EPA/600/R-96/115
September 1996
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
UNITED STATES POSTAL SERVICE
MATERIALS DISTRIBUTION CENTER
TOPEKA, KS
by
Carole O. Bell, Mary Hoel, Henry Huppert, Steven Rolander
Science Applications International Corporation
Newport, RI 02840
EPA Contract No. 68-C2-0148
SAIC Project No. 01-0828-07-1717-040
Project Officers
James S. Bridges
and
N. Theresa Hoagland
Sustainable Technology Division
National Risk Management Research Laboratory
Cincinnati, OH 45268
This study was conducted in cooperation with the
United States Postal Service
NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OH 45268
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DISCLAIMER
The information in this document has been funded wholly or in part by the United States
Environmental Protection Agency under EPA contract No. 68-C2-0148 WA 3-10 to Science
Applications International Corporation. It has been subjected to peer and administrative review,
and it has been approved for publication as an EPA document. Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.
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CONTACT
James Bridges and N. Theresa Hoagland are the EPA contacts for this report. They are presently
with the newly organized National Risk Management Research Laboratory's Sustainable
Technology Division in Cincinnati, OH (formerly the Risk Reduction Engineering Laboratory).
The National Risk Management Research Laboratory is headquartered in Cincinnati, OH, and is
now responsible for research conducted by the Sustainable Technology Division in Cincinnati.
n
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FOREWORD
The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency
strives to formulate and implement actions leading to a compatible balance between human
activities and the ability of natural systems to support and nurture life. To meet this mandate,
EPA's research program is providing data and technical support for solving environmental
problems today and building a science knowledge base necessary to manage our ecological
resources wisely, understand how pollutants affect our health, and prevent or reduce
environmental risks in the future.
The National Risk Management Research Laboratory is the Agency's center for investigation of
technological and management approaches for reducing risks from threats to human health and
the environment. The focus of the Laboratory's research program is on methods for the
prevention and control of pollution to air, land, water, and subsurface resources; protection of
water quality in public water systems; remediation of contaminated sites and ground water; and
prevention and control of indoor air pollution. The goal of this research effort is to catalyze
development and implementation of innovative, cost-effective environmental technologies;
develop scientific and engineering information needed by EPA to support regulatory and policy
decisions; and provide technical support and information transfer to ensure effective
implementation of environmental regulations and strategies.
This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office of Research and Development to assist the
user community and to link researchers with their clients.
E. Timothy Oppelt, Director
National Risk Management Research Laboratory
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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. In this report, the
findings of the Pollution Prevention Opportunity Assessment of the United States Postal Service,
Materials Distribution Center, Central Repair Facility, and Label Printing Center located in
Topeka, KS are described. This assessment was conducted during the week of March 6,1995.
The report describes the mission of each of the functional areas of the facility including
operations performed, processes and materials employed and the wastes and emissions generated.
Recommendations are made 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
and plastics; management of unwanted equipment; and other recommendations that can lead to
the elimination, reduction, or unproved management of the facility's solid and hazardous waste
streams and emissions to air and water.
IV
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TABLE OF CONTENTS
DISCLAIMER i
CONTACT ii
FOREWORD iii
ABSTRACT iv
EXHIBITS vii
ACKNOWLEDGMENTS viii
INTRODUCTION 1
1.1 SITE DESCRIPTION 2
MATERIALS DISTRIBUTION CENTER 3
2.1 FACILITY DESCRIPTION 3
2.1.2 Topeka Purchasing Center 4
2.1.3 Inventory Support 4
2.1.4 Systems Integration 5
2.2 MDC WASTE GENERATING OPERATIONS 5
2.3 WAREHOUSE OPERATIONS 6
MATERIALS DISTRIBUTION CENTER OPPORTUNITIES 8
3.1 PAPER RECYCLING 9
3.2 SOURCE SEPARATION OF ADDITIONAL RECYCLABLES 10
3.3 LIGHTING/ENERGY ; 11
3.4 PACKAGING SPECIFICATIONS 11
LABEL PRINTING CENTER 13
4.1 FACILITY DESCRIPTION 13
4.2 LPC WASTE GENERATING OPERATIONS 14
LABEL PRINTING CENTER (LPC) POLLUTION PREVENTION OPPORTUNITIES 16
5.1 LABELS 16
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5.2 PAPER .17
5.3 LPC MAINTENANCE SHOP ,19
5.4 PRESSURE SENSITIVE OPERATION .21
5.5 LPC HAZARDOUS WASTE GENERATION .23
5.6 LABEL PRINTING PROCESS MODIFICATIONS 24
5.7 PLASTIC TONER BOTTLES 26
CENTRAL REPAIR FACILITY (CRF) 28
6.1 FACILITY DESCRIPTION 28
6.2 CRF WASTE GENERATING OPERATIONS 28
6.2.1 Warehouse 28
6.2.2 Receiving 29
6.2.3 Shipping 29
6.2.4 Purchasing and Stock Room 29
6.2.5 Repair Mechanical fRM) Shop 31
6.2.6 Repair Boards CKB} Shop 31
6.2.7 Repair Peripherals fRP) Shop 31
6.2.8 Specification Development 32
CENTRAL REPAIR FACILITY POLLUTION PREVENTION OPPORTUNITIES 33
7.1 CRF PROCUREMENT AND INVENTORY CONTROL 34
7.2 USEOFEPA33/50 CHEMICALS 34
7.3 FLUXREMOVAL 37
7.4 LEAD SOLDER . 37
7.5 WASTE OIL COLLECTION ... r. 41
7.6 FOAM PACKAGING MATERIAL 43
FACILITY-WIDE OPPORTUNITIES 45
8.1 ENVIRONMENTAL COORDINATOR 46
8.2 ALLOCATION OF WASTE DISPOSAL FEES 46
8.3 SOLID WASTE COMPACTORS 47
8.4 REUSABLE DISTRIBUTION PACKAGING 47
8.5 PURCHASING AND INVENTORY CONTROL 50
8.6 AFFIRMATIVE PROCUREMENT 51
8.7 REDUCE PAPER USE 53
8.8 MAXIMIZE DIVERSION OF RECYCLABLE PAPER 53
8.9 IMPROVE SOURCE SEPARATION OF CORRUGATED CARDBOARD ..54
8.10 REDUCE DISPOSAL OF PLASTIC FILM 57
8.11 IMPROVE DIVERSION OF METALS 59
8.12 FLUORESCENT LIGHTING TUBES 60
8.13 HALON FIRE SUPPRESSANT SYSTEMS 64
8.14 LIGHTING AND ENERGY 67
VI
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8.15 POLLUTION PREVENTION INFORMATION ON THE INTERNET
70
CONCLUSIONS AND RECOMMENDATIONS 72
APPENDICES . 73
EPA 33/50 PROGRAM 74
OZONE DEPLETING SUBSTANCES 75
EPA GREEN LIGHTS PROGRAM & THE FEDERAL ENERGY MANAGEMENT
. PROGRAM 77
EPAENERGY STAR® PROGRAM .79
FLUORESCENT TUBE AND BALLAST RECYCLING 80
HAZARDOUS MATERIAL STORAGE STRUCTURES 82
SUPPLIERS OF VEGETABLE OIL INKS 83
POLLUTION PREVENTION INFORMATION SOURCES 85
EXHIBITS
3.1 MDC WASTE GENERATION .. 8
3.2 PAPER RECYCLING 9
4.1 LIST OF LPC PRODUCTS WITH ODS OR 33/50 CHEMICALS 15
5.1 LPC SOLID WASTE 16
5.2 POTENTIAL CLEANING AND DECREASING SUBSTITUTES 20
5.3 ADDITIONAL CLEANING AND DECREASING SUBSTITUTES 21
5.4 EXAMPLES OF HAZARDOUS WASTE STORAGE STRUCTURES 24
7.1 CRF WASTE GENERATION 33
7.2 MATERIALS USED AT CRF CONTAINING EPA 33/50 CHEMICALS 35
7.3 VENDORS OF LEAD-FREE SOLDER 39
7.4 EXAMPLES OF CONTAINMENT EQUIPMENT 42
8.1 FACILITY-WIDE OPPORTUNITIES 45
8.2 CRF PACKAGING PURCHASES 49
8.3 PRODUCTS WITH MINIMUM RECOVERED CONTENT LEVELS 51
8.4 RECYCLERS OF PAPER AND PAPER PRODUCTS 55
8.5 CORRUGATED CARDBOARD RECYCLING 57
8.6 PLASTIC FILM RECYCLING 59
8.7 METALS RECYCLERS 60
8.8 FLUORESCENT LIGHTING TUBE RECYCLERS 62
8.9 FIRE PROTECTION MEASURES 65
8.10 FEDERAL ENERGY POLICIES 67
VII
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ACKNOWLEDGMENTS
Funding for this project was provided by the United State Postal Service under an interagency
agreement. Jim Bridges and Terri Hoagland of the EPA Office of Research and Development,
National Risk Management Research Laboratory managed the project and participated in the
opportunity assessments. Special thanks are extended to Charlie Bravo and Bernie Denno of the
USPS Office of Environmental Management Policy and the staff of the USPS Topeka, KS
facilities.
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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.
In this report, the findings of the PPOA conducted for the United States Postal Service at
the facilities associated with the Materials Distribution Center located in Topeka, KS are
described. The site assessment was conducted during the week of March 6,1995.
The Assessment Team performed a multi-media pollution prevention assessment. Wastes
of concern included air emissions from the printing operation; wastewater discharges; hazardous
material acquisition, use and storage; hazardous waste storage and disposal; procurement; and
solid waste management, including recycling. The report begins with a brief description of the
facility. This is followed by descriptions of specific operations and the wastes and emissions
generated. 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.
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1.1 SITE DESCRIPTION
The Materials Distribution Center (MDC) is located approximately Vz mile west of Route
75 in Topeka, KS, at the corner of Montara Boulevard and Route 75. The surrounding area is
devoted to mixed industrial and agricultural uses. The site is bordered on the north by Forbes
Industrial Park, on the south by farmland, on the east by Route 75 and Forbes Field, and on the
west by a county golf course. The USPS operations occupy eight buildings on the site. Four
buildings are owned by the USPS (Buildings 301 through 304); four are leased by the USPS
from Forbes Industrial Park (Buildings 1 through 3 and 8).
Buildings 301-304 were built in 1953. Buildings 301 through 303 are one story
warehouses comprising approximately 200,000 square feet each, divided into five 40,000 square
foot areas. Building 304 is the pumphouse for the MDC's backup fire protection system. The
pump is capable of moving water from the on-site water reservoir to the MDC buildings in case
of fire. The USPS occupied these buildings in 1959; previously, the buildings were used by the
Department of Defense for the storage of natural rubber.
The leased facilities, Buildings 1,2, and 3, encompass an additional 440,000 square feet
of warehouse space. Building 8, providing an additional 78,000 square feet, is leased by the
USPS for a contractor-operated Central Repair Facility (CRF).
The USPS MDC operations include three organizational groups operating multiple sites
within and around the MDC location. The resident organizational groups include the Materials
Distribution Center, the Label Printing Center and the Central Repair Facility.
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SECTION 2.0
MATERIALS DISTRIBUTION CENTER (MDC)
This section addresses the operations performed within the MDC and the wastes and
emissions generated by those operations. The section also describes current waste management
practices.
2.1 FACILITY DESCRIPTION
The mission of the MDC is the specification, acquisition, storage, distribution and
maintenance of more than 16,000 parts, supplies, and pieces of equipment for the USPS
automation and computer systems, nationwide. The MDC encompasses five distinct operations:
Materials Distribution Center, Inventory Control, Inventory Support, Systems Integration, and
the Topeka Purchasing Center. The offices, a variety of inventory management and systems
integration functions, and repairables storage are located in Building 303. The MDC warehouses
include Buildings 1,2,3,301, and 302.
Each operation independently procures office supplies, computer and copier paper and
toner cartridges. Laser printer toner cartridge recycling is available, but is managed by a separate
agent hi each operation. Maintenance (plumbing, heating) for all operations is supervised by the
Plant Maintenance staff and billed to the MDC. Maintenance supplies and cleaning chemicals
are included.
2.1.1 INVENTORY CONTROL
Inventory Control includes both Logistics Management and Tech Data (National
Inventory Control) functions. Logistics Management is responsible for tracking equipment,
supplies and parts, maintaining current supplies and predicting future needs. The 22 employees
determine inventory needs for more than 15,000 stock repair parts, supplies and equipment for
400 USPS field offices. They also determine how much of a particular item will be kept on
hand, and notify purchasing when warehouse stock is low. Tech Data works with a core of key
vendors to .determine the parts needed to support each machine for ten years.
Logistics Management also collects excess or discontinued property and manages its sale,
either by auction or negotiated contract with a scrap dealer, based on the quantity and quality of
the materials. USPS has no mechanism to notify this group when equipment phase- out or
modification is planned. Equipment modifications can generate substantial amounts of material
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requiring management or disposal. Receipt of defective equipment also creates significant
material management costs.
2.1.2 Topeka Purchasing Center
The Topeka Purchasing Center has 20 employees including a manager, 14 purchasing
agents and secretarial support. The Purchasing Center does not establish requirements; these are
determined by Inventory Control. The procurement staff is responsible for identifying vendors
and procuring the parts inventory for the USPS automation system, nationwide.
2.1.3 Inventory Support
Inventory Support consists of 30 employees in five separate operations that provide
support to the National Inventory Control operations. Inventory Support is responsible for
establishing purchasing and packaging requirements. Additional responsibilities are described
below.
Provisioning
When procurement of new equipment is anticipated, the provisioning section performs
background research to support the purchase. This may include gathering engineering data from
the manufacturer and USPS Engineering Research and Development, creating models and testing
failure rates. Provisioning staff determine the land and number of parts that will be needed to
support the equipment in the field, particularly the anticipated number of spare parts per site
required for the first year of operation.
Catalogue and Technical Management
This group maintains the records of technical data, including all equipment drawings and
specifications. They are responsible for the catalogue record database and support to the
Assistance Center.
Topeka Material Assistance Center
The Material Assistance Center provides customer assistance to the field offices. These
individuals locate parts, track orders, and assure a timely response to customer questions and
concerns.
Acquisition Support
Acquisition Support provides product quality control and inspection services. The staff
may inspect orders at the loading docks and visit manufacturing facilities to observe and evaluate
products.
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2.1.4 Systems Integration
Systems Integration provides computer information systems support to the facility.
Systems Integration staff operate the Local Area Network (LAN), maintain personal computers,
and provide user support. They perform minor repairs and stockpile old parts for sale as scrap.
Although the complex has e-mail capabilities, the system is seldom used for facility-wide
communications. There has been no effort to procure energy efficient computer equipment.
Although the manager was familiar with EPA's Energy Star program, he felt it was inconvenient
because of the tune required for equipment warm-up. The Systems Integration section is testing
and evaluating the Material Distribution Inventory Management System, a headquarters project.
Fire protection in the computer room is provided by fourteen one quart glass bulbs of halon
installed hi the ceiling.
There is one lunch/break room with vending machines in Building 303. Each water
fountain has a paper cup dispenser. The restrooms are furnished with paper towels and liquid
soap dispensers.
2.2 MDC WASTE GENERATING OPERATIONS
Wastes generated by MDC operations include excess and obsolete equipment and
supplies; corrugated cardboard; computer paper, white paper, mixed office paper, and magazines;
laser toner cartridges; break room wastes including cans, bottles, wrappers, paper cups and food;
pallets; shrink and stretch wrap; plastic and metal strapping; and paper and plastic dunnage.
Solid waste disposal for all operations is coordinated through a single contract with
Topeka Waste, a subsidiary of Waste Management, Inc. The contract includes rental of five 40
cubic yard compactors. One compactor at Building 302 is pulled twice each month, compactors
at both ends of Building 2 are each pulled once per month and the compactor at Building 8 is
pulled weekly. The four waste compactors are pulled a total of 100 times per year. Charge per
pull is $618, for an estimated monthly solid waste collection and disposal bill of $4,944.
In November, 1994, the container at Building 303 was designated as the accumulation
point for recyclable corrugated cardboard. Topeka Waste Management charges $305 to deliver
the cardboard to Republic Paper. Republic Paper pays the MDC $125 for the compactor load,
for a net charge to the MDC of $180 every other month. Facility-wide, estimated monthly solid
waste management fees total $5,034, for an annual waste management expense hi excess of
$60,000. These charges are divided among the three organizational group finance numbers: the
Material Distribution Center pays three fifths of the total, the Label Printing Center one fifth, and
the Central Repair Facility the final one fifth.
The CRF compactor is pulled weekly and accounts for 52 percent of the total waste
volume generated by the Topeka complex. It appears that the CRF is being charged for only 20
percent of the total solid waste disposal costs.
