally generated. Portable oil containers
are used to collect used oil drained from vehicles. According to ERD staff, there has never been
an oil spill hi the room and no oil is sent to the drains. Any used oil generated is sent to the VMF
used oil tanks for recycling. The floors in the automotive bay are mopped with detergent and
water solutions  and rinsed to the area drain system.

       The Automotive Bay has a floor drain system. Materials entering the drains from the
automotive bay are routed through an oil water separator. In practice, any oil separated from the
waste stream is  sent to an underground 250 gallon tank and water is discharged via the sanitary
sewer system. The USPS has been considering replacing this tank with a double lined tank.
Currently the 250 gallon oil tank is reported to be filled with water.

Pollution Prevention Opportunities

1.     Remove or Inactivate Oil Water Separator and Oil Holding Tank

       Since the operations at the Automotive Bay generate minimal amounts of oil and
personnel claim that no oil spills have ever occurred, it appears that the oil-water separator and
oil storage-tank are unnecessary and are not being used for the designed purpose. As well, since
the shop floors are cleaned with detergents and rinsed down the drains, any oil that makes its way
to the oil water  separator is likely emulsified and discharged to the sanitary sewer.

       The Postal Service plans to remove the tank and replace it with a double walled tank.
This option seems expensive and will not prevent oil discharges to the environment since soaps
are regularly rinsed down the drain. Removal of the tank and bypassing of the oil water

                                           21

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      EXHIBIT 3.6 EXAMPLES OF POTENTIALLY INCOMPATIBLE WASTES
Group 1-A
Acetylene sludge
Alkaline caustic liquids
Alkaline cleaner
Alkaline corrosive liquids
Alkaline corrosive battery fluid
Caustic wastewater
Lime sludge and other corrosive alkalies
Lime wastewaters
Lime and water
Spent caustic
                                                   Group 1-B
                                                   Acid sludge
                                                   Acid and water
                                                   Battery acid
                                                   Chemical cleaners
                                                   Electrolyte, acid
                                                   Etching acid liquid or solvent
                                                   Pickling liquor and corrosive acid
                                                   Spent acid
                                                   Spent mixed acid
                                                   Spent sulfuric acid
Potential Consequences: Heat generation, violent reaction
                                                   Group 2-B
                                                   Any waste in group 1-A or 1-B
Group 2-A
Aluminum      Magnesium
Beryllium       Potassium
Calcium        Sodium
Lithium Zinc powder
Other reactive metals and metal hydrides

Potential consequences: Fire or explosion; generation of flammable hydrogen gas.	

Group 3-A                                         Group 3-B
Alcohols                                           Any concentrated waste in groups 1-A or 1-B
Water                                             Calcium
                                                   Lithium
                                                   Metal hydrides
                                                   Potassium
                                                   SO2C12, SOC12, PC13, CH3SiCl3
                                                   Other water-reactive waste

Potential consequences; Fire, explosion, or heat generation; generation of flammable or toxic gases
Group 4-A
Alcohols
Aldehydes
Halogenated hydrocarbons
Nitrated hydrocarbons
Unsaturated hydrocarbons
Other reactive organic compounds and solvents

Potential consequences: Fire, explosion, or violent reaction.
                                                   Group 4-B
                                                   Concentrated group 1-A or 1-B wastes
                                                   Group 2-A wastes
Group S-A
Spent cyanide and sulfide solutions
                                                   Group 5-B
                                                   Group 1-B wastes

Potential consequences: Generation of toxic hydrogen cyanide or hydrogen sulfide gas
Group 6-A
Chlorates
Chlorine
Chlorites
Chromic acid
                Hypochlorite
                Nitrates
                Nitric acid, fuming
                Perchlorates
Permanganates  Peroxides
Other strong oxidizers
Group 6-B
Acetic acid and other organic acids
Concentrated mineral acids
Group 2-A wastes
Group 4-A wastes
Other flammable and combustible wastes
Potential Consequences; Fire, explosion, or violent reaction.
                                                20

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Pollution Prevention Opportunities                                              \

I.     Control the inventory of ink to reduce waste ink generation                 ;

       One of the functions of the laboratory is to test inks used hi mail processing. The
hazardous waste storage area inventory and hazardous waste manifests show that much of the
hazardous waste disposed is stamp ink, cancellation ink and tag ink.  Expired or unused inks are
one of the laboratory's largest hazardous waste streams. To reduce the quantity of waste ink
generated and disposed as hazardous waste, the laboratory should establish an ink inventory
control system that limits the quantities entering the facility and being disposed as hazardous
waste. Prior to ordering of inks, ERD staff should accurately quantify the amount of ink required
for testing and evaluation and order only as much as needed. If particular inks are used on a
regular basis, the ERD needs to ensure that ink is used on a first-in-first-out basis and ordered on
an as-needed basis.  If inks are provided by manufacturers for testing, ERD should require that
the manufacturers take back any unused ink as a prerequisite to testing. ERD staff noted that
some inks have in the past been sent back to the manufacturer for reformulation.  These steps can
significantly reduce the quantity of waste ink generated by the ERD.

2.     Provide separate storage areas for acids and bases to prevent accidental contact.

       In some cabinets, acids and bases were stored on the same shelf. Separate storage areas
would reduce the potential for accidental contact between incompatible chemicals.