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2.3 WAREHOUSE OPERATIONS
temps abo^fce aLTes ' warehouses ™ "S^ with double rows of fluorescent
areas Four sections fR 'IrT ^n*—«»«^ oFm,c uivmea mio live 40,000
". T™ or me c°st to the USPS. Wastes generated from shinnina m<\ rf>^,^ inciude.
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The older warehouses, Buildings 1 and 2, provide a <°^°°>000 e items
warehouse space Building 1 is dedicated to receipt, storage and shipping of 120 separate items,
saved the USPS more than $14 million in the past few years.
^^^-ttz^^ssss*.
302.
Obsolete forms and other paper discards are accumulated on pallets When^15 to18
pallets have accumulated, the contractor, P & S Services, is called tocollect *eP«p£&^
recycling. The P & S contract specifies that the paper must be recycled, not landfilled. me
USPS is paid 0.001 cents per pound of paper.
Building 3 is used for storage of obsolete equipment, materials awaiting auction or
protection; lights were left on, although the warehouse was not occupied.
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The MDC generates limited quantities of hazardous waste. In the past year, the MDC
disposed of two drums of waste paint that were inadvertently shipped to the MDC. The MDC
took responsibility for these drums and disposed of them as hazardous waste.
2.3 WAREHOUSE OPERATIONS
This section addresses the specific operations performed within the warehouses, the
wastes generated by these operations, and current waste management practices.
Five individual buildings and a portion of the MDC office building (303) are devoted to
warehouse operations. With the exception of Building 3, the warehouses are well insulated and
maintained at a comfortable indoor temperature for the physical comfort of the workers and
protection of the fire system. All of the warehouses are lighted with double rows of fluorescent
lamps above the aisles.
Building 301 has 200,000 .square feet of usable space divided into five 40,000 square foot
areas. Four sections of Building 301,160,000 square feet of warehouse space, are leased by the
Defense Logistics Agency and used for storage of bales of natural rubber, each weighing 250
pounds. The rubber has been on-site since the late 1950's and may already have reached the end
of its useful life. DLA has not indicated any interest in removing the rubber, although USPS
personnel indicated that the Postal Service needs the warehouse space. The fifth section of
Building 301 houses maintenance equipment and some maintenance activities, including the
ongoing destruction of more than 160 brass plaques bearing the old Postal Service logo. These
plaques, each weighing more than 100 pounds, were transported to the Topeka facility for
consolidation. Once the logo has been obliterated; the brass will be sold at auction.
Building 302 provides 200,000 square feet of usable space divided into 40,000 square-
foot areas. Building 302 houses the MDC receiving and shipping operations, as well as
warehousing of more than 16,000 "consumable" parts and equipment that are purchased,
consumed, disposed and replaced. Shipping and receiving activities procure thousands of
cardboard boxes and jiffy bags annually. The MDC was unable to quantify either the number of
these purchases or the cost to the USPS. Wastes generated from shipping and receiving include:
corrugated cardboard; paper, metal and plastic strapping; polystyrene peanuts; plastic film;
pallets; fluorescent light tubes and employee wastes.
Section A of Building 303 is the repairables section, housing 1,300 different kinds of
equipment that can be or have been repaired for reuse in USPS operations. Some computer
equipment from the Central Repair Facility awaiting shipping is stored here. The warehouses
were clean and well organized; however, significant quantities of obsolete equipment were
evident throughout the facility. For example, the Assessment Team observed more than 150
Apple HE computers, dating from the 1970s, still in the original boxes.
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The older warehouses, Buildings 1 and 2, provide a total of 400,000 square feet of
warehouse space. Building 1 is dedicated to receipt, storage and shipping of 120 separate items,
including capital equipment and supplies. These facilities are operated under the Rapid
Emergency Deployment Inventory or REDI system. Orders are generated by Inventory Control
and delivered daily, accompanied by appropriate shipping labels. After the items to fill an order
are removed from their warehouse locations, they are taken to the loading dock, packaged, and
shipped by Yellow Freight. All shipments are tracked using an electronic data interface through
which the USPS can communicate directly with Yellow Freight, locate any shipment and
determine its status within minutes. By eliminating paperwork and human error, this system has
saved the USPS more than $14 million in the past few years.
Building 2 is the supply warehouse for more than 3,500 paper products, including USPS
forms and documents. The shipping operation reuses some cardboard boxes, but most are
discarded into the compactor. For shipment of multiple packages to Bulk Mail Centers, the
supply warehouse currently uses cardboard gaylord boxes. The gaylords, 4 feet square, were
purchased to replace reusable over the road (OTR) containers. USPS staff defended this decision
because they need at least 11, and sometimes as many as 30, gaylord-size containers per day and
they cannot guarantee that OTRs will be available when needed. Staff stated that other USPS
facilities hoard OTRs, especially during the Christmas holiday season. Also, the OTRs require
more storage space, while gaylords store flat until used. It should be noted, however, that during
the three day assessment more than 20 OTRs were sitting outside in the snow behind Building
302.
Obsolete forms and other paper discards are accumulated on pallets. When 15 to 18
pallets have accumulated, the contractor, P & S Services, is called to collect the paper for
recycling. The P & S contract specifies that the paper must be recycled, not landfilled. The
USPS is paid 0.001 cents per pound of paper.
Building 3 is used for storage of obsolete equipment, materials awaiting auction or
disposal, and courtesy storage. For example, more than one hundred defective mail storage
boxes are stacked in cardboard boxes. The USPS logo must be cut from both sides of each box
before the metal can be sold as scrap. Building 3 is heated only minimally to maintain freeze
protection; lights were left on, although the warehouse was not occupied.
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SECTION 3.0
MATERIALS DISTRIBUTION CENTER OPPORTUNITIES
This section describes pollution prevention opportunities specific to the operations of the
Materials Distribution Center (MDC). Exhibit 3.1 summarizes the wastes generated by the
MDC, current management practices and potential pollution prevention opportunities.
EXHIBIT 3.1 MDC WASTE GENERATION
Waste
Obsolete, damaged or
defective equipment
Corrugated cardboard
Computer print-out
White paper
Mixed paper
Magazines
Toner cartridges
Pallets
Plastic stretch wrap
Strapping .
Dunnage
Current Management
USPS logo removed/defaced; auctioned or
sold as scrap
Some hauled to Republic Recycling by
Topeka Waste Management for net cost of
$180 per compactor load
Some collected for recycling by Hunter; some
discarded as waste
Some collected for recycling; most discarded
as waste
Some collected for recycling; some discarded
as waste
Discarded as waste
Refurbished and reused in multiple programs
Reused then discarded as waste
Discarded as waste
Discarded as waste
Discarded as waste
Opportunities
Reduce generation
Improve economics of scrap sales
Reduce incoming boxes
Improve diversion for recycling
Improve economics of recycling
Reduce generation
Improve diversion for recycling
Reduce generation, divert for
recycling
Reduce generation, divert for
recycling
Reduce generation, divert for
recycling
Combine into single program
Reduce variety, establish recycling
options
Reduce generation, divert for
recycling
Divert for recycling
Reuse, divert for recycling
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3.1 PAPER RECYCLING
Current Conditions
The Supply warehouse in Building 2 stores and ships paper products, e.g., Postal Service
forms and catalogs, to USPS facilities throughout the United States. The warehouse contains
3,500 unique items. For various reasons, such as the new Postal Service logo, items become
obsolete and must be removed from stock. Rather than disposing of the material in the dumpster,
the warehouse supervisor established a recycling program with P & S Services. The program
includes obsolete forms, publications, catalogs, and some cardboard.
The contract with P & S Services was awarded in September, 1992, and stipulates that the
paper must be recycled, not landfilled. The USPS receives $0.001 per pound ($2.00 per ton) for
scrap paper, including forms and miscellaneous paper grades. P & S Services also will collect
scrap wood and wooden pallets at no cost. Revenues received from the paper recycling program
are sent to the USPS payment center in San Mateo, CA.
Exhibit 3.2 lists the invoices that USPS has received from P & S Services. There is a
discrepancy, since there are no invoices for 1994. The USPS Contract Representative is working
to rectify this problem.
EXHIBIT 3.2 PAPER RECYCLING
Period
Oct-Dec92
Jan-March 93
July-Sept 93
Amount
Oct- 68,000 Ibs
Nov - 75,000 Ibs
Dec - 225,000 Ibs
173,000 Ibs
15,000 Ibs
Payment
$368.00
$172.97
$15.00
P & S Services collects material on an on-call basis and must pick up the paper within 48
hours. For each pick-up, the Postal Service must have available a truckload of material, i.e., 18
pallet loads or skids. According to the warehouse supervisor, P & S services picked up 18 pallets
per week (approximately 72 pallets per month or 864 pallets per year) hi 1994. For 1995, the
warehouse supervisor expects to generate 18 skids once every 2 weeks. A large amount of paper
was generated in 1994 because the new Postal Service logo made many forms obsolete.
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Pollution Prevention Opportunities
1. Reduce waste paper generation :;
The Postal Service should attempt to minimize the number of items that become obsolete
to reduce their waste paper generation. The supply warehouse staff should conduct a study to
determine the most common reasons why supply items become obsolete. Based on this study,
USPS can make recommendations to the appropriate offices about print quantities and revising
forms and catalogs in a manner that reduces the quantity of these items that must be discarded as
obsolete. Items that change for aesthetic reasons should not automatically be discarded or
recycled; rather, the existing stocks should be distributed and used during a transition phase
before new forms are issued.
2. Seek a more beneficial recycling contract
The supply warehouse should identify other paper recyclers hi the area that will provide
better service, including competitive pricing and better record keeping. The MDC should seek, a
long-term contract for paper recycling with a per ton payment indexed to the paper market. This
would guarantee a higher price for the paper. See Section 8.8 for additional recommendations
concerning unproved paper recycling and a list of area recyclers.
3.2 SOURCE SEPARATION OF ADDITIONAL RECYCLABLES
Current Conditions
The offices in the Materials Distribution Center currently separate some computer
printout for recycling. The computer printout is collected in 90-gallon wheeled containers.
However, the Assessment Team saw significant quantities of white paper and mixed office paper
in the waste containers. Aluminum cans and other food and beverage containers from the break
room are also discarded into the solid waste stream.
Pollution Prevention Opportunities
1. Seek new markets
Given the current market value of all grades of office paper, the MDC should seek a
market for .additional paper grades and enter into a long-term paper recycling contract indexed to
the paper market.
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2. Employee involvement and training
Employees need information concerning the kinds of paper that can and should be
recycled. Employees should be involved in the planning and implementation of the recycling
program so that they will value participating in it.
3. Improve source separation of paper
The MDC should provide individual desktop/side collection containers for recyclable
paper. These container should be clearly labeled and/or a distinct color to distinguish them from
the waste containers. A collection container for paper recycling should be located next to each
printer and copying machine. Employees should be encouraged to empty their desk collection
boxes into centralized consolidation containers. The recyclable paper should be regarded as a
valuable commodity, not a waste.
4. Source separate additional items
Recycling of aluminum cans and other food and beverage containers can be coordinated
with Shawnee County collection of toner bottles from the LPC.
33 LIGHTING/ENERGY
Current Conditions
The Assessment Team observed that MDC staff routinely left lights and equipment
turned on in restrooms, break room, offices and warehouses.
Pollution Prevention Opportunities
1. Motion sensitive lighting
Install motion sensitive lighting in breakrooms and other infrequently used areas.
2. Turn lights off
In warehouses, turn lights off in unused sections or maintain only low-level security
lighting. Establish a policy of turning lights off when leaving an office.
2. Low energy lighting
See Section 8.14 for a discussion of federal energy policies and the EPA Green Lights
Program. Even if the facility does not join the Green Lights program, it should strive to
incorporate the goals of the program into its lighting plans.
11
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3.4 PACKAGING SPECIFICATIONS
Current CtmM#«ni.
— ,- J ^ui" menf ^ ** PaCkagmg sPecifications to ensure the
packaging than is necessaV to protege sliL80™ t T^ ****** Speciflcations may require more
toner shipped to the LPC require that two boL^^^^^f08 specifications for
boxes must be palletized with rigid cardboard T H corrugated box. The
multiple layers will not protect the bottles of to ^fT' *f and shrinkwrapped. These
shipping any better than a sinele corramtrf i™ & ^°mdamage from f°rklift movement or
required packaging becomes solid vSSd^he ^^S multiPle bo^s of toner. All of the
specified originally. C must Pa^to dlsP°se of the packaging they
USpS Waste ReHnof,-^ ^1lidp (Ag 552 p ^^ , QQ.
rp:sreduc^rkagbgwastes^^ - -•
ior pacKaging are (1) no packasine (J\ ' ' • aaichire3ni« "ostal priorities
and (4) packaging that is recyclable' and co tain P agmg' ^ refiUable or reusable packaging,
materials should consist of 90 percent product * ^ materials- As a rule
1.
Review packaging specifications
packaging
not be threatened.
directs
S°Hd WaSte **•* »f
ackaging whenever product integrity wUl
12
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SECTION 4.0
LABEL PRINTING CENTER
practices.
4.1 FACILITY DESCRIPTION
The Labs, Printing Center (Buiiding 303) produce
enter the order information rnto the
discarded.
2x3-1/3 inch tags and each prints approxnnately 2;^1'°" ^tT^eL high-speed lines
of banding tape per day.
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3.4 PACKAGING SPECIFICATIONS
Current Conditions
Inventory Support staff are responsible for packaging specifications to ensure the
integrity of procured parts and equipment. In some cases, these specifications may require more
packaging than is necessary to protect the shipment. For example, packaging specifications for
toner shipped to the LPC require that two bottles of toner be placed in a corrugated box. The
boxes must be palletized with rigid cardboard comers, banded and shrinkwrapped. These
multiple layers will not protect the bottles of toner from damage from forklift movement or
shipping any better than a single corrugated box containing multiple bottles of toner. All of the
required packaging becomes solid waste and the MDC must pay to dispose of the packaging they
specified originally.
USPS Waste Reduction Guide (AS 552 February, 1992, p. 36) encourages postal
managers to reduce packaging wastes entering the Postal Service waste stream. "Postal priorities
for packaging are (1) no packaging, (2) minimal packaging, (3) refillable or reusable packaging,
and (4) packaging that is recyclable and contains recycled materials. As a rule of thumb, ordered
materials should consist of 90 percent product and 10 percent packaging."
Pollution Prevention Opportunities
1. Review packaging specifications
Review all packaging specifications for redundancy. Develop a policy that directs
developers of specifications to perform critical review of potential solid waste impacts of
packaging requirements. Reduce multiple layers of packaging whenever product integrity will
not be threatened.
12
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SECTION 4.0
LABEL PRINTING CENTER
This section addresses the specific operations performed within the Label Printing Center,
the wastes and emissions generated by these operations, and current waste management
practices.
4.1 FACILITY DESCRIPTION
The Label Printing Center (Building 303) produces variable data bag and tray labels for
40,000 customers, including USPS nationwide and a variety of bulk mailers. These labels must
be both human and machine readable. Orders for the labels are submitted on a USPS form.
Clerks enter the order information into the computer and file the order forms. The forms are
retained for three years. Only computer printouts are collected for recycling. Office paper and
quarterly purges of the files generate significant quantities of mixed office paper that is currently
discarded.
A majority of the labels are produced on a Dennison Presidax 1440 Ion Deposition
Computerized Label Printing System. Ion Deposition printing utilizes a toner to create the data
image on an anodized dielectric cylinder. The image is then transferred to the paper between the
dielectric cylinder and a pressure roller using 2,000 psi hydraulic pressure. Following
application of the data image, the paper is cut to size and the label order is wrapped with a clear
plastic, heat-welded banding tape. The LPC operates three lines. All three lines operate during
Tour 2 (day) and two of the three operate.during Tour 1 (evening). One line is shut down for
maintenance during Tour 1 on a rotating basis. Line 1 produces the 1x3-1/3 inch tags and prints
approximately 4 to 5 million tags per shift. This line produces collated sets of tags on alternating
weeks. The collated sets are made up of approximately 10 million tags. Lines 2 and 3 produce
2x3-1/3 inch tags and each prints approximately 2.5 million tags per shift. These lines run
collated sets every week that consist of approximately 10 million tags. These high-speed lines
use a total of thirty-five 650 pound rolls of tag stock paper, 32 gallons of toner and 13,800 yards
of banding tape per day.
Although the toner is poured from a one gallon/five pound bottle into the printer
receptacle, the printer area is remarkably clean and well maintained. The toner receptacle is
enclosed and an exhaust system draws any fugitive toner dust into a bag-house unit. The unit has
been in operation for one year, and the sock filters are currently being changed for the first time.
Facility personnel plan to dispose of the filters into the solid waste compactor. Floors around the
13
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equipment are cleaned regularly with a treated mop. The mop heads are returned to the supplier
who cleans, retreats and returns them to the facility.