3.     Reduce Chemical Usage and Establish Chemical Waste Storage System

       Waste acids and bases are typically neutralized prior to discharge through the sanitary
sewer; however,  all other chemicals sent through the drain enter the sanitary sewer untreated.
Laboratory staff should minimize the use of chemicals by measuring out only what is needed for
a procedure and should strive to minimize  the waste generated from performing analyses.  The
laboratory staff also should minimize the quantity of hazardous chemicals that enter the
environment via the sanitary sewer.  Instead of sending chemicals to the sanitary sewer, the
laboratory should set up a waste storage container system that segregates incompatible wastes
and stores them prior to appropriate management or recycling.  The containers can be five-gallon
carboys clearly marked with the waste type.  This system will minimize the potential for mixing
of incompatible wastes .and provide a system that diverts chemicals from the sanitary sewer
system to appropriate treatment systems. Exhibit 3.6 provides examples of potentially
incompatible wastes, waste components, and materials along with the consequences from mixing
the materials taken from Law. Regulations, and Guidelines for Handling Hazardous Waste. CA
Department of Health, Feb.  1975. (46 FR 2872, Jan. 12,1981).
                                           19

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Intangible Cost
$ = Low Risk
$$ = Moderate Risk
$$$ = High Risk
00

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4.     Parts washer

       Eliminate the parts washer in the model room or replace with a non-petroleum based or
an aqueous-based cleaning system.  The parts washer is one of the few steady sources of
hazardous waste generation hi the ERD. While the cost of management of this waste is relatively
small (approximately $524 per year), this piece of equipment alone puts the ERD into the small
quantity generator status because it generates approximately 1,024 pounds of hazardous spent
solvent per year. The parts washer operates on a full-service contract basis.  Although service
contracts add an element of convenience for the ERD, they also tend to encourage waste
generation, Providers of full service parts washing systems do not evaluate the useful life of the
solvent used; they charge to pick up the waste material every quarter, whether or not the solvent
has reached the end of its useful life. This results in the unnecessary generation of regulated
wastes. Waste generation would be reduced significantly if the  system was maintained on a
schedule based on the useful life of the product.  The USPS has already conducted an evaluation
of six parts cleaning systems and compared them to the standard solvent-based cleaning system.
Exhibit 3.5 summarizes the results of this study. For a more complete description of the study
please see Environmental Compliance Model Vehicle Maintenance Facility, United States Postal
Service, Northeast Area, Hartford, CT: Vehicle Maintenance Alternative Technologies
Demonstrations and Evaluations, February 28,1994.

3.2    ANALYTICAL LABORATORY

Current Conditions

       The laboratory appears well organized with chemical stocks well accounted for and
MSDS sheets readily available.  The laboratory has separate storage areas for solvents, solid
chemicals, and inks. However, hi one undersink cabinet, acids and bases were stored together
inappropriately.  In addition, one cabinet contained a bottle marked "waste" with no additional
description. The laboratory generates wastes such as acids, bases, solvents, inks, and dyes. The
Assessment Team noted the lack of appropriate waste chemical storage containers. The lab
personnel stated that small amounts of chemical waste are often put into the drains.  Waste acids
and bases are typically neutralized in the lab prior to disposal via the sanitary sewer system. The
drains in the laboratory lead to one of the three ERD limestone neutralization tanks. This is a
small tank filled with limestone designed to neutralize acids entering from the laboratories prior
to discharge to the sanitary sewer system. The Assessment Team found the pit containing the
tank contained approximately three feet of water. The source of the water was unclear. The
room also .contained a chiller and ERD staff explained that recent maintenance on the chiller
system may have generated water that flowed into the pit.
                                           17

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2.     Hazardous Waste Recordkeeping
                                     -i*r -        '-'frl-
       Establish better procedures for tracking hazardous waste generation and management.
Tracking of hazardous waste disposal is somewhat haphazard. The ability to reduce hazardous
waste generation begins with an understanding of the waste generation patterns of the facility.
RCRA requires that facilities retain hazardous waste records for three years from the date of
transport. Specifically, the facility must retain for three years, signed copies of hazardous waste
manifests, copies of the biennial report and exception reports (if not a small quantity generator),
and copies of any test results and waste analyses or other determinations performed on disposed
wastes.  ERD should set up a filing system that presents this information hi an orderly manner
that would allow more effective tracking of wastes.

3.     Hazardous Waste Generator Status and Facility Hazardous Waste Cleanup Day

       Over the short term, the ERD can reasonably maintain its small quantity generator status.
This can be accomplished by tracking hazardous waste generation and smoothing out the
episodic nature of the hazardous waste  generation.

       Over the long term, the ERD should strive to become a Conditionally Exempt Small
Quantity Generator (CESQG).  This would potentially exempt the ERD from most hazardous
waste regulations. This is a feasible goal, but several steps are required to attain CESQG status.
The parts washer should be replaced with one which does not generate a hazardous waste. The
waste generated from the parts washer alone causes the ERD to be considered a Small Quantity
Generator.  See the discussion below on the replacement of the parts washer.  The facility should
also have a hazardous materials/waste cleanup day. The goal of this cleanup would be to
eliminate the current accumulation and purge cycles for hazardous waste.  While this process
could make the ERD a large quantity generator for the current year, it also would provide a fresh
start.  The cleanup process should include evaluating every material found in each shop to
determine its age, use, and whether it is still needed.  Materials that are no longer needed in a
particular area should then be assessed  for possible use hi another operation.

       It is essential for the facility to eliminate the materials accumulation and purge cycles hi
order to reduce the quantity of waste generated.  After this cleanup and evaluation is completed,
future hazardous materials acquisition,  use and waste generation must be carefully monitored so
the quantities and types of wastes disposed can be controlled. This type of control has been
implemented hi other USPS facilities.  For example, the Bulk Mail Center hi Dallas, TX has
established a procedure hi which all chemical/material purchase orders are reviewed by technical
staff to determine if the material contains hazardous constituents. This procedure has allowed
staff to reduce the quantities of hazardous materials that enter the facility, provide an opportunity
for the technical staff to find  non-toxic  alternatives and reduce the generation of hazardous
materials requiring disposal.  Applying this type of control over the purchasing practices would
allow the ERD to maintain SQG or CESQG status hi the future.
                                           16

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site generated no more than 100 kg (220 Ibs.) of hazardous waste, and no more than 1 kg (2.2 Ibs.)
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; site accumulated no more than 1000 kg (2,200 Ibs.) of hazardous waste, and no more than 1 kg (2.:
and no more than 100 kg (220 Ibs.) of material from the cleanup of the spillage of acute hazardous 1
site treated or disposed of the hazardous waste in a manner consistent with regulatory provisions (4
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is a Small Ouantitv Generator (SOG) if it meets all the following criteria:
ne or more months site generated more than 100 kg (220 Ibs. of hazardous waste but in no month d
100 Ibs.) or more of hazardous waste; or 2) generate 1 kg (2.2 Ibs.) or more acute hazardous waste; i
r more of material from the cleanup of a spillage of acute hazardous waste; and
site accumulated nor more than 1 kg (2.2 Ibs.) of acute hazardous waste and no more than 100 kg (
p of a spillage of acute hazardous waste; and
site stored its waste in tanks or containers in a manner consistent with regulatory provisions.
site met all the criteria for a conditionally exempt small quantity generator, but
site accumulated 1,000 kg (2,200 Ibs.) or more of hazardous waste.
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is a Large Ouantitv Generator ( LOG) if it met any of the following criteria:
site generated in one or more months 1,000 kg (2,200 Ibs.) or more of RCRA hazardous waste; or
site generated in one or more months during 1991, or accumulated at any time, 1 kg (2.2 Ibs.) of F
site generated or accumulated at any time more than 100 kg (220 Ibs.) of spill cleanup material con
ous waste.

-------
EXHIBIT 3.3 ERD HAZARDOUS WASTE DISPOSAL EVENTS IN 1993 AND 1994
Date - Manifest
Number
10/05/93 - 09374
10/19/93 - 09460
1/94
02/24/94 - 58571
4/94
5/19/94 - 10916
7/94
09/16/94-11765
09/14/94 - 37148
10/94
Quantity Disposed Per Manifest
1200 Ibs. Non-regulated Material
3000 Ibs. Non-regulated Material
500 Ibs. Waste ink (D001)
300 Ibs. Caustic (D002)
4001bs.KOH(D002)
400 Ibs. Waste Ethanol (D001)
300 Ibs. Paraffinic Naphthenes (D001)
450 Ibs. Waste Oil (D001)
250 Ibs. Non-regulated Material
300 Ibs. Waste Caustic (ammonia) (D002)
300 Ibs. NaOH solution (D002)
150 Ibs. Petroleum Naphtha (D001)
40 Ibs. Flammable Liquid (D001)
10 Ibs. Flammable Liquids (pentachlorophenol)
(D001, D037, F027)
256 Ibs. Waste Combustible Liquid (D001)
1434 Ibs. Waste Flammable Liquid (F005)
256 Ibs. Waste Combustible Liquid (D001)
25 Ibs. Waste Compressed Gas, Flammable (D001)
250 Ibs. Waste Paint (DOO 1)
100 Ibs. Waste Flammable Liquid (D001, D008)
25 Ibs. Waste Flammable Liquid (D001, F003, F005)
256 Ibs. Waste Combustible Liquid (D001)
200 Ibs. Non-regulated Material
60 Ibs. Regulated Liquid
60 Ibs. Corrosive Liquid (D002)
239 Ibs. Waste Flammable Liquid (F003)
256 Ibs. Waste Combustible Liquid (D001)
Contractor
Laidlaw
Laidlaw
Safety Kleen
Safety Kleen
Safety Kleen
Laidlaw
Safety Kleen
Laidlaw
Safety Kleen
Safety Kleen
Cost
Included
above
Included
above
$131.00
$2157.00
$131.00
$1,218
$131.00
$966.00
$359.50
$131.00
                               14

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EXHIBIT 3.3 ERD HAZARDOUS WASTE DISPOSAL EVENTS IN 1993 AND 1994
Date - Manifest
Number
1/93
4/93
04/05/93 - 08124