The Label Printing Center also has a small Pressure Sensitive Label section which creates
small orders and custom labels for various Postal Service operations. This operation was moved
from New Jersey to Topeka in August, 1994. It utilizes an AM Multigraphics 2500 VR master
plate maker and two AM Multigraphics 2850 Offset Lithography presses. One two-person shift
processes orders that are cut to size and packaged by hand. Approximately half of the printing is
done on pressure sensitive stock and the other half on 110 and 120 Ib. cardstock and 20 Ib. bond
paper in a variety of colors. The purchase and use of paper varies seasonally and by workload;
however, facility personnel estimate that they will use 36,000 sheets of cardstock and 9,000
sheets of pressure sensitive paper per year.
Additional components of the LPC operations include: a raw material storage warehouse,
containing rolls of paper and boxes of toner for the printing system, as well as boxes of a variety
of colors and sizes of paper for the Pressure Sensitive section; a maintenance shop containing a
seldom-used solvent parts washer; and several computer rooms where label orders are entered
into the computers that drive the printing system. The cost of the paper is reduced because the
USPS has the ability to warehouse a significant stock of paper rolls. The LPC also contains a
break room for workers.
4.2 LPC WASTE GENERATING OPERATIONS
The Label Printing Center generates several hazardous wastes. These include gear oil,
hydraulic oil, and cleaners, degreasers, and chemicals associated with the operation of the offset
lithography presses: Blankrola solvent, Deglazing solvent, and Toner Remover. Exhibit 4.1
shows the products used by the Label Printing Center that contain ozone depleting substances
(ODS) or chemicals on EPA's 33/50 list of chemicals targeted for reduction. See the appendices
for further discussion of ozone depleting substances and EPA 33/50 Chemicals.
Solid wastes include corrugated cardboard, computer print-out, mixed office paper,
printed label stock, banded and printed label stock, cardboard cores and wooden ends from rolls
of paper, and HDPE plastic toner bottles. The toner bottles are collected by Shawnee County for
recycling on a no cost/no revenue basis. About five percent of the labels printed are test runs or
defective runs generating as much as 16,000 to 20,000 pounds of recyclable paper per month.
The printed white and colored tag stock is collected in gaylord boxes and sold to Republic Paper.
Republic Paper collects the tag stock and pays three cents per pound, providing monthly revenue
of $480 to $600. Another 4,000 pounds of excess banded label stock is generated each month.
The clear plastic bands are considered a contaminant and, because it is extremely labor intensive
to remove the bands to recover the paper, Republic collects this material, but does not pay for it.
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EXHIBIT 4.1 LIST OF LPC PRODUCTS WITH ODS OR 33/50 CHEMICALS
MSDS
Number
12
15
17
18
20
21
25
26
28
30
36
39
40
42
43
44
49
51
53
Trade Name
SLI Designers Cream
Belt dressing TM-3244
Clenesco Polylube Spray Grease
Curtis Industries Duratron Electric Parts cleaner
Radiator Specialty Company Electric Motor and
Contact Cleaner
Chemtronics Flux-off NR
Chemtronics Konform
Home Oil Company Solvent
Illinois Bronze Paint Company Wrinkle Finish Spray
Steven Industries Neoprene Contact Cement
Dymon A- 103 Contact Cleaner & Degreaser
Excelda MFG Co. Stainless Steel Polish-aerosol
GC Electronics Contact Kleen
Dymon A-098 Mechanics Friend
Crown Teflon Lubricant
GC Electronics Flux Remover-hi strength
AM Multigraphic Blankrola Solvent
AM Multigraphic Copier Toner Remover
AM Multigraphic Deglazing Solvent
ODS or 33/50 Chemical
20% xylene by weight
30% trichloroethane
17% trichloroethane
93% trichlorotrifluoroethane
4% trichlorofluoromethane
25 % perchloroethylene
73% trichloroethane
92% 1,1 ,2-trichloro- 1 ,2,2-trifluoroethane
1-10% toluene
30-80% 1 , 1 ,2-trichloro- 1 ,2,2-trifluoroethane
3% toluene
35-48% methylene chloride
8.2% methyl ethyl ketone
75-90% 1 , 1 ,2-trichloro- 1 ,2,2-trifluoroethane
98% trichloroethane
74% 1 , 1 ,2-trichloro- 1 ,2,2-trifluoroethane
perchloroethylene
1-10% toluene
51-70% trichloroethane
1 - 1 0% 1 , 1 ,2-trichloro- 1 ,2,2-trifluoroethane
74% methylene chloride
9.3% 1 , 1 ,2-trichloro- 1 ,2,2-trifluoroethane
25% perchloroethylene
70-75% trichloroethane
96% trichloroethane
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SECTION 5.0
LABEL PRINTING CENTER (LPC) POLLUTION PREVENTION OPPORTUNITIES
This section describes pollution prevention opportunities specific to the Label Printing
Center (LPC). Exhibit 5.1 presents the waste generated by the LPC and potential pollution
prevention opportunities.
EXHIBIT 5.1 LPC SOLID WASTE
Waste
Corrugated cardboard
Computer paper
Mixed office paper
Test runs and defective
printed label stock
Banded label stock
Cores and ends
HOPE bottles
Current Management
Hauled to Republic Recycling by
Topeka Waste Management for net
cost of $180 per compactor load
Some collected for recycling by
Hunter; some discarded as waste
Discarded as waste
Recycled
Recycled
Discarded as waste
Recycled
Opportunities
Reduce incoming boxes
Improve diversion for recycling
Improve economics of recycling
Reduce generation
Improve diversion for recycling
Reduce generation
Divert for recycling
Reduce generation
Reduce generation
Divert for reuse or recycling
Reuse
5.1 LABELS
Current Conditions
The LPC prints and distributes more than twelve million labels each day. The label
ordering operation and the label printing operation generate significant quantities of paper,
plastic and chemicals. In addition, the labels themselves are discarded and replaced, repeatedly,
throughout the mail distribution system.
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Pollution Prevention Opportunities
The USPS should seek an alternative mechanism to label mail bags, boxes and reusable
mail distribution equipment. For example, reusable labels may be used in closed loop
distribution programs. A bar-code or magnetic strip with coded information could be utilized if
human readability is not required.
5.2 PAPER
Current Conditions
The LPC currently is using virgin paper in its label printing operation. The LPC has a
three-year contract that expires in May, 1996 with the Paper Company of America (PC A) to
supply Ungummed Label Paper (tag) that meets U.S. Postal Specification #430307 dated August
8,1992. This specification requires 100 Ib. paper on 13.51 inch wide rolls with a roll diameter of
48 inches. The LPC uses approximately 35 rolls of paper per day. Therefore, the LPC uses
approximately 22,750 pounds of paper per day. The LPC uses mostly white paper but also uses
small amounts of colored paper. Paper is used on a first-in first-out basis. The paper is unloaded
from the pallet in the warehouse staging area outside of the LPC. The outer wrapping, including
brown paper, cardboard ends and wooden core plugs is disposed. The paper is then rolled into
the LPC and allowed to acclimate for one week prior to use in the printers.
Pollution Prevention Opportunities
1. Specify Tag Paper with Recovered Content hi New Procurements
The LPC should procure paper with recovered content after the current paper contract
expires in May, 1996. The USPS Waste Reduction Guide (AS 552, 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.
The LPC should strive to use paper with recovered content. The Assessment Team
contacted the current paper contractor, Paper Corporation of America (PC A), who indicated that
the current USPS contract price of $0.39 per pound was favorable to the USPS, since the price of
virgin paper has nearly doubled since this contract was signed. The PCA representative stated
that the paper used by the LPC is available with greater than 20 percent recovered content and,
on receipt of a firm request for paper with recovered content, they could provide a quote hi two
weeks for delivery hi 30 days. This indicates that paper used by the LPC is readily available
with recovered content. The PCA representative stated that the recovered-content paper would
certainly meet the existing paper technical specifications and that the quality of the paper with
recovered content was just as good as the virgin paper. The price of paper with recovered
content is currently higher than virgin paper. The PCA representative stated that the current
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price of this type of virgin paper was approximately $0.62 per pound, while paper with recovered
content was approximately $0.65 per pound. This could represent an increase in paper costs of
approximately $150,000 per year based on the current contract delivery rate of 5,200,000 Ibs. per
year. USPS Headquarters is drafting a policy supporting a five percent price preference for
products with recycled content. Facilities will be encouraged to purchase recycled-content
products, even at a higher price, as long as that price is no more than five percent above the price
of the product manufactured from virgin materials.
2. Recycle Core Plugs or Return for Reuse
The wooden core plugs on the paper rolls are used by the paper manufacturer to prevent
the cardboard fiber cores from being crushed during paper rolling, movement and storage. These
plugs, which come two per roll, are approximately 6 inches hi diameter and 1 inch thick and
weigh approximately 1.1 pounds each. The plugs are removed prior to paper use. In the past,
some of these plugs have been donated to schools for use in crafts projects. However, they are
typically disposed into the solid waste compactor. Use of approximately 35 rolls per day or
8,750 paper rolls per year, results in the disposal of approximately 17,500 core plugs weighing
approximately 19,250 pounds. The volume of cores disposed is approximately 10.6 cubic yards.
Based on the disposal fee for solid waste of $618 per compactor load, core disposal costs
approximately $155.00 per year.
The paper supplier stated that the paper mill would accept return of the plug cores as long
as they were not cracked or broken and the shipper paid for freight charges. The Postal Service
should accumulate the cores for an appropriate period of time and ship them back to the mills for
reuse. This may cost more than the disposal fee but should be considered as an option. Future
contracts should specify that the supplier backhand or absorb the cost of returning the plug cores.
3. List the Core Plugs on a Waste Exchange
A second alternative would be to list the core plugs on a waste exchange. Materials
Exchanges were established to provide a means for industrial waste generators to recycle (or
reuse) valuable resources. In general, waste exchanges try to "match-up" generators of waste
with companies interested hi recycling or reusing the discarded materials. The benefit from
waste exchanges is that clients minimize waste disposal expenses, reduce the need for landfilling,
and increase the value of wastes, by-products, surplus and off-spec resources. For further
information, contact:
Kansas Materials Exchange
P.O. Box 152
Hutchinson, KS 67504-0152
(316)6620551
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4. Recycle Fiberboard Cores
Approximately 8,750 fiberboard cores from the paper rolls are generated per year by the
LPC. Currently, the cores are discarded as solid waste. The cardboard recycler will not accept
the cores mixed with corrugated cardboard. LPC staff should work with local paper recyclers to
identify a market for the fiberboard. See Exhibit 8.4 for a list of local paper recyclers.
5.3 LPC MAINTENANCE SHOP
Current Conditions
The LPC has its own machine/maintenance shop where parts for the label printers are
cleaned and repaired. This shop has several repair benches and a solvent sink. The LPC uses
approximately 20 products that contain either ozone depleting substances (ODS) or chemicals on
EPA's 33/50 list. Exhibit 4.1 provides a list of materials used by the LPC that contain these
constituents. The LPC has begun phasing out the use of products with 33/50 chemicals and LPC
personnel state that adequate substitutes have not been found for nine materials.
Based on discussions with LPC personnel, the parts washer is used very rarely. The parts
washer is a solvent based unit and the LPC personnel state that the solvent has not been changed
hi five years. The LPC personnel also indicated that they have approximately 25-30 gallons of
fresh solvent (perchloroethylene) stored in a drum for use in the parts washer.
Pollution Prevention Opportunities
1. Eliminate solvent sink or replace with an aqueous washer
Eliminate the parts washer or replace with a non-petroleum based or an aqueous cleaning
system. The LPC should evaluate the frequency of use of the parts cleaner and make a
determination if the parts cleaner is necessary for the shop. If the LPC ever chooses or is
required to replace this parts cleaner, it should select an aqueous cleaning system. An aqueous
based parts cleaner currently is used at the CRF Repair Mechanical (RM) operation and
personnel have reported more than satisfactory parts cleaning.
2. Replace Products containing ODS and EPA 33/50 Chemicals
The LPC provided MSDSs for all of the products used. The Assessment Team identified
20 materials that contained constituents of concern, either ozone depleting chemicals or other
chemicals on EPA's 33/50 list. The LPC has taken steps to eliminate the use of or is depleting
existing stocks, with the exception of nine products. The following products have not been
eliminated because the LPC has not yet found an adequate substitute.
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Dylek NF Aerosol
LPC personnel were concerned about using particular chemicals that were not listed on
EPA's 33/50 list. Specifically, they were concerned about the use of 1,1-dichloro-l-fluoroethane.
This is an ingredient in Dylek NF Aerosol which is used as a cleaner for the small holes in the
ion deposition plate. 1,1-dichloro-l-fluoroethane is a hydrochlorofluorocarbon (HCFC) and is
considered a Class IIODS).
The Department of Defense (DOD), and the Air Force specifically, have taken the lead in
eliminating the purchase and use of ODS. DOD has restricted the purchase and use of all Class I
ODS (e.g., CFCs, Halon) and allows the use of Class II ODS only as a last resort. Specifically,
DOD states that Class II ODS may be used only after all environmentally preferable alternatives
have been evaluated and rejected for technical or economic reasons. The Postal Service does not
have a written policy concerning ODS, but USPS Headquarters has stated that facilities should
follow the Air Force policy described above.
In addition, the toxicity of this material is in the same range as other organic chemicals on
EPA's 33/50 list, targeted by EPA for reduction. Ideally, the LPC should specify a substitute
cleaner that can perform the cleaning function and is more environmentally acceptable. On-site
testing will still be necessary to assess the performance of any cleaner identified. Potential
substitutes are listed in Exhibit 5.2.
EXHIBIT 5.2 POTENTIAL CLEANING AND DECREASING SUBSTITUTES
Product/Company
Enviro Klean 1000
Allied Enterprises, Inc
Electrowash 2000
Chemtronics
Heavy Duty Degreaser
CRC Industries
Description
Low VOC, non-CFC aerosol spray for
degreasing various industrial parts and
equipment
General purpose electronic precision
cleaner. No ODS, safe on plastics.
Heavy duty cleaning and degreasing.
Removes grease, oil, dirt and other
contaminants from parts and equipment
NSN and Price
6850-01-061-5493
16 oz. $4.00
6850-01-393-9054
12.5 oz. $9.50
6850-01-380-3976
20 oz. $5.63
Chemtronics FluxoffNR
Chemtronics FluxoffNR is used to remove excess solder flux from circuit boards
following board repair. According to the MSDS, this material contains 92 percent 1,1,2-
trichloro-l,2,2-trifluoroethane. This chemical is a Class I ODS and is targeted for elimination by
Federal facilities.
20
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The Repair Board (RB) shop of the CRF has used this material in the past. This shop has
discontinued its use because of the presence of the l,l»2-trichloro-l,2,2-trifluoroethane. The
CRF has changed to a cleaning method that scrubs the boards with a solution of water and Mr.
Clean followed by rinsing with water and drying with pressurized air. Technicians at the CRF
stated that this method took more time and effort but that the quality of cleaning was acceptable.
The LPC should consider this alternate cleaning method for its board cleaning. For additional
less toxic electronics/flux cleaners see the Defense General Supply Center's Environmentally
Preferred Products Guide or the examples noted in Exhibit 5.2 above.
Dymon A-l 03 Contact Cleaner and Degreaser
This contact cleaner and degreaser is used to clean electronic parts and contains 75 to 90
percent I,lj2-trichloro-l,2,2-trifluoroethane. The LPC uses 144 -16 oz. cans per year. There are
several potential electronics cleaners/degreasers that do not contain ODS or chemicals on the
EPA 33/50 list. Exhibit 5.3 identifies two potential substitutes.
EXHIBIT 5.3 ADDITIONAL CLEANING AND DECREASING SUBSTITUTES
Product/Company
Electronics Cleaner/Degreaser 2000
Chemtronics Inc.
Lectra Clean II
CRC Industries
Description
Removes oils, grease, dirt and
fluxes. High dielectric strength.
Ultrasonic applications. Not
compatible with some plastics.
Electrical cleaning and degreasing.
Removes grease, oil, dirt and other
contaminants from motors, parts,
and other equipment
NSN and price
6850-01-1038
1 8 oz aerosol
$14.15
6850-01-382-5783
12-20 oz cans
$67.50
Gunk Brake Cleaner
The LPC uses 24-10 ounce cans of Gunk per year to clean the brake drums on the high-
speed printers. The MDC uses Curtisol Brake and Parts Cleaner (33882) for cleaning brake
drums. The Curtisol product does not contain any constituents of concern.