04/26/93

06/07/93 - 12287
06/07/93-12251
7/93
07/16/93-47644
10/93
10/04/93 - 09358













Quantity Disposed Per Manifest

256 Ibs. Waste Combustible Liquid (D001)
256 Ibs. Waste Combustible Liquid (D001)
3001bs.NaOH(D002)
300 Ibs. Alkaline Liquid
300 Ibs. Alkaline Liquid
300 Ibs. Hazardous Liquid, o-cresylic acid (F001,
F004)
200 Ibs. Waste Acid (D002)
956 Ibs. Waste Flammable Liquid (F005)
196 Ibs. Waste Petroleum Distillates (D001)
717 Ibs. Waste Flammable Liquid (F005)
148 Ibs. Waste Combustible Liquid (F001)
256 Ibs. Waste Combustible Liquid (D001)
1792 Ibs. Waste Flammable Liquid (FOOS)
256 Ibs. Waste Combustible Liquid (D001)
175 Ibs. Non-regulated Material
150 Ibs. Flammable Liquid (D001, D008)
400 Ibs. Non-regulated Material
150 Ibs. Flammable Liquid (D001, D035)
150 Ibs. Sodium Benzoate
120 Ibs. Non-regulated material!
40 Ibs. Iodine
40 Ibs. Flammable Liquid (D001,P027)
80 Ibs. Flammable Liquid (D001)
15 Ibs. Compressed Gas (D001, D008)
5 Ibs. Waste Flammable Solids (D001)
80 Ibs. Flammable Liquid (D001, D002)
50 Ibs. Flammable Liquid (D001, D002, U239)
8 Ibs. Waste flammable solid (D009)
Contractor

Safety Kleen
Safety Kleen
Laidlaw





Safety Kleen

Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
Safety Kleen
Laidlaw













Cost

$131.00
$131.00
$2392.00
1




$1618.00

$1078.50
$180.00
$131.00
$1797.50
$131.00
$14,799













                              13

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 regulated materials and poisonous solids in 1993 and 260 pounds of non-regulated materials in
 1994. These wastes were accumulated from all areas pf the ERD. During 1993 and 1994 the
 ERD spent $22,389 and $5,224.50 respectively to dispose of materials as hazardous wastes. The
 Assessment Team grouped the hazardous waste disposed by calendar month to determine the
 ERD generator status under RCRA. Exhibit 3.2 presents the quantity of hazardous waste, hi
 pounds, disposed by the ERD each month during 1993-1994. Exhibit 3.3 provides a listing of
 each hazardous waste disposal event during 1993 and 1994. It was unclear whether this was all
 of the hazardous waste generated, since the hazardous waste disposal recordkeeping was
 somewhat haphazard. This calculation does not include the non-regulated and poisonous
 materials disposed as hazardous waste. The status of a hazardous waste generators is defined
 primarily by the monthly generation of non-acute hazardous waste and acute hazardous waste.
 The categories of waste generators are presented hi Exhibit 3.4 with the regulatory requirements
 for each generator status. Based on the manifests provided, the ERD was a Large Quantity
 Generator in at least two months during 1993. In April 1993 the ERD generated approximately
 2,208 pounds of hazardous waste. In October 1993, the ERD generated approximately 3,728
 pounds of hazardous waste including 50 pounds of acutely hazardous waste (40 Ibs. of P027 (3-
 Chloropropionitrile) and 10 Ibs of F027 (discarded unused formulations of tri, tetra, or
 pentachlorophenol)). As a result, the ERD was a Large Quantity Generator.  During 1994,  the
 ERD was considered a Small Quantity Generator throughout the year.

EXHIBIT 3.2 MONTHLY HAZARDOUS WASTE DISPOSAL DURING 1993 AND 1994
                                     (POUNDS)

93
94
Jan
256
256
Feb
0
1434
Mar
0
0
Apr
2208
256
May
0
400
Jun
865
0
Jill
2048
256
Aug
0
0
Sep
0
299
Oct
3728
256
Nov
0
0
Dec
0
0
Total
9,105
2,901
 Pollution Prevention Opportunities

 1.      Coordination of Hazardous Waste Management

        Coordinate all hazardous waste generation and management under one individual who is
 responsible for all hazardous waste disposal. Currently it appears that most hazardous waste
 generation is handled through one individual but the model room parts washer is managed by
 maintenance through an outside contractor. Management of all hazardous materials and wastes
 by one individual would allow better tracking of hazardous wastes. A more coordinated
 hazardous waste management system will allow the facility staff to better identify sources of
 waste generation and target source reduction efforts in those areas. The hazardous waste tracking
 and management system should be incorporated into the Hazardous Materials Inventory Control
 System (HMICS) (see Section 8.3) so that purchases of hazardous materials and hazardous waste
 disposal will be coordinated through one path.
                                           12

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Reuse paper and envelopes
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Reduce quantity received to what is needed
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                                     SECTION 3.0

                               ERD OPPORTUNITIES
       This section addresses the specific pollution prevention opportunities identified within.
the ERD facility. Exhibit 3.1 summarizes the wastes generated in ERD operations and potential
pollution prevention opportunities.

3.1    ERD HAZARDOUS WASTE GENERATION

Current Conditions

       The ERD does not generate significant quantities of hazardous waste on a regular basis
(an exception is the solvent parts washer hi the model room). Rather, over the past two years the
ERD has had several episodic hazardous waste generation events. Specifically it appears that
hazardous wastes are generated during cleanups of specific areas, when expired or spent
materials and wastes are purged from the facility.

       The ERD stores hazardous waste in an appropriate manner and allows limited access to
the hazardous waste storage containers.  Two hazardous waste storage areas were noted, one in
the ERD hallway outside of the high bay and one in the ERD reproduction center. The
hazardous waste storage area hi the reproduction center stored only spent toner from the
reproduction machine. The storage area near the high bay was the primary storage area, with
numerous wastes being stored.

       One individual is responsible for the hazardous waste storage area and the ultimate
disposal of accumulated hazardous waste. However, the hazardous waste generated by the parts
washer is coordinated by maintenance staff with an outside contractor servicing and disposing
the hazardous waste generated.

       The facility contained numerous flammable materials cabinets. With the exception of the
analytical laboratory cabinets, which were well organized and accounted for, these cabinets were
filled with a large variety of paints, oils, greases, inks, adhesives, and cleaning compounds.
Many products were old, unused or obsolete.

       Based on the hazardous waste manifests provided by the USPS, the ERD disposed of
approximately 9,105 pounds of hazardous waste hi 1993 and 2,901 pounds of hazardous waste hi
1994. In addition, ERD discarded as hazardous waste approximately 5,535  Ibs of non-
                                          10

-------
calcium chloride and potash, water softener salt, boxes of new and used toner cartridges, and
cases of paper cups.
                                           9

-------
       The loading dock area also contains the maintenance supply storage room. Purchases of
custodial supplies are made by purchase order and by individual credit card. Record keeping is
by supplier rather than individual product.

2.2.10 Support Buildings

       The ERD facility has three support buildings: the Reproduction Center, the ERD
Warehouse No. 1 (Hilltop) and the Eskridge Building Warehouse.
                                                                   *
       The ERD Reproduction Center stores design drawings on 35 mm aperture cards so that
they can be retrieved and copied on request. Because the facility is changing to an electronic
storage and retrieval system, long-term planning for disposal of the aperture cards should be
initiated. The Reproduction Center houses a hazardous waste storage locker containing one 55-
gallon drum.  The drum is used for accumulation of liquid waste from the 938 duplication
machine. In addition, the Reproduction Center collects white paper for recycling in a gaylord
box that is collected on an on-call basis.  The break  room had separate containers for newsprint
and glass and aluminum food and beverage containers.

       The ERD is responsible for the cost and maintenance of an eight cubic yard dumpster at
the National Testing Center located in the same building as the Reproduction Center.  This
container is pulled twice each week for a flat fee of $ 127.00 per month.

       The ERD Warehouse No. 1, also called the Hilltop Warehouse, is used for storage of
excess equipment, test equipment from completed or cancelled projects and obsolete and excess
computer equipment, particularly a large number of Wang word processors.  There is no
inventory of the contents of the building; some items in the warehouse bore date tags indicating
that they had been there for as long as five years.  The Postal Service maintains an excess
equipment warehouse in Greensboro, NC.  Occasionally, Greensboro will send a trailer to collect
usable material from the Hilltop Warehouse.

       ERD staff provided receipts from Waste Management of Northern Virginia indicating
purges of the warehouse contents on three occasions. Between September and December, 1994,
seven 30 cubic yard containers were sent to a local landfill.  If the contents of those containers
was similar to material still stored in the warehouse, the Postal Service paid more than $2,000 to
landfill viable computer equipment and recyclable metals.

       The Hilltop Warehouse also contains approximately 3,185 pounds of reserve Halon for
the fire suppression systems.  Research into the transfer of this halon to the Department of
Defense halon reserve has been initiated. For a description of halon-related opportunities, see the
discussion hi Section 5.4.

       The Eskridge Building Warehouse  is used for storage of supplies and equipment for
grounds and facility maintenance. For example, the site contained a snow plow, bags of deicer,

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2.2.9  Maintenance and Loading Dock

       The maintenance staff consists of approximately 17 people including five custodians, two
mechanics, one mechanics helper, one electrician, one supply clerk, one mail room clerk, and a
messenger/driver. This staff is responsible for the day-to-day supply, maintenance, shipping and
receiving and cleanup activities.

       The loading dock has two truck bays and a third bay that contains the 30 cubic yard trash
compactor for the ERD. The compactor is pulled approximately twice each month; costs include
$75 per pull plus landfill disposal averaging $50/ton. White paper is the only material actively
recycled.  The ERD compactor is full of corrugated cardboard, although the adjacent mail
Processing and Distribution Center (PDC) recycles cardboard. The PDC Plant Maintenance
Engineer explained that moving the corrugated from the ERD to the PDC created issues for the
on-site labor unions.  There is uncertainty about who is responsible for moving the materials
from one facility to another. In addition, the PDC pays for removal of the corrugated cardboard
and the current system of finance and accounting would make allocation of charges very
difficult. However, the ERD does take some pallets to the PDC open top container; other pallets
are placed into the compactor.                                                   '.

       Dozens of printer toner cartridges are stored in boxes against one wall awaiting collection
by the contracted recharge company.  This area is also a temporary storage area for deliveries of
paper and other supplies.  In the center of the dock area, the Plant Maintenance Engineer placed a
container for accumulation of packaging material (foam peanuts) for reuse.  A container for
collection of spent alkaline batteries was located nearby. The engineer noted that employees fire
encouraged to bring batteries from home for recycling. Approximately 80 pounds  of batteries
have been collected in six months.  Ninety gallon containers for storage of white paper for
recycling are also maintained hi the loading dock area. According to ERD staff, maintenance
workers collect the white paper from containers on all floors each Tuesday; the paper is then
collected by Environmental Recycling Incorporated on Wednesday.

       Metals, including tin from the model room and aluminum beverage containers, have been
self-hauled to Davis Industries, Inc. In the future, the ERD intends to recycle metals hi a
cooperative effort with the VMF.