5.4 PRESSURE SENSITIVE OPERATION
Current Conditions
The Pressure Sensitive printing operation uses the following chemicals of concern: AM
Multigraphic Blankrola Solvent containing 25 percent perchloroethylene; AM Multigraphic
Copier Toner Remover containing 70 to 75 percent trichloroethane which is placed on small
wipe pads and used to clean the printer roller, mat or print drum; and AM Multigraphic
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Deglazing Solvent containing 96 percent trichloroethane, used for rubber roller deglazing and
deglazing the mats on the printer cylinder. These chemicals, when spent, constitute the majority
of hazardous waste generated by the facility.
Pollution Prevention Opportunity
1. Replace Chemicals with Non-toxic Alternatives
In cooperation with the equipment manufacturer, AM Multigraphics, LPC staff have
identified potential substitutes for these three materials. While some retraining of personnel may
be necessary, introduction of substitute chemicals has the potential to eliminate most hazardous
waste generation at the LPC.
2. Replace Petroleum-based Inks with Vegetable or Aqueous-based inks
Vegetable-based inks are alternative printing inks made with soybean or other vegetable
derived oils in place of all or part of the petroleum-based oils used in most inks. Soy-based ink,
or soy ink, was developed in 1979 as an alternative to petroleum-based inks to decrease
industry's dependence on imported oil. Since that time, approximately one-third of the
newspapers printed in the U.S. have begun to use soy inks. In addition, nearly one-fourth of the
commercial printers in the U.S. now are using soy ink on a regular basis.
Vegetable inks are available in both black and a variety of colors. According to trade
associations, colored soy ink is more widely used than black. Apparently, color vegetable based
inks are more competitively priced and tend to perform better than black inks, hi relation to its
petroleum-based counterparts. However, soy ink manufacturers indicate that black soy ink is
often the least expensive, with certain colors, such as green and purple, being the most
expensive. Among manufacturers, obviously, prices vary.
Soy inks offer many pollution prevention advantages over petroleum based products
because they:
• Reduce the content of petroleum oil hi inks and consequently lessen solvent emissions.
In heat-set printing, petroleum-based inks are dried, and volatile organic compounds
(VOCs) are released into the atmosphere in the drying process. Soybean oil does not
evaporate when the ink dries. Instead, the oil polymerizes as the ink hardens.
• Are easier to remove from paper pulp prior to recycling. This means there is less damage
to pulp fibers, fewer harsh chemicals are required, and less bleaching is required, leading
to more usable fiber and cleaner waste water in deinking and pulping mills.
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• Reduce the amount of paper wasted in press start-up. Soy ink flows more smoothly than
petroleum-based inks; as a result, the ink coverage is more thorough from the beginning
of a print job.
• Provide a more intense color than petroleum-based inks because soy oil is clear, while
petroleum is a dark, murky color. As a result, printers can use less ink to gain the same
effect. Some printers report as much as 25 percent greater mileage from soy inks.
• Decrease spoilage and the need to dispose of spoiled inks. Properly formulated soy inks
may exhibit better storage properties.
Some literature indicates that soy ink cleans off of presses more easily than petroleum-
based inks, allowing the printer to use less harmful cleaners, such as soap and water, as opposed
to the typical hydrocarbon solvents used to remove conventional inks from presses. However, no
confirmation of this information could be gained from actual printers. Most indicated no
difference hi necessary cleaning procedures.
See the appendices for Federal requirements for use of vegetable-based inks and industry
points of contact.
5.5 LPC HAZARDOUS WASTE GENERATION
Current Conditions
The LPC generates hazardous waste from the new offset printing process. This process
generates three hazardous waste streams. These include: Blanket wash (Blankrola) which
contains tetrachloroethylene (F002 when spent); Electrostatic solution containing potassium
hexacyanoferrate (potentially D003); and liquid developer, containing isoparaffmic hydrocarbons
(D001 if spent).
The LPC generates approximately one gallon per week of each of the above hazardous
waste streams. These are stored temporarily near the printing process and transferred to the
hazardous waste storage drums that are located in a lean-to shed adjacent to Building 303, where
the hazardous waste is stored in two drums on a pallet.
In addition there were numerous off-spec and/or outdated products in storage awaiting
disposal. The LPC staff is attempting to characterize and dispose of these materials in an
appropriate manner.
Pollution Prevention Opportunities
1. Set up an adequate hazardous waste storage area or satellite accumulation area.
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The LPC should set up an adequate hazardous waste storage area to reduce the potential
for spills, worker exposure and mixture of incompatible chemicals. The report from the facility
compliance audit performed in December, 1994 noted several compliance deficiencies for the
hazardous waste storage area and provided several options to remedy the hazardous waste
storage deficiencies. The Assessment Team concurs with each of the suggestions in the
compliance audit report and believes that the MDC/LPC should set up a secure hazardous waste
storage area or satellite accumulation site as soon as possible. The compliance report did not
provide any research information on storage containers, and LPC personnel were interested in
identifying potential storage devices: Exhibit 5.4 presents some examples of outdoor hazardous
waste storage containers. See the appendices for further guidance on procurement of storage
equipment.
EXHIBIT 5.4 EXAMPLES OF HAZARDOUS WASTE STORAGE STRUCTURES
Name and Address
Model
Price (May 1995)
P&D Systemtechnic
3026 River Park Drive
Louisville, KY 40211
(502) 776-7776
2P2-G (Non-combustible)
2-drum capacity
$1385.00
Safety Storage Inc.
23 01 Bert Drive
Hollister, CA 95023
(408) 637-5955
Safety Storage Locker, Model 2 (non-
combustible)
2 drum capacity
$910.00
HazStor Hazardous Material Storage
2454 E. Dempster St.
Desplaines, IL 60016
(708)294-1000
Model LK02 (Non-combustible)
Model LF02 (Fire Rated)
2 drum capacity
$2,350
$3,650
Precision Quincy Corp.
1625 North Lake Shore Drive
Woodstock, IL 60098
(815) 338-2960
Model HB 5 ST (Non-combustible)
3-5 drum capacity
$3,000
5.6 LABEL PRINTING PROCESS MODIFICATIONS
Current Conditions
The Label Printing Center generates significant quantities of recyclable paper from its
Dennison Presidax 1440 Ion Deposition Computerized Label Printing System. A majority of the
paper, approximately 20,000 pounds per month, is clean label stock which is recycled by
Republic Paper. Republic pays three cents per pound for this clean tag stock. An additional
4,000 pounds of label stock contaminated with plastic banding are generated each month. The
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clear plastic bands are considered a contaminant and, because it is extremely labor intensive to
remove the bands to recover the paper, Republic does not pay for this label stock.
Because of the design of the Dennison Printing Systems, it is not possible to perform
quality control (QC) on the labels prior to banding; therefore, some defective and test runs are
banded with the heat sensitive tape. LPC supervisors expressed a willingness to modify the
printing system to perform QC prior to the heat sensitive banding; however, this would require
an engineering redesign of the system.
In addition, LPC staff also are willing to consider alternatives to the heat sensitive
banding to permit increased recycling of the label stock; however, there are several constraints on
banding. For instance, the majority of the label must be visible and the banded label must be
both machine and human readable.
Pollution Prevention Opportunities
1. Modify the label printing process
The state of Kansas operates a non-regulatory pollution prevention program at the
Department of Environment's Office of Science and Support. The program provides assistance
in the form of library searches, free on-site consultations, and workshops on issues such as
solvent alternatives. Annual awards recognize innovative pollution prevention efforts. Contact
Theresa Hodges, Director, at (913) 296-5572 for more information.
Technical assistance is available through the Pollution Prevention Institute at the Kansas
State University Extension Service. The Pollution Prevention Institute provides free access to
the services of chemical and materials engineers. For further information, contact Michele
Feenstra (913) 532-6501.
The LPC should contact the Pollution Prevention Institute at Kansas State and the
Pollution Prevention Office at the Kansas Department of Environment for assistance in reducing
the waste from the Dennison Printing System. These organizations can assist in the following
areas:
• Reduce the reject rate of the printing systems,
• Develop a substitute for the heat sensitive plastic banding, such as a cellulose band or
paper wrapper with the label printed on the outside, and
• Redesign the printing system to allow quality control prior to banding.
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2. Stop banding test runs
The LPC should stop banding the test label with the heat sensitive banding tape. The test
bundles will always be waste and should not be banded. This will reduce the amount of
contaminated label stock.
5.7 PLASTIC TONER BOTTLES
Current Conditions
On average, the LPC uses 32 bottles of ion deposition toner per day, or 700 bottles per
month. Each bottle contains 5 pounds, or 3,000 ml of toner. The bottles were designed with a
wide mouth so that they could be placed into the printers, but there were problems with this
system. Currently, the toner is poured from the bottles into a collection bin in the printers. In the
past, the printing facility tried to use the toner hi bulk; however, transferring the toner from the
bulk containers to the printers proved very messy.
The toner bottles are made of natural HDPE plastic and have screw on lids. Currently,
LPC staff place the empty plastic bottles in a collection container. The toner bottles are picked
up by Shawnee County for recycling on a no cost/no revenue basis.
Pollution Prevention Opportunities
1. Establish a reuse program
The LPC should attempt to establish a reuse program with the toner manufacturer or
supplier. The Assessment Team contacted Delphax, the toner supplier, and Coates
Reprographics, the toner manufacturer, to determine whether they would accept the used
containers for refilling/reuse. Delphax does not accept the used containers for refilling or
recycling; instead, they encourage their customers to recycle the containers locally. Coates also
does not accept the used containers for refilling because of technical specifications on particulate
matter in the container. According to Coates, refilling the containers would require cleaning the
containers, and the combined cost of transporting and cleaning the containers would be higher
than the company can afford. Coates encourages its customers to recycle the containers.
Although neither the toner manufacturer nor supplier currently accept used toner bottles
for reuse, they may be willing to establish a trial closed-loop program in the future. Contact:
Mr. Steve Milewski
Delphax Systems
5 Campanelli Circle
Canton, MA 02021
(617) 828-9917 and
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Mr. Anthony Nickalls
Coates Reprographics Inc.
Country Club Road, P.O. Box #180
Dallas, Pennsylvania 18612-0160
(717)675-1131
2. Recycling
The LPC should contact other recyclers in the Topeka-Kansas City area to determine
whether the LPC can receive revenue from the used HDPE toner bottles. The Assessment Team
contacted Smurflt Recycling in Kansas City, KS to determine whether they would accept the
toner bottles. Smurfit accepts baled HDPE containers, although they may be able to accept them
unbaled in Gaylord containers. Before providing a price quotation, a Smurfit representative
would need to assess the type and quantity of material. The contact at Smurfit is Mr. John
Funke, Jr., Smurfit Recycling, 510 Division St., Kansas City, KS, 66103, (913) 236-8000, FAX:
(913) 722-5600.
3. Procurement specifications
For future toner procurement contracts, the Postal Service should consider including
language that requires the manufacturer or supplier to accept the toner bottles back for refilling
and reuse.
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SECTION 6.0
CENTRAL REPAIR FACILITY (CRF)
This section describes the operations of the Central Repair Facility, the solid and
hazardous wastes generated and the current arrangements for the management of those wastes.
6.1 FACILITY DESCRIPTION
The Central Repair Facility utilizes 78,400 square feet in Building 8, which is owned by
Forbes Industrial Park and leased to the USPS. Facility operations are performed by an on-site
contractor. There are 150 contractor employees and a USPS Facility Manager on-site. Facility
maintenance (plumbing, heating) is provided by the MDC Plant Maintenance staff. Solid waste
is disposed into a 40 cubic yard compactor which is serviced under the Topeka Waste contract
and charged back to the facility. The compactor is pulled weekly. CRF is responsible for
procuring janitorial services and cleaning supplies, however, USPS pays for the custodial
services.
The Central Repair Facility receives and repairs electronic equipment, including circuit
boards, monitors, printers and motors from USPS facilities, nationwide. Equipment still under
warranty is sent back to the manufacturer for repair and then returned to CRF for distribution to
USPS facilities. To avoid spending more on repairs than an item is worth, the CRF operates
according to a Master List, supplied by the USPS, that dictates the maximum amount of time and
money that can be spent to repair a particular item.
If the CRF makes a preliminary determination that it is not cost effective to repair a piece
of equipment or that the part is obsolete, the decision to dispose of the piece of equipment must
be confirmed by the Materials Review Board. The Board determines the final disposition of the
equipment which may be discarded, cannibalized and discarded, or returned to USPS for auction.
6.2 CRF WASTE GENERATING OPERATIONS
The following discussion describes the numerous wastes generated from the operation of
the CRF.
6.2.1 Warehouse
The CRF Warehouse contains parts and equipment awaiting repair as well as a supply of
containers for shipping repaired equipment. The warehouse is cleaned out twice each year,
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generating two to three compactor'loads per cleanup of discarded equipment and packaging.
Some pieces are returned to the MDC for auction and some metals are diverted for recycling.
6.2.2 Receiving
In the Receiving Section, boxes of equipment are unpacked prior to assignment to an
appropriate repair operation. A single employee unpacks the equipment and places the
packaging into a metal OTR. When it is full, the OTR is rolled over to the solid waste compactor
and emptied. As much as 90 percent of the packaging, including corrugated cardboard boxes,
foam molds, paper, plastic film, tape, strapping and other dunnage is discarded. A CRF staff
person indicated that there was no economic incentive to recycle.
6.2.3 Shipping
To protect repaired equipment during shipment, each part is encased in urethane foam.
An employee sprays liquid "Instafoam" into a corrugated cardboard box. As the foam begins to
rise, a pink plastic film sheet is placed on top of the foam. The repaired part is placed on top of
the plastic sheet and pressed into the foam which forms a protective nest around it. Next, the part
is covered with another plastic sheet and the box filled with foam. Closing the box forms the
foam over the part. This operation is supposed to be performed inside a hood; instead, the fan in
the hood is turned on and the work performed on a shelf hi front of the hood. The Instafoam
contains 4,4-diphenylmethane diisocyanate which is subject to the reporting requirements of the
Emergency Planning and Community Right-to-Know Act (EPCRA). The CRF currently does
not use sufficient quantities of this material to meet the reporting threshold.
The boxes with the foam mold are intended for reuse for shipping of similar kinds of
equipment. In reality, most are discarded. The foam attaches to the wall of the corrugated box,
contaminating the corrugated and rendering it unacceptable for recycling. Smaller boxes sized
for specific parts and pieces of equipment are utilized in another area of the shipping operation.
The shipping department uses approximately 30 different sizes and types of boxes and jiffybags.
In the past year, the CRF used 22,925 new boxes and 23,313 new jiffy bags. Some boxes
received were reused for shipping. Many parts are shipped to the MDC for restocking. Parts or
machines that are high dollar items or of limited quantity are sent directly back to the end user.
6.2.4 Purchasing and Stock Room
The CRF stock room maintains inventory control by utilizing contractor-developed
software to sustain an accessible record of the status of each item. Under the current contract
with the USPS, the contractor is required to control the inventory and materials used in the CRF
and maintain a stockroom to properly support CRF operations. Requirements include
maintaining stockroom security at all times and limiting the number of employees authorized to
make receipts to and issues from the stockroom. The contractor is required to maintain a current
29
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inventory of all accountable items furnished by the USPS and to perform quarterly inventories of
one quarter of the stockroom items, and annual inventory of all accountable property items.
Procurement and Inventory Control at the Central Repair Facility provides an example of
a well organized and operated materials handling operation. All supplies and parts are ordered
by a central purchasing department. Materials are managed from a Central Stock Room. The
purchasing department does not specify paper products with recovered content, but some toilet
tissue and towels contain recovered content. Otherwise, no products with recovered content are
procured by the CRF. The following provides a more detailed description of the purchasing and
material control system at the CRF.
Purchasing
The purchasing department at the CRF consists of two purchasing agents. One agent
handles the stock inventory and the other purchases new or special items. The purchasing
department is authorized to make purchases up to $10,000. Purchases above $10,000 require
USPS approval. Only the USPS supervisor has a credit card for purchases. The purchasing
agents use a purchasing and materials inventory system based on software developed by the
contractor to manage its inventory. This system contains a database of information on all items
purchased by the CRF, including description, National Stock Number (NSN), Original
Equipment Manufacturer (OEM) number, quantity on-hand, price, vendor, and storage location.
This system also tracks the usage of items as they are requisitioned from stock and automatically
produces purchase orders based on usage rates and stock reorder point (usually half the yearly
usage rate). This system allows the purchasing department to track monthly usage so material
shortages do not occur and to observe trends to allow investigation of abnormal usage of
materials. The system allows the procurement staff to provide rapid turnaround on requests
concerning stock on hand as well as past material usage trends. They are able to access NSNs,
product information and costs in a clear concise fashion. This system can also track waste
disposition. For example, the purchasing staff was able to track the quantity of waste oil sent for
recycling in the past year (26 55-gallon drums)..