       Adjacent to the loading dock is an electrical room that contains the back-up batteries for
the facility.  The battery system is designed to keep the computer systems operational should the
diesel generator fail to provide an uninterrupted power supply during a power outage. The
batteries will keep the computer system on-line for approximately 30 minutes. The third acid
neutralization tank is located beneath the battery room. The ERD has a back-up generator that is
run once each month for 15 minutes.  Preventative maintenance on the generator is performed by
maintenance staff once per year, generating used oil.

-------
              27 20 oz. bottles Type 028 3M Fix Solution
              14 30 oz. bottles CD-5 3M Developer ,
              3 80 oz. bottles Toner Clear Mix
             45 gal. bottles Kodak Ultratec Fixer and Replenisher
             45 gal. bottles Kodak Ultratec Developer and Replenisher
             4 16 oz. bottles Kodak Indicator Stop Bath
             5 Ibs. 8 oz. Developer Premix

The photoprocessing room is equipped with a Halon fire extinguisher.

2.2.6   Environmental Laboratory

       The Environmental Laboratory performs physical testing of postal equipment under
extreme conditions:  heat, cold, humidity etc. The work performed in the Environmental
Laboratory includes corrosion testing hi a salt chamber, UV light exposure and physical integrity
testing. For example, mailboxes are tested hi this laboratory to determine if they meet
Postmaster General specifications. The Environmental Laboratory contains one of three
limestone neutralization tanks for the facility. The drains from the analytical laboratory are
routed though the limestone tanks prior to discharge to the sanitary sewer.  The Assessment
Team found that the pit in which the tank was located contained approximately three feet of
water.  The room also contained a chiller and ERD staff explained that recent maintenance on the
chiller system may have generated water that flowed into the pit.

2.2.7   Metallurgical Laboratory

       The Metallurgical Laboratory is staffed by three individuals who are responsible for
testing and evaluating the physical properties of materials from which Postal  Service equipment
is manufactured. The physical properties of metals, plastics and other materials are tested in this
laboratory. For example, longer-life corrugated plastic trays were tested for physical integrity.
There were very few chemicals in this laboratory and all were labeled and stored appropriately.
Wastes, both solid and hazardous, are also minimal.

2.2.8   Analytical Laboratory

       This laboratory is staffed by three individuals who perform analytical testing for the
facility. This includes testing of stamp inks, glues, and papers. The laboratory appears well
organized with chemicals accounted for and Material Safety Data Sheets (MSDS) readily
available. The laboratory has separate storage areas for solvents, solid chemicals, and inks.  In
one undersink cabinet, acids and bases were stored together inappropriately.  The Assessment
Team noted the lack of appropriate waste chemical storage containers. Wastes generated include
waste inks, glues, phosphorescent inks, and laboratory chemicals.

-------
       The Automotive Bay contained one of the three lime neutralization tanks for the facility.
This neutralization tank was installed for a battery storage area; however, batteries are no longer
stored hi the area and the tank is used as a sump for the salt chamber.

       The drains hi the area all are connected to an oil water separator. In practice any oil
separated from the effluent is sent to an underground 250 gallon tank and water is discharged to
the sanitary sewer. Based on discussions with the area personnel and maintenance supervisor,
there has never been an oil spill in the room and no oil is sent to the drains. The staff stated that
the floors were washed with soapy water and rinsed down the drams. This may negate the
effectiveness of the oil/water separator because the soap would emulsify any oil in the equipment
and allow oil to exit the system through the sewer. The 250 gallon oil tank was reported to be
filled with water.

       Given its current use, minimal amounts of waste are being generated from the
Automotive Bay on a regular basis.  However, a recent collection and purge of hazardous
materials generated unused/unneeded chemicals, oils, paints and solvents had occurred. These
materials were stored for disposal hi the hazardous waste storage locker.

2.2.4  Hazardous \Vaste Storage Area

       The hazardous waste storage area is located in the hallway outside the high bay area.  The
storage area contains two 55-gallon drums and approximately 15 to 20 small containers of oils,
paints, and aerosol degreasers. According to the ERD staff, these containers were generated
from a recent purge  of unneeded chemicals/products.

2.2.5  Photoprocessing Room

       The photoprocessing room is no  longer hi use because of concerns about air quality,
worker safety and wastewater discharges raised during an earlier compliance audit. The
equipment has been unplugged but remains hi place until a new site or user is located. A color
developer with silver recovery unit and an aperture card plotter sit idle. The room also contains a
color plotter that is still hi use.

       Next to the photoprocessing room is a room that was designed and constructed as a
darkroom. The sinks and counters are still hi place, but the equipment was donated to a school.
The donated equipment included: three color enlargers, a stack camera and film dryers. This
space is currently hi use as an office and storage area for unused computer equipment scheduled
to be moved to the warehouse.                                                  :

       The flammable materials cabinet hi the  photoprocessing room contains the following
photo chemicals. According to USPS staff, these chemicals are in good condition and will
accompany the developing equipment when a new user is located. The chemicals include:
                                           5

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 contamination is minimal. In the computer laboratories, several aerosol degreasers and cleaners
 were in use.                                     .

 2.2.2  Model Room

       The Model Room is a machine shop that develops prototypes of machines, produces
 working models required for testing and research and manufactures parts and pieces as needed.
 The Model Room contains numerous kinds of machine shop apparatus including lathes, presses,
 milling machines etc.  A separate welding room, which houses a sand blasting cabinet, is entered
 through the Model Room.