Material Distribution
Distribution of items is carefully controlled hi the CRF. Access to the stock room is
limited to a small group of authorized employees. Only stockroom employees are allowed into
the stock areas; others have access only to a parts pickup area. If an item is required by a
technician, it is requested via computer. The contractor has developed a system by which the
shop supervisor or other authorized party enters the request at a terminal in the shop. The request
is processed in the stock room, removed from stock, placed in a bin for pickup and deducted
from the computer inventory record. Each shop designates a "runner" who is authorized to enter
the parts pickup area to retrieve the completed order. This system keeps a tight control over
stock and keeps employees at their work stations, rather than searching for parts.
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6.2.5 Repair Mechanical (RM) Shop
The RM shop performs a wide variety of mechanical repairs, including motors for letter
sorting machines and other motor parts. The shop has 17 technicians. When a machine is
brought in for repair, any oil is drained into a drain pan. The used oil is then placed into a used
oil storage drum that contains a funnel and cap. There is no secondary containment system for
the used oil drum. When the oil drum is full (approximately every three weeks), the drum is
capped and moved with a fork lift to the back loading dock. After several drums are
accumulated, an oil recycler is called to collect the oil. The recycler charges $15.00 per drum.
The technicians use disposable rags for cleanup.
The RM shop contains two aqueous parts washers in a diked area. Water from the parts
washers is drained once per month into the sanitary sewer system. A filter system is being
ordered for the parts washer to remove oil from the water prior to sending it to the drain. The
disposal method for any filters generated has not yet been determined.
The shop also uses a heated oil system to heat bearings prior to use. No waste oil has
been generated from this system to date. Other wastes generated from this shop include scrap
metals and batteries which are recycled with the MDC metals recycling program.
6.2.6 Repair Boards (Rm Shop
The RB shop repairs numerous types of circuit boards. The shop has 53 technicians. The
technicians typically clean the board to remove dust and dirt prior to beginning work. This is
performed manually in the wash room by scrubbing the board with Mr. Clean (ammonia, soap,
and water) and water or, in some cases, nail polish remover (acetone). The clean boards then are
dried using compressed air. All washing chemicals are discharged into the sanitary sewer. The
technicians then diagnose the problem and replace chips or other defective components by
desoldering the piece and resoldering a replacement part. After repair, the board is washed again
to remove excess flux and dirt. CRF personnel estimate that the desoldering operation generates
approximately one pound of lead solder per day that is discarded as solid waste. Technicians use
disposable rags for cleaning. Several products containing EPA 33/50 chemicals were noted in
the shop.
6.2.7 Repair Peripherals (RP) Shop
The RP shop is very similar to the RB except that it has 22 technicians and repairs
keyboards, monitors, printers and other peripherals. The RP shop utilizes Fluxsolv, a product
containing 1,1,1-rrichloroethane, to clean circuit boards.
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6.2.8 Specification Development
The Specifications Development area is an office setting where the specifications for
equipment testing and repair are developed. This office has no recycling, and no duplex copying
capability. The specifications development area also has a computer room and document storage
area which has a Halon fire suppression system.
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SECTION 7.0
CENTRAL REPAIR FACILITY POLLUTION PREVENTION OPPORTUNITIES
This section presents the Pollution Prevention opportunities specific to the Central Repair
Facility (CRF). Exhibit 7.1 provides a list of the CRF wastes, management practices and
potential pollution prevention opportunities.
EXHIBIT 7.1 CRF WASTE GENERATION
Waste
Cardboard
Foam
Plastic film
Tape
Strapping
Metal
Batteries
Paper
Oil
Computer parts
Solder
Current Management
Discarded into solid waste
Discarded into solid waste
Discarded into solid waste
Discarded into solid waste
Discarded into solid waste
Collected for recycling
Discarded into solid waste
Accumulated for recycling through
MDC
Discarded into solid waste
Discarded into solid waste
Collected for recycling
Sold as scrap
Discarded into solid waste
Discarded into solid waste
Opportunities
Replace with durables, Reuse
Recycle
Replace with durables, Reuse
Reduce, Recycle
Eliminate
Reduce, recycle
Improve source separation for recycling
Source separate
Recycle
Reduce paper use
Recycle
Secondary containment for drums
Cover storage area
Sell to computer recycler
Less-toxic substitute
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7.1 CRF PROCUREMENT AND INVENTORY CONTROL
Current Conditions • '
The CRF stock room maintains inventory control by utilizing contractor-developed
software to sustain an accessible record of the status of each item (see Section 6.2.4 for a full
description of the inventory control system).
Pollution Prevention Opportunities
1. Use the system to track hazardous materials.
The inventory control system should be modified to include a data field that indicates the
presence of ODS, EPA 33/50 chemicals, and TRI chemicals and that can be used to track
hazardous materials ordered and used in the CRF. This will allow the CRF to identify products
containing hazardous materials and target them for reduction in use or for product substitution.
Such a system may also assist in the quantification of hazardous materials used, for the purposes
of TRI reporting.
7.2 USE OF EPA 33/50 CHEMICALS
Current Conditions
The CRF currently uses many materials containing chemicals on the EPA 33/50 list.
Exhibit 7.2 presents the materials identified by CRF contractor personnel as containing EPA
33/50 chemicals. The CRF has phased out the use of some products that contain these chemicals
and some employees have used personal initiative to remove others from the work place.
Pollution Prevention Opportunities
1. Change Purchasing Specifications
Change purchasing specifications to require substitute products that do not contain the
target chemicals. Once current stock is exhausted, only 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 publishes bi-monthly Hazardous
Technical Information Series Bulletins on new environmentally-preferable products, as well. To
be placed on the DGSC mailing list, write to Defense General Supply
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EXHIBIT 7.2 MATERIALS USED AT CRF CONTAINING EPA 33/50 CHEMICALS
Category/Product
Use
33/50 chemical
Adhesives
E-Z Weld Multipurpose Solvent Cement
Scotch-Grip 1357 High Performance contact
Adhesive
Liquid Nails 601
Service Cement
Trubond Contact Cement
General purpose adhesive
General purpose adhesive
Wood to wood, wood to
polyurethane
Foam to metal
General purpose adhesive
methyl ethyl ketone
methyl ethyl ketone
benzene
toluene
toluene, methyl ethyl
ketone
Office Supplies
Correction Fluid Thinner
Correction Fluid
Thinning correction fluid
Paper correction
1,1,1 -trichloroethane
1,1,1 -trichloroethane
Solders
LA-CO Fast 50/50
Copper Alloy Solder
Flux cored Solder
Metal Alloy Solder
Solder
Solder
Solder
Solder
lead
nickel
lead
lead
Flux Remover
Fluxsolv
Remove excess solder flux
1,1,1 -trichloroethane
Coatings/Paints
Red GLPT Varnish
Kleer Spray
Ultra Flat Black
Locquic primer T
Red Lead
Used on windings and coils
Clear coat on bar code labels
Recoating metal surfaces
Primer
Coating to check gear tooth
contact
xylene
toluene
xylene
1,1,1 -trichloroethane
lead tetraoxide
Lubricants
Spray Lube
Tel-X Aerosol
Lubricant
Lubricant
1,1,1 -trichloroethane
1,1,1 -trichloroethane
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EXHIBIT 7.2 MATERIALS USED AT CRF CONTAINING EPA 33/50 CHEMICALS
Category/Product
Cleaners
GSA Stainless Steel Polish
Meter Mist Country Garden
Temperature Testing
Tempilaq 200-219
Tempilaq400
Tempilaq 375, 388
Tempilaq 313, 319, 325, 331, 338, 344, 350, 363
Tempilaq Red Label Thinner
Other •
Imtech NCI Toner
Prevent Aerosol
Use
Steel polish
Air freshener
Indicate temperature when
heating metal for different
applications
Tempilaq thinner
Copier toner
Unknown use
33/50 chemical
1,1,1 -trichloroethane
1 , 1 , 1-trichloroethane
toluene
1,1,1 -trichloroethane,
toluene
1,1,1 -trichloroethane,
toluene
1,1,1 -trichloroethane,
toluene
1 , 1 , 1 -trichloroethane
toluene
1 , 1 , 1 -trichloroethane
Center, DGSC-SHS/HTIS, 8000 Jefferson Davis Highway, Richmond, VA 23297-5670. There
are several other sources of information on pollution prevention as well as on potential chemical
substitutes. See the appendices for additional sources of pollution prevention information. See
Section 8.15 for a discussion of Internet Resources.
The following describes some potential alternatives to products currently purchased that
contain EPA 33/50 chemicals. Ideally, the CRF should specify substitutes that can perform the
same function and are more environmentally acceptable. On-site testing will be necessary to
assess the performance of these products.
Cleaners
The CRF currently uses a GSA stainless steel cleaner that contains 1,1,1-trichloroethane.
GSA stocks a stainless steel cleaner that does not contain any EPA 33/50 chemicals. Caljen
Gleem Stainless Steel Cleaner has a National Stock Number of 7930-01-360-8050.
<
Air Freshener
The CRF currently uses an air freshener that contains 1,1,1-trichloroethane. There are
numerous off-the-shelf air fresheners that do not contain EPA 33/50 chemicals.
36
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Correction Fluid
Aqueous based correction fluid is available from GSA. The NSN is 7510-01-020-2806.
This will eliminate the use of both the correction fluid and correction fluid thinner containing
1,1,1 -trichloroethane.
7.3 FLUX REMOVAL
Current Conditions
During the on-site assessment, the Team observed several methods of removing flux and
cleaning printed circuit boards prior to and following repair. Among the shops in the CRF, there
are different policies concerning the use of hazardous materials. In particular, the Repair Board
(RB) shop and the Repair Peripheral (RP) shop have different policies on the use of Fluxsolv
which contains 1,1,1-trichloroethane. The RB shop is not allowed to use Fluxsolv to clean the
circuit boards because the shop supervisor is concerned about the health effects of 1,1,1 -
trichloroethane. Instead, RB shop staff must clean the boards with Mr. Clean detergent and
water. RB staff find that this method works; however, it takes a little more effort.
In contrast, RP shop staff routinely use Fluxsolv to clean their circuit boards. When
asked if Mr. Clean could be substituted for Fluxsolv, shop staff indicated that it would not work.
It did not appear that the RP shop had made any attempt to identify less-toxic substitutes for
Fluxsolv.
Pollution Prevention Opportunities
1. Make facility-wide hazardous materials policy changes
When a substitute is found for a product containing hazardous material, the CRF should
make a policy change that applies to all the shops in the facility. This should apply immediately
to the substitution of Mr. Clean for Fluxsolv as well as for future substitutes that may be found to
work in place of hazardous substances.
7.4 LEAD SOLDER
Current Conditions
The Central Repair Facility uses lead-containing solder hi its electronic repair activities to
"connect" or form conductive electrical joints on circuit boards. In 1994, the CRF used 68 rolls
of Kester solder, 351 rolls of solder wick lite, six rolls of flux .025 diameter reliacore 15 RMA
wire solder alloy, and two rolls of flux P-3 reliacore 15'RMA wire solder alloy. The CRF has
always used lead solder in its operations and has not conducted any research into alternatives.
As one technician stated, "We use lead solder because that's what we have always used."
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The desoldering operations at the CRF generate approximately one pound of lead solder
waste per day. The lead-containing solder waste is disposed into the solid waste compactor as
common practice. In Kansas, lead waste is governed by the Federal Resource Conservation and
Recovery Act (RCRA). However, most RCRA regulations do not apply to small quantity
generators, i.e. those generators who produce less than 100 kg/month of all types of hazardous
waste. Although the CRF may be allowed to dispose of the lead solder waste in the trash, there
are several environmental concerns associated with this waste management practice. Most
importantly, heavy metals, such as lead, may leach from the landfill to contaminate local ground
water supplies and cause human health concerns.
In addition to the environmental concerns associated with lead, lead soldering also
requires the use effluxes and cleaning solvents containing hazardous chemicals such as methyl
ethyl ketone and toluene.
Pollution Prevention Opportunities
1. Lead Solder Substitutes
The CRF should identify an alternative, lead-free solder and substitute this product for
the lead solder in its repair activities. There is a relatively large commercial market for lead-free
solders, and a variety of vendors. However, there are no "drop-in" replacements for lead
containing solders. That is, any lead-free replacement will have different performance
characteristics than standard lead solders and may require technical changes in soldering
techniques.
Prior to procuring and using lead-free solders, the CRF should insure that any
replacement solder meets their requirements. Because of the wide range of performance
requirements and the wide variety of lead-free solders available, it is not possible to recommend
a one-for-one replacement. The actual selection of a specific solder should be performed by CRF
staff. Exhibit 7.3 provides information about vendors of lead-free electronic solders.
For additional information on research and development efforts on lead-free solders, the
CRF should contact the National Technology Transfer Center (NTTC). NTTC can provide
information, at no cost, about ongoing research and development, as well as evaluations of lead
free solders. Their address is:
The National Technology Transfer Center
316 Washington Avenue
Wheeling, WV 26003
Phone: (304) 243-2126
FAX: (304) 243-2539
Contact: Mr. Aaron M. Hasak, Technology Agent
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EXfflBIT 7.3 VENDORS OF LEAD-FREE SOLDER
Vendor
Description (Information as of May 1995)
Englehard Corporation
235 Kilvert Street
Warwick, RI02886
1-800-225-2130
Englehard Corporation manufactures a variety of lead-free solders.
In particular they manufacture a rosin core solder for electronic use
called Silvabrite 100. The cost of this solder, which is a
tin/copper/silver alloy, is $9.43/lb, based on a 50 Ib. order.
IBM/Fusion Incorporated
4658 East 355th St
Willoughby OH 44094
(216)953-4964
FAX: (216) 942 9083
IBM Fusion manufactures lead-free solders, including tin/silver
solders. They stated that these solders perform as well as
conventional lead solders.
Taracorp Industries
1200 16th St.
Granite City IL, 62040
1-800-851-3300, ext 162
FAX: (618) 451 9310
Taracorp Industries manufactures a wide variety of lead-free solders
for use in electronics. Prices range from $3.80/lb for tin/antimony
solder, to $4.95/lb for tin/copper solder. The type of solder will
depend upon the specific applications and requirements, such as
melting temperature and strength.
Kester Solder Test Equipment
515 East TouhyAve
DesPlaines, IL60018
(708) 699-5562
FAX: (708) 699 5548
Kester Solder Test Equipment manufactures lead free solder for
electronic use. Before using this solder, the circuit boards must be
tested to ensure that they can withstand the higher temperatures
typically required for lead-free solders.
Arcade Electronics
5655 F General Washington Drive
Alexandria VA 22312
(703) 941 1074
FAX: (703) 941 1325
Arcade Electronics has available a tin solder which can be used with
a flux that does not require cleaning. It is available in 20 pound
boxes at $15.10 per pound.
Another resource available to the CRF is the Manufacturing Technology Information
Analysis Center (MTJAC), part of the Defense Technical Information Center. This Center can
provide information, at no cost, on lead-free solders for electronic use. Their address is:
Manufacturing Technology Information Analysis Center
ITT Research Institute
10 West 35th Street
Chicago, IL 60616-3799
Phone: 800-421-0586
FAX: (312) 567-4736
2. Lead solder waste recycling
Although the CRF may be legally permitted to dispose of their lead soldering waste in the
trash, this practice should be discontinued because of the environmental, human health and
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liability concerns associated with this type of lead disposal. Instead, the CRF should institute a
lead soldering waste collection and recycling program. This program can be established easily
and at little cost. Placing a centralized lead soldering waste drum in each shop to collect the lead
waste from staff and placing individual lead soldering waste collection containers at each
technician's work station will allow ease of lead accumulation.
There are several lead recycling operations in Kansas and Missouri that will accept lead
soldering waste from the CRF. Lead recyclers include:
Schuylkill Metal Corporation
P.O. Box 156
Forest City, MO 64451
(816)446-3321
Schuylkill Metal Corporation is a secondary smelter of lead located approximately 100
miles from Kansas City, MO. Then- primary source of lead is from lead-acid batteries.
However, they have the capacity to accept other forms of lead waste, including soldering waste.
Soldering waste is not an especially valuable source of waste, but Schuylkill Metal Corporation
will accept small quantities at no cost as a public service. Generators can deliver soldering waste
directly to the plant or Schuylkill may be willing to pick up from the generator when there is a
vehicle in the area.
The Doe Run Company
Highway KK
Boss, MO 65440
(314)626-3476
The Doe Run Company is a large secondary lead smelter. They are located in the south
central part of Missouri, approximately 250 miles from Kansas City. They accept a variety of
soldering wastes; normally, they pick up material in full truck loads. The value of the material
depends upon the type of waste. They will accept small quantities of lead waste delivered to
their facility.
3. Materials Exchange
The CRF also may consider contacting the Kansas Materials Exchange to determine
whether they will accept a listing for lead soldering waste. The exchange was established to
provide a means for industrial waste generators to recycle (or reuse) valuable resources. In
general, waste exchanges try to "match-up" generators of waste with companies interested in
recycling or reusing the discarded materials. The benefit from waste exchanges is that clients
minimize waste disposal expenses, reduce the need for landfilling, and increase the value of
wastes, by-products, surplus and off-spec resources.
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Kansas Materials Exchange
P.O. Box 152
Hutchinson, KS 67504-0152
(316)662-0551
7.5 WASTE OIL COLLECTION
Current Conditions
The Repair Mechanical (RM) Shop in the CRF generates waste oil from its repair
activities. There is a centralized collection drum hi the shop to collect the used oil. The RM
•shop generates one drum of waste oil every two to three weeks. They generated 26 drums of oil
hi the past year. When the drum in the shop is full, it is capped and moved to the loading dock
with a forklift. After several drums have accumulated, the CRF contacts Capitol City Oil who
charges $15.00 per drum to recycle the used oil.
None of the used oil drums has secondary containment to prevent spills and leaks from
escaping into the environment. On the loading dock, there was evidence of oil spills and/or leaks
and one empty drum was knocked over because of the wind. An oil sheen was observed on the
dock during a period of rain.
Pollution Prevention Opportunities
1. Obtain secondary containment for used oil drums
To prevent spills or leaks that may escape into the environment, the CRF should purchase
secondary containment for the used oil collection drums located inside and outside the building.
In addition, the drums stored outside should be covered to protect them from the elements.
Sources and cost estimates for secondary containment equipment are listed below in Exhibit 7.4
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EXHIBIT 7.4 EXAMPLES OF CONTAINMENT EQUIPMENT
Product
Manufacturer
Description
Cost (May 1995)
Double Drum Waste
Collection Center
#57-858
Direct Safety Company
7815 South 46th Street
Phoenix, AZ 85044
1-800-528-7405
Polyethylene drum storage
system which stores two 55-
gallon drums. Two lockable
slide-on covers snap into place
for watertight seal. Drums rest on
removable grating.
$699.00
Spill Control Pallets
(available in two-drum
and four-drum sizes)
2-drum #57-852
4-drum #11-683
Direct Safety Company
7815 South 46th Street
Phoenix, AZ 85044
1-800-528-7405
Designed for use hi weather-
protected environment, these
pallets provide secondary
containment necessary to protect
against leaking drums.
2-drum: $281.00
4-drum: $434.00
Spill Killer Containment
Unit
#57-130
Direct Safety Company
7815 South 46th Street
Phoenix, AZ 85044
1-800-528-7405
This secondary containment
holds one 55-gallon drum and is
designed to be easily moved by a
forklift.
$148.75
Spill Skid Systems
3-drum SpillSkid with
fiberglass grate and tarp
#YS-23412
4-drum SpillSkid with
fiberglass grate with tarp
#YS-14896
Lab Safety Supply
P.O. Box 1368
Janesville, WI53547-1368
1-800-356-0783
Each holds a full 85 gallons of
spill inside an HOPE wellspace.
Sturdy, non-metallic construction.
Transportable by forklift
3-drum with grate and
tarp $441.20
4-drum with grate and
tarp $572.00
SteelSkids and Spill
Platform
YS-18394
Lab Safety Supply
P.O. Box 1368
Janesville, WI 53547-1368
1-800-356-0783
Factory-grade platforms of 7-
gauge steel allow safe storage of
up to nine 55 -gallon drums. All
units feature removable steel-bar
grating, 3/4" drain plug and
attached grounding bolt for
flammable protection.
Nine drum platform
$1,444.00
Polyethylene Spill Sump
Basin
#74-095A
C&H Distributors
400 South 5th Street
P.O. Box 04499
Milwaukee, WI 53204
1-800-558-9966
Made of HOPE; prevents
environmental contamination by
collecting leaks and spills.
$45.00
Spill Container
2-drum base #74-226D
2-drum cover #74-234D
4-drum base #74-245D
4-drum cover #74-262D
C&H Distributors
400 South 5th Street
P.O. Box 04499
Milwaukee, WI 53204
1-800-558-9966
Contains spills and leaks from 55-
gallon steel drums. Drums are
held securely by a molded-in
locating ring
2-drum base $207.00
2-drum cover $207.00
4-drum base $247.00
4-drum cover $247.00
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7.6 FOAM PACKAGING MATERIAL
Current Conditions
To ship computers and computer parts, the CRF uses "Instafoam," an expandable liquid
foam, as packaging material in the cardboard boxes. CRF staff spray the Instafoam in a
cardboard box, place a plastic sheet over the foam, allow the foam to expand, and then place the
object in the box. A second plastic sheet is placed over the computer equipment, and the
Instafoam is sprayed onto this plastic sheet to provide additional protection. Since the Instafoam
is sprayed directly into the cardboard box, the box cannot be recycled, because it is very difficult
to remove the foam from the box.
The Instafoam is supplied hi a set of 120 gallon drums: Part A Instafoam is a polymeric
diphenylmethane diisocyanate, and Part B Instafoam is a mixture of polyols, methane catalysts
and silicone surfactant. The CRF used approximately 18 sets of the Instafoam hi 1994 at a cost
of $82,620. In addition, the CRF used an estimated 23,000 boxes and 46,000 plastic sheets for
shipping at a cost of more than $3 0,000.
As mentioned earlier, the Instafoam contains 4,4 diphenylmethane diisocyanate which is
subject to the reporting requirements of EPCRA; however, the CRF does not use enough of the
material to make it reportable under these regulations. Currently, the Instafoam operation is
conducted next to, rather than under, the fume hood. Although the hood is turned on when the
Instafoam is sprayed, it is not able to capture all of the vapors because the operation occurs at too
great a distance from hood.
Pollution Prevention Opportunities
1. Use reusable foam templates
Since the Instafoam contains hazardous materials, the CRF should find alternatives to this
product. The CRF should pursue the use of reusable foam templates as packaging materials. In
general, the equipment shipped from the CRF falls into four categories: 1) monitors, 2)
keyboards, 3) computers and 4) circuit boards. Although the specific shapes may vary slightly,
the overall form of the equipment hi each category is similar. A template could be developed for
each category and used as packaging material in place of the Instafoam. This recommendation
should be addressed hi conjunction with the recommendations concerning reusable packaging
(see Section 8.4). A foam template will eliminate the use of a product that contains a TRI
chemical and will allow the reuse/recycling of the packaging container.
There are several considerations for this pollution prevention opportunity. First, the
CRF/USPS must establish a system to return the templates to the CRF for reuse. There will be
labor costs associated with the research and design of this type of program. A second
consideration is that the foam packaging will require more storage space. CRF will have to
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identify storage space; however, there appears to be sufficient storage space available in other
warehouses (e.g., Building 3).
2. Change Instafoam process
If the CRF continues to use the Instafoam process, then the process of filling the box
should be modified. The filling of the boxes should be performed inside the ventilation hood to
reduce worker exposure to hazardous chemicals. The current hood is not large enough to make
its use easy for the workers; modification of the hood may be necessary.
Operators also should change the method of using the Instafoam. Staff should place a
plastic sheet in each box prior to spraying the foam. This will prevent the foam from adhering to
the box and allow separation of the foam from the box. The box can then be reused to package a
different part or be recycled.
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SECTION 8.0
FACILITY-WIDE OPPORTUNITIES
This section addresses pollution.prevention opportunities that impact a variety of
operations within the Topeka facilities. Exhibit 8.1 summarizes the opportunities identified
during the PPOA.
EXHIBIT 8.1 FACILITY-WIDE OPPORTUNITIES
Waste or Operation
Environmental management
Waste disposal
Corrugated cardboard
Procurement
Paper
Energy
Fluorescent lighting tubes
Halon fire suppressants
Pollution Prevention Opportunities
Appoint environmental coordinators to organize pollution prevention
and recycling activities among the operations
Allocate solid waste disposal costs based on generation
Use compactor pressure gauge to determine when containers should be
pulled
Perform cost/benefit analysis
Introduce reusable distribution packaging
Establish closed loop network for OTRs
Improve source separation for recycling
Establish a new recycling contract
Utilize inventory control software
Purchase products containing recycled content
Eliminate purchase of products with EPA 33/50 chemicals
Reduce paper use
Train employees in source separation
Institute a multi-facility recycling program
Establish lights out policy
Use motion sensitive lighting where appropriate
Utilize Green Lights Program
Procure Energy Star compliant computer equipment
Establish a recycling program
Replace
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8.1 ENVIRONMENTAL COORDINATOR
Current Conditions :
The Topeka Materials Distribution Center does not have an environmental coordinator
who is responsible for the environmental activities at the Topeka facilities. Instead,
environmental activities are addressed on an as-needed basis by either the facility maintenance
supervisor or various interested staff members. More importantly, no one is designated to
monitor environmental compliance issues at the Topeka site. Ultimately, the highest ranking
USPS employee on site is responsible for all environmental activities, including the CRF.
Should a hazardous waste spill occur, this individual would be held responsible and liable for the
clean-up.
In addition, there is no coordination between the organizations that have established
environmental programs, such as recycling. For instance, the Label Printing Center has initiated
a paper recycling program with Republic Paper, the Supply Warehouse in Building 2 has
established a separate paper recycling program with P & S Services and the MDC offices are
working with Hunter. No attempt has been made to coordinate these recycling programs.
Pollution Prevention Opportunities
1. Appoint Environmental Coordinators
The Materials Distribution Center should appoint at least two environmental coordinators
for the Topeka facilities. One should be responsible for the environmental activities at the MDC
and the other should be responsible for the Central Repair Facility. These individuals should
monitor the environmental issues at the facilities and identify opportunities to either reduce or
recycle the wastes generated. In addition, the two environmental coordinators should work
together to develop environmental programs, such as affirmative procurement, that apply to all
the facilities. These activities are not likely to require an extensive time commitment; interested
staff could be encouraged to accept this additional responsibility...
8.2 ALLOCATION OF WASTE DISPOSAL FEES
Current Conditions
One compactor at Building 302 is pulled twice each month (24 pulls per year).
Compactors at both ends of Building 2 are each pulled once per month (24 pulls total) and the
compactor at Building 8 is pulled weekly (52 pulls per year). The four waste compactors are
pulled a total of 100 times per year. According to the MDC solid waste contract administrator,
the MDC is charged 3/5 of the total solid waste costs, the LPC 1/5 and the CRF 1/5.
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Pollution Prevention Opportunity
1. Reallocate solid waste costs based on generation rate.
The current cost allocation system does not provide any incentive for an organization to
reduce its solid waste disposal. Each organization's solid waste disposal charges are constant,
regardless of the quantity of waste generated. The MDC should allocate solid waste disposal
costs based on the number of compactor pulls that an organization requires. This will provide
equitable sharing of costs and allow organizations to realize reduced operating costs based on
reduced waste generation.
8.3 SOLID WASTE COMPACTORS
Current Conditions
The 40 cubic yard compactors for solid waste are pulled on a weekly or bi-weekly basis.
The charge is $618 per pull.
Pollution Prevention Opportunities
Use the pressure gauge on the compactor to determine whether the container is full.
Pulling only when the container is full may reduce the number of pulls, and thus the total solid
waste collection and disposal costs for the facilities.
8.4 REUSABLE DISTRIBUTION PACKAGING
Current Conditions
The MDC, LPC and CRF purchase thousands of single use corrugated boxes to ship
printed labels, supplies and equipment to regional bulk mail facilities for distribution to other
USPS facilities. For example, the MDC uses corrugated gaylord boxes to containerize boxed
USPS forms and documents for shipment to regional Bulk Mail Centers (BMCs). Topeka MDC
staff noted mat they were unable to maintain a sufficient supply of BMC Over the Road
containers (OTRs) to meet their shipping needs.
The USPS Waste Reduction Guide (AS 552, February, 1992, p. 36) states that USPS
priorities for packaging are (1) no packaging, (2) minimal packaging, (3) refillable or reusable
packaging, and (4) packaging that is recyclable and contains recycled materials. USPS policy
states, "Returnable packaging—such as some shipping containers—can be returned to suppliers for
reuse and redistribution. Refillable or reusable packaging may be refilled or reused by postal
employees, manufacturers and consumers ... Requirements-generating offices should investigate
the potential for using these types of packaging. Packaging that can be refilled or reused for its
original purpose is preferable ..."
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Neither the MDC nor the LPC was able to determine the number of boxes purchased
annually. Exhibit 8.2 provides an overview of CRF purchases of boxes and other packaging.
Once the shipments from the MDC, LPC or CRF are received at their final destination,
the boxes become waste. The USPS incurs additional costs for the labor to unpack and manage
the boxes as well as the costs associated with their ultimate recycling or disposal.
The USPS has addressed the question of how to move mail between or among facilities
and, at the same time, reduce the generation of waste and the cost and labor to manage that
waste. The USPS maintains an inventory of more than 75 million pieces of reusable mail
transport equipment (MTE) ranging from trays and hampers to rolling stock. Wire containers,
BMC OTRs, and multi-purpose containers are considered desirable because the increased
capacity of these containers reduces the number of trips, resulting hi savings from reduced labor
and transportation costs.
At present, each USPS facility must document its requirements for MTE. Local areas are
encouraged to establish "closed loop" systems to ensure the availability of containers (Container
Methods Handbook PO-502, pp. 116f). However, imbalances in container availability affect
facility operations and MTE inventory control remains a complex problem. To improve
inventory control, the USPS plans to establish a network of 31 Mail Transport Equipment
Service Centers. The MTESC will provide computerized inventory tracking and maintain repair
records. Facilities will be able to call the MTESC to find out where excess MTE should be sent
as well as to order additional MTE.
Pollution Prevention Opportunities
1. Initiate cost/benefit analysis
The USPS should apply the same policy to the movement of USPS materials and supplies
that they have applied to the movement of mail. USPS should initiate a study to determine the
cost/benefit of replacing single use corrugated boxes in certain USPS shipping operations with
distribution packaging that can be reused hundreds of tunes.
According to a 1994 report entitled Delivering the Goods: Benefits of Reusable Shipping
Containers (INFORM, Inc.), reusable distribution packaging is most effective when utilized:
• for frequent deliveries,
• over short distances ,
• between a small number of parties, and
• using company-owned or "dedicated" vehicles
The MDC initiates daily shipments to regional Bulk Mail Centers using dedicated vehicles.
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EXHIBIT 8.2 CRF PACKAGING PURCHASES
Item
Folder/foam 20x12x3
Folder/foam 7x7x3
Folder/foam 12x10x4
Folder/foam 10x8x3
Starpack 6x6x10
Starpack 10x10x12
DoubleWall (DW) box 9.5x5.75x4.75
DW box 8x4x4
DWbox 19.75xll.375x8.75
DW box 17.5x14x12
TripleWall (TW) Box 28x28x20
DW Box 22.5x1 1x9.5
DW Box 26x15x13
DW box comer stitch 22.75x21x16
DW box fold to fold 24x24x9.5
DWbox 15.5x8.5x10.25
DWbox 14.75x13.25x13.75
DWbox 15.75 x 14.25x13.75
DWbox 12x12x6
DWbox 25.5x20.5xl 8
DW box 21x15.75x13.125
DWbox 14x14x8
TW box 30x15x12
DWbox 24x16x12
DWbox 24x12x6
DWbox 38x29x24
Box for model 644
Coir, box 16x16x16
DW box 40.75x5.25xl.75
DWbox 24x24x24
TOTAL
Cost Per Item
$1.72 ea
.65 ea
.88 ea
.67 ea
2.66 ea
6.79 ea
.65 ea
.38
.76 ea
2.21 ea
23.41 ea
3.15
4.91
2.18
3.10
1.44
1.46
3.14
.59
3.81
2.38
1.02
5.61
2.60
2.32
5.20
3.17
1.17
2.16
5.10
Quantity Used
4,820
3,483
2,829
11,422
206
373
3,148
60
3,354
2,401
27
135
125
1,579
490
315
180
60
3,375
1,680
1,251
2,465
30
475
765
8
249
693
5
55
46,058
Total Cost
$ 8,290.40
2,263.95
2,489.52
7,652.74
547.96
2,532.67
2,046.20
22.80
2,549.04
5,306.21
632.07
425.25
613.75
3,442.22
1,519.00
453.60
262.80
188.40
1,991.25
6,400.80
2,977.38
2,514.30
168.30
1,235.00
1,774.80
41.60
789.33
810.81
10.80
280.50
$51,943.05
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The five major obstacles to expanding reuse of distribution containers are: 1) capital
expense, 2) tracking containers, 3) cost of returning containers to point of origin, 4) lack of
storage space and 5) resistance to change. The REDI system (see Section 2.3) could serve as a
model for an OTR tracking system. Containers can be hauled to the MDC using established
routes. Storage space should not provide a major obstacle since the containers will move in and
out of the facility on a daily basis.