       In general, the machines are lightly used, as very little production of parts is performed.
 As a result, maintenance, including oil changes, does not occur on a scheduled basis. Cutting
 fluids on several machines were aqueous-based, while others were oil-based.  A waste oil
 collection drum was located in one corner of the room. The drum sat atop a brand new, plastic
 spill containment tray.

        Several flammable materials cabinets are associated with the Model Room. These
 contain lubrication and cutting oils as well as inks, cleaning solvents and paints. The room also
 contains a large, old parts washer. This parts washer is serviced quarterly by an outside
 contractor. Under the terms of the service contract, the contractor removes 40 gallons of
 petroleum naphtha solvent quarterly.  This material is classified as a waste combustible liquid,
 Not Otherwise Specified (N.O.S.) with hazardous waste numbers D001 (ignitable), D006
 (cadmium), D035 (methyl ethyl ketone), D039 (perchloroethylene), and D040
 (trichloroethylene). The cost of the parts washer service is $524 per year. The maintenance
 supervisor expressed interest hi replacing this parts washer with an aqueous parts washer.  The
 machine shop has a scrap aluminum and steel recycling collection area. Machine shavings,
 however, are currently being disposed hi the solid waste compactor. The primary wastes
 generated by this area are scrap metals, metal shavings, waste oil and spent solvent from the parts
 cleaner.

        Waste receptacles hi this area contain a variety of materials including recyclable white
 paper, mixed paper, corrugated cardboard, plastic film and strapping, coffee cups and uneaten
 food.

 2.2.3   Automotive Bay

        The Automotive Bay is a high bay area in which research is performed on USPS vehicles.
 The bay contains several lifts and a salt chamber for corrosion testing. Examples of work
-performed in the Automotive Bay include the conversion of gas powered postal vehicles to
 Compressed Natural Gas (CNG) and corrosion testing of metals. At present, this area seemed to
 be used as a multi-purpose room. Recreational equipment was stored hi the room and a test mail
 assembly operation was being performed at one end.

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                                    SECTION 2.0

        ENGINEERING RESEARCH AND DEVELOPMENT FACILITY (ERD)
       This section addresses the specific operations performed within the ERD facility, the
wastes and emissions generated by these operations, and current waste management practices. A
majority of the solid waste is generated by office operations.  Hazardous wastes are generated
primarily by the research laboratories and from maintenance operations.

2.1    FACILITY DESCRIPTION

       Engineering, Research and Development (ERD) is responsible for the performance of
engineering, chemical, metallurgical and other kinds of research and development activities for
the Postal Service. These research and development activities include development and testing
of new mail processing equipment, development and testing of new materials and coatings for
mail handling and storage containers, chemical testing of stamp inks and papers and installation
and testing of coatings, alternative fuel equipment and retread tires for Postal Service vehicles.

       The ERD employs approximately 800 people. These include administrative, engineering,
computer, maintenance and janitorial personnel. The ERD facility has approximately 163,000
square feet of area on four floors. The three upper floors include offices, conference rooms,
computer laboratories and mainframe computer rooms. A break room is located on the third
floor. The basement level includes a model/machine shop, automotive bay, mail processing
equipment test bay, as well as a plotter/photoprocessing room and chemical, environmental and
metallurgical laboratories. The ERD also is responsible  for three support buildings. The
following description provides additional details concerning the major areas in the ERD facility.

2.2    ERD WASTE GENERATING ACTIVITIES

2.2.1  Office Space and Computer Laboratories

       The upper three floors of the ERD facility are occupied by offices, software design
activities, computer laboratories and mainframe computer rooms. Each computer room has a
Halon fire suppression system. The significant wastes include computer printouts, white paper,
mixed office paper, corrugated cardboard, paper cups and lunchroom wastes such as paper and
plastic bags, cans and bottles and uneaten food. The ERD has instituted a white paper recycling
program and it appears that the employees are active participants. Many of the centralized
collection bins were completely filled with paper. A cursory examination indicated that

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Highway to the north and an industrial area with a number of commercialoperations forms the
eastern border. A chainlink fence surrounds the USPS site, and a guard monitors all cars
entering from Prosperity Avenue. Vehicles can enter facility parking lots from Lee Highway
unchallenged.

       The USPS Merrifield operations include three main organizational groups operating
multiple sites within and around the Merrifield location. The three resident organizational
groups include: Engineering, Research and Development (ERD): the Processing and Distribution
Center (PDC); and the Vehicle Maintenance Facility (VMF). The mission of each group is
described below, followed by potential pollution prevention opportunities.

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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 waste
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, to identify the pollution prevention opportunities for
those facilities, to recommend implementation strategies and to develop facility guidance that.
can be incorporated into a revision of the USPS Waste Reduction Guide.

       This report describes the findings of the PPOA conducted for the United States Postal
Service's Northern Virginia facilities located hi Merrifield, VA. The site assessment was
conducted during the week of January 23,1995.

       The Assessment Team performed a multi-media assessment.  Wastes of concern included
emissions to air, primarily from solvents allowed to evaporate; wastewater discharges and the pH
level of these discharges when released to the sanitary sewer; hazardous material acquisition 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.  Both site-wide
and operation-specific recommendations are made that may lead to the elimination, reduction, or
improved management of the facility's waste streams. Mention of trade names, commercial
products or vendors does not constitute endorsement or recommendation for use.