2. Establish closed loop network for BMC OTRs
Specifically, the MDC should establish a closed loop distribution network with regional
BMCs. This will allow the MDC and the BMC to keep track of the number of OTRs in transit
and establish a system to haul OTRs to the MDC on a regular basis. Once this closed loop
network is established, the MDC will be able to eliminate the use of the corrugated gay lord
boxes, reducing purchasing, labor and disposal costs for both the MDC and the BMCs.
As mentioned above, the USPS provides instructions for designing and implementing
"Closed Loops" in Handbook PO-502, Container Methods, Section 322.4, page 116.
8.5 PURCHASING AND INVENTORY CONTROL
Current Conditions ,
Despite numerous telephone discussions, the Materials Distribution Center staff did not
provide any information on the kinds and quantities of packaging purchased for the warehouse
operations. The staff did state that each section kept this information separately and there was no
centralized information storage. The Central Repair Facility purchasing agents use a purchasing
and materials inventory system based on software developed by the contractor. This system
contains a database of information on all items purchased by the CRF, including description,
NSN, OEM, quantity on-hand, price, vendor, and storage location. This system also tracks the
usage of items as they are requisitioned from stock. The system allows the procurement staff to
provided rapid turnaround on requests concerning stock on hand as well as past material usage
trends.
Pollution Prevention Opportunities
1. Introduce inventory control software
Introduce the use of software that will enable the MDC to store purchasing and stock
information in a database that includes fields for tracking monthly use, quantity on-hand, price,
vendor, and storage location. This information can be used to track monthly usage so material
shortages do not occur and to observe trends to allow investigation of abnormal usage of
materials. This system also can track waste disposition and recycling.
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8.6 AFFIRMATIVE PROCUREMENT
Current Conditions
The decentralized nature of the procurement system at the Topeka facility leads to
inconsistent purchasing practices and procurement standards. For instance, the CRF has cleaning
product dispenser units that measure exact amounts of product for use, while the MDC 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 USPS Waste Reduction Guide 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 finalized 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 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 Branch Agency, it is
Postal Service policy to adhere to Executive Orders whenever possible. Exhibit 8.3 presents
products for which EPA has established minimum recovered content levels.
None of the Topeka operations is able to document successful implementation of EPA
procurement guidelines for products manufactured with recovered content. In addition, the
operations cannot demonstrate successful reduction or elimination of the seventeen 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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EXHIBIT 8.3 PRODUCTS WITH MINIMUM RECOVERED CONTENT LEVELS
Category/Product
Percent Recovered Content
Paper
High grade bleached printing and writing paper
20%
Mimeo and duplicator paper
20%
Computer paper
20%
Envelopes
20%
Tissue Products
Toilet tissue
2-100%
Paper towels
40-100%
Paper napkins
30-100%
Facial tissue
10-100%
Unbleached packaging
Corrugated boxes
25-50%
Vehicular Products
Lubricating Oil (re-refined oil)
25%
Tires
retread tires
Construction Products
Fiberglass (glass cullet)
20-25%
Cellulose loose-fill and spray-on (postconsumer paper)
75%
Structural fiberboards
80-100%
Laminated paperboards
100%
Cement and Concrete (coal fly ash)
0-40%
Cement and Concrete (ground granulated blast furnace slag)
25-50%
Polyester Carpet Face Fiber (PET resin)
25-100%
Patio blocks (rubber or rubber blends)
90-100%
Patio blocks (plastic or plastic blends)
90-100%
Floor tiles (rubber)
90-100%
Floor tiles (plastic)
90-100%
Transportation products
Traffic cones (PVC, LDPE, Crumb Rubber)
50-100%
Traffic barricades (HDPE, LDPE, Pet Steel)
80-100%
Traffic barricades (Fiberglass)
100%
Park and Recreation Products
Playground surfaces (rubber or plastic)
90-100%
Running tracks (rubber or plastic)
90-100%
Landscaping Products
Paper-based hydraulic mulch (postconsumer recovered paper)
100%
Wood-based hydraulic mulch (recovered wood and/or paper)
100%
Non-paper Office Products
Office recycling containers and waste receptacles (plastic)
20-100%
Office recycling containers and waste receptacles (steel)
25-100%
Plastic desktop accessories (polystyrene)
25-80%
Plastic-covered binders (plastic)
25-50%
Chipboard, paperboard, pressboard binders
80%
Plastic trash bags
10-100%
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Pollution Prevention Opportunities
1. Purchase products with recycled content and train staff
The Topeka MDC, LPC and CRF should establish preference programs and adopt
specifications for the purchase of products made with the percentages of recovered material
specified in EPA Guidelines. Changes in the procurement system will create staff training
opportunities. In addition, staff will need training on Federal affirmative procurement
requirements.
8.7 REDUCE PAPER USE
Current Conditions
Personnel interviewed by the Assessment Team in offices and warehouse settings, while
aware of the double-sided copying capabilities of some duplicating equipment, do not
consistently use those options. The copying machine in the CRF does not have duplex
capability. Staff is not aware of any efforts to encourage reduction in the quantity of paper used
and disposed. While computer printouts can be placed in collection containers for recycling, the
Assessment Team observed a significant amount of CPO in the waste containers. White and
mixed office papers and magazines are not recycled.
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.
• Establish a duplex copying policy-for all multi-page documents and provide staff training
hi the use of the double-sided function on copying equipment. As equipment is replaced,
specify easy to use, rapid, duplex capability.
• Expand and encourage the use of electronic mail in office and warehouse settings rattier
using paper memos and distribution copies.
• Limit distribution lists. If paper copies are necessary, circulate one memo or report with
a cover sheet indicating distribution.
• Identify opportunities to reuse paper and paper products. Corrugated cardboard boxes,
jiffy bags, manila envelopes and other packaging materials are reusable for their original
function; paper can be turned over and used as scratch paper or made into message pads.
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Encourage staff to proofread on screen and save information on disks rather than as paper
file copies.
8.8 MAXIMIZE DIVERSION OF RECYCLABLE PAPER
Current Conditions
Paper recycling operations target only computer printouts (CPO) and corrugated
cardboard. White office paper, mixed office paper, magazines and newsprint are not source
separated for recycling.
Pollution Prevention Opportunities
The Topeka facilities generate a quantifiable supply of consistent quality used paper.
Given the current market value of a variety of paper grades, the MDC and CRF should pursue a
long-term contract with a paper recycler or manufacturer. Such a contract should provide
containers, regular collection and a per-ton payment indexed to the paper market. The recyclers
will pay a higher price for source separated paper and paper products. In addition, prices
fluctuate considerably. Factors affecting prices include current market prices, whether the
recycler picks up the material or it is delivered, volume, etc.
Each employee should receive basic training in what lands of paper can be recycled and a
container for source separation of recyclable paper. Exhibit 8.4 provides information on some
local companies interested in discussing paper recycling opportunities.
8.9 IMPROVE SOURCE SEPARATION OF CORRUGATED CARDBOARD (OCC)
Current Conditions
Corrugated cardboard is generated primarily by shipments to the facility from MDC and
LPC suppliers of parts and equipment, office products, paper, toner and other supplies. In the
CRF, corrugated cardboard is generated by shipments from USPS facilities. See Section 8.4 for
a discussion of waste reduction opportunities associated with reusable distribution packaging.
Since November, 1994, the 40 cubic yard compactor located behind Building 303 has
been dedicated to cardboard recycling, as have approximately forty of the 1.5 cubic yard
collection containers in the warehouses (Buildings 302, 1 and 2). Some of these smaller
containers have been labeled "cardboard only". The compactor is pulled every other month by
Topeka Waste. Topeka Waste charges $305 per pull to transport the OCC to Republic Paper;
Republic Paper pays the MDC $125 for the 40 cubic yards of compacted OCC for a net cost to
the MDC of $180 per compactor load.
54
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(May 1995)
Requirements
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In all three operations MDC, LPC and CRF, source separation of corrugated cardboard
for recycling is haphazard at best. For example, in many of the 1.5 cubic yard containers within
the MDC warehouses, wastes were not segregated. Corrugated cardboard was mixed with paper,
plastic film, plastic and metal strapping, coffee cups, aluminum cans and other materials. Even
some of the designated cardboard collection containers were contaminated with other materials.
The LPC appeared to be the most efficient in diverting corrugated boxes, but they were
discarding the round end cover sheets and kraft protective sheets from the paper rolls. The CRF
was not separating cardboard for recycling in any of its operations, although at least 75 percent of
the solid waste from the CRF is corrugated cardboard.
Based on the Assessment Team's observations of the five compactors and approximately
forty 1.5 cubic yard waste collection containers in the warehouses, a conservative estimate of the
quantity of corrugated cardboard, based on best professional judgement, is that corrugated
cardboard comprises 90 percent of the material in the dedicated OCC compactor and 50-60
percent of the material discarded into the other four solid waste compactors. As discussed
earlier, MDC disposal records indicate that Topeka Waste pulls the solid waste compactors a
total of 100 times per year and charges $618 per pull for a total annual disposal cost of $61,800.
Compacted corrugated cardboard weighs between 300 and 500 pounds per cubic yard.
Thus, a full 40 cubic yard compactor contains approximately 12,000 Ibs or six tons of compacted
cardboard. The USPS pays out $ 180 per compactor load every other month for a total annual
expenditure of $1,080 compared with $3,708 for disposal of the material.
Pollution Prevention Opportunities
1. Improve separation under existing collection arrangement
Establish a corrugated cardboard source separation policy, designate containers for
cardboard only and train all employees to maintain separation of OCC for recycling. Continue
current collection arrangement with Topeka Waste and Republic Paper.
The MDC stated that there were 100 pulls of the 40 cubic yard compactors per year. The
Assessment Team observed that at least 50 percent of the solid waste in the compactors is
corrugated cardboard. If this cardboard were source separated, 50 compactor pulls would be
waste and 50 pulls would be segregated corrugated cardboard. Each solid waste pull costs $618,
so 50 pulls represents $30,900 in waste transportation and disposal costs. If these 50 container
loads were delivered to Republic Paper, instead of the landfill, the cost would be reduced to $305
per pull and the total annual cost reduced to $15,250. Thus, potential savings from avoided
disposal costs for this option are $15,650. In addition, Republic Paper pays $125 per load of
corrugated for potential annual revenues of $6,250. Total potential savings for this option are
$21,900.
56
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2. Improve separation and initiate a new contract
Establish a corrugated cardboard source separation policy, designate containers for
cardboard only and train all employees to maintain separation of OCC for recycling. Establish a
market with a local recycler willing to enter into a contract based on a fixed price plus a fixed
percentage of current market price.
Again, the current annual cost of transportation and disposal of 50 compactor loads at
$618 per pull is $30,900. Other local paper recyclers will pull source separated, loose corrugated
cardboard at no charge and'pay between $75 and $165 per ton for the value of the material. Fees
for container rental and pulls are always negotiable; USPS should leverage the quantity and
quality of the product to obtain containers and collection at no charge. Eliminating 50 pulls at
$618 per pull produces potential savings from avoided disposal of $30,900. Assuming six tons
per foil 40 cubic yard compacted pull, the Topeka facilities generate 300 tons of recyclable
corrugated cardboard per year. At the more conservative return of $75 per ton, the total revenue
would be $22,500. In response to a blind telephone call, Republic Paper stated that they would
pay $100 per ton for clean, loose corrugated cardboard. At $100 per ton, the USPS could
generate revenues of $30,000 per year. Revenues plus avoided disposal yields savings of
$53,400 to $60,900 per year. Exhibit 8.5 compares the costs of the two OCC recycling options.
EXHIBIT 8.5 CORRUGATED CARDBOARD RECYCLING
Maximize corrugated
cardboard recycling
Total additional pulls of 40
cubic yards compacted
corrugated per year
Annual weight of corrugated
Annual collection costs
Annual avoided disposal
Revenues from sale of
corrugated
TOTAL SAVINGS
Option 1:
Continue current arrangement with
Topeka Waste and Republic Paper
50
300 tons
$ 15,250 ($305/pull)
$15,650
$6,250 ($125/pull)
$21,900
Option 2:
Negotiate a contract with
another paper recycler
50
300 tons
0
$30,900
$22,500 - $30,000 ($75-
100/ton)
$53,400 - 60,900
57
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8.10 REDUCE DISPOSAL OF PLASTIC FILM
Current Conditions '
Plastic shrink and stretch wrap enters the waste stream from pallets and packages shipped
to the warehouses and CRF. When these deliveries are unwrapped for distribution to warehouse
storage or shipment to USPS facilities, the plastic film is disposed into the solid waste stream.
Pollution prevention opportunities
1. Collect the plastic stretch film for recycling
Plastic film recyclers will collect truckload quantities (approximately 20 tons) of clean.,
baled stretch wrap and pay approximately $40 per ton for the material. Both Mobil Chemical
and Smurfit Recycling provide stretch film recycling programs.
Mobil's stretch wrap recycling services are offered nationwide. The program includes
collection and purchase options for the used stretch wrap. The stretch wrap must be free of
contaminants and baled. In addition, Mobil requires truckload quantities for transportation
services to be cost effective. A truckload would consist of an average of 30,000 to 40,000
pounds of stretch wrap.
Mobil has strict content specifications for the material the company purchases. Mobil
specifications include baled stretch wrap containing at least 96 percent polyethylene stretch film
and: "
Less than 3 percent HDPE, LDPE bags and shrink film
No PVC or PVDC (Saran) films
• No moisture - dry bales only
• No trash, loose paper or corrugated inside bales
• No corrugated or poly slip sheets as headers/end caps on bales
No strapping, twine or tape
• No wood or broken pallet pieces
• No polystyrene or polyurethane foam
• No oil or grease
• No hazardous material, medical wastes, nor containers used to package these
products.
Bale specifications include:
Dimensions of 24"x36"x42" minimum to 36"x48"x72" maximum
Weight of 750 pounds minimum to 1,200 pounds maximum
• Bale integrity must be maintained through shipping, unloading and storage.
58
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Mobil picks up the material and pays 2 cents per pound for the stretch wrap.
The material is processed at Mobil's facility located in Jacksonville, IL. The recycled resin is
then used by various divisions within the company to manufacture products, such as: new
handwrap and institutional can liners; Hefty trash bags; Trex, a wood-polymer composite; and
trash cans. For further information, contact: Mobil Chemical Company, Commercial Recycling
Group-Reston I at (703) 742-6546
Smurfit Recycling has a plant hi Kansas City, KS and purchases clean, baled stretch wrap
hi truckload quantities. Smurfit pays approximately $20 to $40 per ton for truckload quantities.
Smurfit requires that the stretch wrap be free of contaminants, including paper.
The recycling industry requires high quality and large quantities of stretch wrap for
material collection and processing to be cost effective. The Postal Service may have difficulty in
accumulating truckload quantities of stretch wrap. As an alternative to the truckload quantity
requirement, the Postal Service could implement a comprehensive materials recovery program to
include stretch wrap, office paper, polystyrene, aluminum cans and corrugated cardboard.
Smurfit could collect a truckload of all of the materials, rather than requiring truckloads of
individual materials. For further information, contact:
Smurfit Recycling at (618) 463-6389.
The Topeka operations would have to purchase a baler and store the bales of stretch wrap
until a truckload quantity was accumulated. Approximate revenues from a truckload of clean,
baled stretch wrap would be $800. Stretch wrap represents approximately 10 percent of the
waste stream or 192 compacted cubic, yds. per year. At an estimated weight of 225 pounds per
compacted cubic yard, the Topeka operations generate slightly more than 40,000 pounds or about
one truckload of plastic film per year. Exhibit 8.6 provides a summary of the economics of
plastic film recycling.
EXHIBIT 8.6 PLASTIC FILM RECYCLING
Activity
Baling equipment purchase
Annual operating and maintenance
costs (includes labor)
Avoided disposal
Sale of plastic film
TOTAL
Costs
$8,500
$5,000
$13,500
Revenues
$2,900
800
$3,700
While Exhibit 8.6 suggests that purchase of a baler for plastic film recycling is not cost
effective, it should be noted that the same baler could be used to bale corrugated cardboard.
59
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Baling could potentially increase the revenues from the sale of the cardboard since all recyclers
pay a premium for baled corrugated.
Since other regional USPS facilities, including Bulk Mail Centers and Processing &
Distribution Centers, also generate substantial quantities of plastic stretch film, the USPS could
consider a consolidated operation. USPS could purchase one baler, locate it at a facility that has
storage space, and consolidate plastic film recycling for a variety of regional facilities. The film
could be transported in clearly labeled collection boxes as part of the regional transportation
system.
8.11 IMPROVE DIVERSION OF METALS
Current Conditions
Some metals are diverted for recycling in the LPC and CRF. However, there is no clearly
stated policy and directive concerning metals recycling. Employees are inconsistent in their
metals recycling behaviors. In Building 1, for example, some metal strapping is collected for
reuse. In the other warehouses, however, the Assessment Team observed large quantities of
metal strapping in the waste collection containers.