       The USPS Merrifield operations are located on the south side of Lee Highway (Route 29)
in Fairfax County VA on approximately 15.5 acres of land bordered by Lee Highway on the
north and Prosperity Avenue on the west. An office park and warehouses are located across Lee

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                              ACKNOWLEDGEMENTS
Funding for this project was provided by the United State Postal Service under an interagency
agreement. Jim Bridges and Terri Hoagland of the EPA Office of Research and Development,
National Risk Management Research Laboratory managed the project and participated in the
opportunity assessments. Special thanks are extended to Charlie Bravo and Bernie Denno of the
USPS Office of Environmental Management Policy and the staffs of the USPS Merrifield, VA
facilities.

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                             EXHIBITS
3.1 WASTES SOURCES AND POLLUTION PREVENTION OPPORTUNITIES	11
3.2 MONTHLY HAZARDOUS WASTE DISPOSAL DURING 1993 AND 1994 	12
3.3 ERD HAZARDOUS WASTE DISPOSAL EVENTS IN 1993 AND 1994	13
3.4 CLASSIFICATION OF HAZARDOUS WASTE GENERATORS	 15
3.5 SUMMARY RESULTS ON PARTS CLEANERS EVALUATED BY THE USPS ....... 18
3.6 EXAMPLES OF POTENTIALLY INCOMPATIBLE WASTES	20
3.7 FIRE PROTECTION MEASURES	23
5.1 PDC POLLUTION PREVENTION OPPORTUNITIES	30
5.2 WEEKLY PURCHASES OF DISPOSABLE FOODSERVICE ITEMS	32
5.3 PDC HAZARDOUS WASTE DISPOSAL DURING 1993 AND 1994 	37
5.4 PRODUCTS USED CONTAINING EPA 33/50 CONSTITUENTS	39
6.1 VMF WASTE GENERATION AND RECYCLING ACTIVITIES	'...42
7.1 VMF WASTES SOURCES AND POLLUTION PREVENTION OPPORTUNITIES .... 46
7.2 COST/BENEFIT ANALYSIS: HVLP PAINT APPLICATION SYSTEM	48
7.3 COST/BENEFIT ANALYSIS: PAINT GUN WASHER STATION  	50
7.4 COST/BENEFIT ANALYSIS: ANTIFREEZE DISTILLATION UNIT	54
8.1 MERRTFIELD WASTE SOURCES AND OPPORTUNITIES	56
8.2 EPA MINIMUM RECOVERED CONTENT LEVELS	59
8.3 LASER PRINTER TONER CARTRIDGE REFURBISHERS	72
8.4 FEDERAL ENERGY POLICIES		73
                                IX

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CONCLUSIONS AND RECOMMENDATIONS	77
                           ;   ;- *   :f

APPENDICES	78
     EPA 33/50 PROGRAM	79
     OZONE DEPLETING SUBSTANCES 	80
     EPA GREEN LIGHTS PROGRAM & THE FEDERAL ENERGY MANAGEMENT
          PROGRAM	82
     EPAENERGY STAR PROGRAM	83
     COMPUTER EQUIPMENT REUSE AND RECYCLING 	85
     HAZARDOUS MATERIAL PHARMACY	87
     POLLUTION PREVENTION INFORMATION SOURCES ........	89
                              vm

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           4.2.1  Loading Docks	.26
           4.2.2  Hazardous Waste Storage Area	.27
           4.2.3  Mail Sorting Floor	 ,	.27
           4.2.4  Maintenance Cage	.._	.27
           4.2.5  Cafeteria	;.;	27
           4.2.6  Offices	28
           4.2.7  Facility Maintenance .... i	28
           4.2.8  Paint Booth 	28
           4.2.9  Maintenance Supply/Parts Room	28
           4.2.10 Battery Room			.28

PDC OPPORTUNITIES	29
     5.1    CAFETERIA	i		29
     5.2    PDC HAZARDOUS WASTE GENERATION	36
     5.3    CHEMICALS ON THE EPA 33/50 LIST	38
     5.4    MAIL HANDLING TRAYS	 40

VEHICLE MAINTENANCE FACILITY (VMF)	41
     6.1    FACILITY DESCRIPTION	41
     6.2    VMF WASTE GENERATING ACTIVITIES.  	41
           6.2.1  Service Bays	.41
           6.2.2  Paint Shop	43
           6.2.3  Wash Rack	.44
           6.2.4  Administrative Offices and Supply Room	 44

VMF POLLUTION PREVENTION OPPORTUNITIES	.45
     7.1    PAINTBOOTH	45
     7.2    AQUEOUS PARTS WASHER	 51
     7.3    HAZARDOUS MATERIALS STORAGE	52
     7.4    WATER RECIRCULATING SYSTEM FOR WASH RACK	52
     7.5    PURCHASING ON-SITE ANTIFREEZE RECYCLING UNIT	.53
     7.6    ENGINE OIL	;	.54

SITE-WIDE POLLUTION PREVENTION OPPORTUNITIES 	56
     8.1    SITE-WIDE CLEAN-UP EVENT i	57
     8.2    PROCUREMENT	57
     8.3    HAZARDOUS MATERIALS INVENTORY CONTROL SYSTEM 	62
     8.4    DONATION/REUSE OF OLD COMPUTERS  	65
     8.5    PAPER WASTE REDUCTION  .,	68
     8.6    UBBM REDUCTION	;	69
     8.7    RECYCLING		69
     8.8    ENERGY	71
     8.9    POLLUTION PREVENTION INFORMATION ON THE INTERNET  	75

                                  vii

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