Pollution Prevention Opportunities
1. Improve source separation
Establish a policy concerning which metals will be diverted for recycling. Provide
training for employees and locate clearly labeled containers for source separation of recyclable
metals. Exhibit 8.7 provides a list of local companies interested in working with USPS to
establish a broader metals recycling program. Recyclers will pay more for source separated
materials; however, prices vary considerably and are dependent on the commodities market.
EXHIBITS.? METALS RECYCLERS
Recycler
A&D Scrap Metal Recycling
Topeka, KS
(913) 232-1666
Bailey's Recycling Company
Topeka, KS
(913)232-5152
Material Accepted
All metals
All metals
Requirements
Separate by metal
Separate by metal
Material Price
(May 1995)
Iron and tin: $40/ton
Aluminum: $.46/lb
Iron: $40-$44/ton;
Aluminum, up to 50 Ibs:
$.50/lb; Aluminum, more than
50 Ibs: $.52/lb
60
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Becker Brothers, Inc.
Kansas City, MO
(816)471-3244
Till-Star Enterprises
Topeka, KS
(913)354-7710
All metals, including
aluminum cans.
All metals
Separate by metal
Separate by metal
Prices vary with commodity
prices and are dependent on
quality
Iron: $20/ton
Aluminum: $.45-$.50/lb
8.12 FLUORESCENT LIGHTING TUBES
Current Conditions
The offices, warehouses and work areas are lighted with hundreds of fluorescent tubes
arranged in pairs spaced approximately four feet apart. Expired lamps are stored in unprotected
piles in several warehouse locations, including the LPC. In one location, the Assessment Team
found a partially filled bulb crusher ~ a 55 gallon drum, sealed to prevent exposure to mercury,
with a mechanism to crush the expired fluorescent tubes. The maintenance staff stated that they
had not yet identified an environmentally sound disposal option for the fluorescent tubes.
USPS Memorandum for Managers, Operations Support, dated December 16, 1994, states
that "Under no circumstances should these lamps be mechanically crushed or ground into smaller
pieces. This method of disposal increases the exposure of hazardous materials to both employees
and the environment. Lamps should be boxed prior to disposal."
Fluorescent lights are one of the most energy efficient lighting sources available.
However, fluorescent lighting tubes contain mercury, which is used as an element to conduct the
flow of the electric current. Historically, fluorescent lighting tubes were discarded into landfills.
When the tubes broke, mercury was released to the environment. This potential hazard caused
many states to classify fluorescent lighting tubes as hazardous waste and require that they be
managed in accordance with applicable hazardous waste laws and regulations.
Recycling spent fluorescent lighting tubes offers an environmentally sound alternative to
expensive hazardous waste disposal. Additionally, recycling may relieve the generator of future
liability concerns associated with tube disposal. Several companies provide recycling services
for spent fluorescent lighting tubes and some of these companies also accept ballasts, a
component of the light fixture. Ballasts manufactured prior to 1980 contain polychlorinated
biphenyls (PCBs), which also present disposal problems. However, ballasts produced after 1980
do not contain PCBs. According to Ron Newman of A-TEC Recycling, the useful life of ballasts
is approximately 15 years. Since ballasts manufactured after 1980 do not contain PCBs, ballasts
containing PCBs should not present significant disposal problems beyond the near term.
Some states allow ballasts that do not contain PCBs to be disposed of in sanitary landfills.
However, according to Stephanie Small of DYNEX Environmental, Inc., non-PCB ballasts
61
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contain diethylhexylphthalate (DEHP). Evidence indicates that DEHP is a human carcinogen.
Due to either the PCBs or DEHP content, Ms. Small recommends that customers manage all
ballasts as hazardous.
Pollution Prevention Opportunities
1. Establish a recycling program
Store expired bulbs in boxes in a safe area. USPS facilities should ship expired bulbs to
an approved facility for recycling of glass, metals, and mercury. Expired ballasts should be
shipped to an approved facility for appropriate disposal of hazardous constituents.
Exhibit 8.8 provides information on the specific services offered by companies that
provide fluorescent tube recycling services, the cost of the services and the geographic area
serviced by each company. See the appendices for further information on fluorescent tube and
ballast management.
62
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8.13 HALON FIRE SUPPRESSANT SYSTEMS
Current Conditions
The MDC computer room is protected by 14 one quart glass bulbs of Halon in the ceiling.
In addition, there are 21 nine pound portable halon extinguishers in the warehouses. The CRF
utilizes a 360 pound Halon 1301 system hi Building 8. Halon fire suppression systems at the
MDC and CRF provide a high level of fire protection, with minimal secondary damage and
minimal disruption to resumption of operations in the event of a fire. The level of protection
provided by these systems is more than adequate to protect the assets at risk.
Although halon has excellent fire extinguishing properties, halons deplete stratospheric
ozone, a substance critical in 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 hi 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.
The halon systems are hi place hi computer rooms and storage areas for computer
equipment. The computer equipment protected by the halon systems is used in supply functions
for the USPS. The Postal Service must address both short- and long-term issues associated with
providing adequate fire protection for these functions. 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. Long term supplies of
halons are uncertain. Although significant expenditures may be required, the USPS should
prepare for potential future shortages by identifying its long term fire protection needs at the
MDC and CRF and implementing 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 systems in place and, after installing the new systems, properly transfer any remaining
halon 1301 to the Defense Logistics Agency for banking.
Pollution Prevention Opportunities
1. Cease Discharge Testing
Until the USPS identifies a suitable replacement for the halon 1301 systems hi place hi
the building, the MDC and CRF 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.
65
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2. Perform Regular Preventive Maintenance
Another significant loss of halon in fixed systems is through leaks hi valves and
discharge lines. The MDC and CRF should conduct regular preventive maintenance to insure
that all halon systems in place are intact and free of leaks.
3. Implement Fire Protection Measures
In developing an alternative to halon 1301 fire suppression systems, USPS 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 MDC 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. By taking these
considerations into effect, USPS 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 in Exhibit 8.9.
EXHIBIT 8.9 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
Availability of manual fire suppression equipment
Fire department response time
According to a report 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 computer equipment and storage rooms, as well as fires that
start in the rooms themselves.
66
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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
in 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 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 Defense Logistics Agency (DLA) in
accordance with appropriate DLA procedures. The following alternatives would provide
adequate fire protection in the MDC and CRF.
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.
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.
67
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8.14 LIGHTING AND ENERGY
Current Conditions
Based on information provided by the MDC staff, the USPS facility in Topeka pays more
than $348,000 for electricity per year. This expense breaks down as follows: Buildings 1,2, and
3 - $35,495; Building 8 - $62,660; and Building 303 - $250,662.
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
Executive Order 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 8.10.
EXHIBIT 8.10 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
Pollution Prevention Opportunities
1. Install energy efficient lighting
In 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
68
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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."
2. Become a Federal Partner in the Green Lights Program
Green Lights provides free technical assistance to participants through written materials,
information hotlines, and thorough survey and analysis software products that allow Green
Lights participants to analyze their options for installing energy-efficient lighting. The system
helps participants survey the lighting systems hi their facilities, assess then- retrofit options, select
the option that maximizes energy and pollution savings while simultaneously rating or improving
lighting quality and meeting the Green Lights profitability criteria, and produces reports suitable
for use by facility managers, financial staff, and senior management. See the appendices for
further information on the Federal Energy Management Program and Green Lights.
3. Establish a "Lights Out" policy
Establish a policy of turning off lights and equipment when leaving an area. Where
machine design permits, turn photocopiers to low power when not in use. Installation of motion
sensors that automatically turn off the lights is another alternative. Each kilowatt hour saved
prevents the formation of air pollutants, including 0.68 kg of carbon dioxide, 5.8 g of sulfur
dioxide and 2.5 g of nitrogen oxides.
4. Procure computers that meet Energy Star requirements
Future computer equipment purchases should specify equipment that is energy efficient.
Executive Order 12845 requires Federal agencies to purchase computer equipment that meets
EPA Energy Star requirements for energy efficiency. The EPA Energy Star Program is a
69
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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 in use. The Federal Supply Service offers a product called the Intelligent
Energy Saver, a PC add-on device that controls electrical power to the PC and its peripherals.
The complete PC system can be powered on and off at user-defined dates and tunes. See the
appendices for futher information on Energy Star.
8.15 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$e. This internet-based information source is funded by the
Environmental Protection Agency and the Strategic Environmental Research and Development
Program. Enviro$en$e allows those implementing pollution prevention programs or developing
research and development projects" to benefit from the experience, progress, and knowledge of
their peers. Enviro$en$e includes a pollution prevention forum for all levels of government,
researchers, industry, and public interest groups.- Enviro$en$e has been developed to host an
expert architecture known as the Solvent Umbrella. The Solvent Umbrella will allow users to
access solvent alternative information through a single, easy-to-use command structure.
Enviro$en$e is also modem accessible via Bulletin Board System (BBS). Through Netscape,
Enviro$en$e address is:
http://wastenot.mel.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 the EPA and related organizations.. In
addition to this document the EPA's Public Information Center is available to provide assistance
in accessing environmental information. An experimental EPA People Locator is also available.
Through Netscape, EPA's WWW server can be accessed through http://www.epa.gov.
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The EPA WWW server provides information on EPA Agency information and
environmental data, including:
• Press Releases, Calendar, Announcements, Speeches,
• EPA Offices and Regions,
• Consumer Information,
• EPA Initiatives, Policy and Strategy Documents,
• Rules, Regulations and Legislation,
EPA Standards,
• Science, Research and Technology,
• Information about Grants, Contracts (RFPs), and Job Vacancies,
• Newsletters and Journals, and
• Software and Databases,
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/ index_txt.html.
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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 Materials
Distribution Center, Label Printing Center and Central Repair Facility in Topeka, KS. During
the assessment process* the Assessment Team identified opportunities to reduce both the quantity
and toxicity of the wastes generated by this facility and recommended techniques for
implementation of those pollution prevention options. The opportunities described in the
previous sections constitute the recommendations of the Assessment Team. Exhibits 2.1,5.1,7.1
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 materials distribution, printing and computer repair facilities nationwide
as well as other Federal facilities with similar operations.
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APPENDICES
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EPA 33/50 PROGRAM
The 33/50 Program, one of EPA's Partners for the Environment Program, began in the late 1980s
as a voluntary program to reduce toxic emissions of seventeen high priority chemicals reported
on the Toxic Release Inventory (TRI). These high priority chemicals, chosen because of their
relative toxicities, volumes of use, and potential for reduction through pollution prevention
include:
•> Benzene > 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 in September 1996 when the 1994 Toxic Release
Inventory data became available for public release. Between 1988 and 1994,33/50 Program
participants reduced environmental releases and off-site transfers of the 17 target chemicals by
757 million pounds. Companies and organizations participate in the 33/50 Program by
submitting a letter to EPA stating then- intention to participate and outlining their reduction
targets and strategies. More than 1,300 parent companies operating about 6,000 facilities in the
U.S. have participated hi the 33/50 Program.
For more information about the participation in the EPA 33/50 Program, contact EPA's TSCA
Assistance Hotline at (202) 554-1404. Or contact the 33/50 Program staff directly at:
33/50 Program (Mail Code 7408)
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
401 M Street
Washington DC 20460
Phone:202-260-7538
POC: Ms. Chris Tirpak
Email: tirpak.chris@epamail.epa.gov
Information on the 33/50 Program is also available on-line through the Enviro$en$e web site:
http://es.inel.gov/partners/3350/3350.html
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OZONE DEPLETING SUBSTANCES
The ozone layer in the stratosphere protects life on earth from exposure to dangerous levels of
ultraviolet light. When CFCs and other ozone-degrading chemicals are released into the
atmosphere, they will eventually rise to the stratosphere where they destroy the protective ozone
layer. This destruction is occurring at a more rapid rate than ozone can be created through
natural processes. Destruction of the ozone layer leads to higher levels of ultraviolet radiation
reaching Earth's surface. This can lead to higher incidences of skin cancer, cataracts, and
weakened immune systems. It is also expected to reduce both crop yields and ocean
productivity.
The U.S., in cooperation with over 140 other countries, is phasing out the production of
ozone-depleting substances. In 1985, the Vienna Convention was adopted to formalize
international cooperation in stratospheric ozone protection. Additional efforts resulted in the
signing of the Montreal Protocol hi 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 hi 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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The best source of technical, policy, and substitute chemical information can be obtained through
the U.S. EPA's Stratospheric Ozone World Wide Web Home Page:
http://www.epa.gov/ozone/index.html. This web site contains information on the science of
ozone depletion, substitutes for ozone depleting substances, international policy, and links to
other sources of information. It can be used as a "jumping off' point for a wide variety of
information related to ozone depletion available on the World Wide Web.
The mailing address for the Office of Stratospheric Protection is:
Office of Stratospheric Protection
U.S. Environmental Protection Agency
Mail Code 6205J
401MSt.,SW
Washington, DC 20460
Enviro$en$e also has access to several material substitution databases. 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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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 hi energy consumption in its Federal
buildings by FY 1995, when measured against a FY 1985 baseline on a Btu per gross-square-foot
basis and a 20 percent reduction in Btu per gross-square-foot by FY 2000. In 1994, the
President signed Executive Order 12902, Energy Efficiency and Water Conservation at Federal
Facilities, which requires Federal agencies to reduce energy consumption by 30 percent by the
year 2005, based on the agency's 1985 energy use.
In response to these mandated requirements, the U.S. Department of Energy's Federal Energy
Management Program was established to assist Federal agencies to reduce energy costs by
advancing energy efficiency, water conservation, and the use of solar and other renewable
energy. FEMP accomplishes its mission by creating partnerships, leveraging resources,
transferring technology, and providing training and support. For information on the Federal
Energy Management Program contact the FEMP Help Desk at (800) DOE-EREC or the FEMP
Office at (202) 586-5772.
The Department of Energy's Federal Energy Management Program has teamed up with the
EPA's Green Lights Program to assist Federal agencies to achieve the mandated energy
reductions. A kick-off is planned in 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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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/greenlights.htrnl. 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) 268-6014 for
specific information on U.S. Postal Service involvement in FEMP and Green Lights Programs.
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EPA ENERGY STAR® PROGRAM
The ENERGY STAR® Program is a voluntary pollution prevention program aimed at reducing
energy consumption to help to combat smog, acid rain, and climate change through decreased
emissions from electricity generation. It includes programs aimed at homes, residential HVAC,
office products, buildings, and lighting. Programs of interest to the U.S. Postal Service include:
> Office Products. The EPA ENERGY STAR® Office Equipment program is a partnership
with the office equipment industry to promote energy-efficient personal computers, monitors,
printers, fax machines, and copiers. In 1993, an Executive Order 12845 was issued requiring
all U.S. Federal agencies to purchase ENERGY STAR® computers, monitors and printers.
> Buildings. EPA's ENERGY STAR® Buildings program is a voluntary energy-efficiency
program for U.S. commercial buildings. Partners can expect to reduce total building energy
consumption by 30% on average.
For more information about the ENERGY STAR® Program, contact:
ENERGY STAR® Programs
U.S. EPA Atmospheric Pollution Prevention Division
401 M Street SW (6202J)
Washington DC 20460
POC: Ms. Jeanne Birskin, Chief, ENERGY STAR® Programs
Tel: (202) 233-9190
Toll Free: (888) STAR-YES
Fax: (202) 233-9569
Fax-back system: (202) 233-9659.
The ENERGY STAR® World Wide Web Home Page is at:
ENERGY STAR® Home Page
http://www.epa.gov/energystar.html
This web page contains news and information on all of the ENERGY STAR® initiatives.
The Atmospheric Pollution Prevention Division also prepares a newsletter, The Update, which
communicates events, highlights, and news affecting Green Lights and ENERGY STAR®
program participants. It is available on-line through the ENERGY STAR® Home Page.
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FLUORESCENT TUBE AND BALLAST RECYCLING
Fluorescent tubes and lighting ballasts contain hazardous constituents that can make their
handling and disposal problematic. Fluorescent tubes contain mercury which may be subject to
hazardous waste regulations if deemed hazardous by the Toxicity Characteristic Leaching
Procedure (TCLP) (40 CFR 261). Individual states may have other specific regulatory
requirements governing the disposal of fluorescent tubes. However, in most cases, fluorescent
tubes can be legally handled and disposed as municipal solid waste, creating a potential liability
to the waste generator.
Fluorescent lamp ballasts manufactured before 1979 will contain polychlorinated biphenyls
(PCBs), while those manufactured after 1979 should contain a label stating "NO PCBs." If there
is no label, you should assume that the ballast contains PCBs. PCB-containing ballasts that are
intact and are not leaking can be disposed in a municipal solid waste landfill in properly packed
and sealed 55-gallon drums (40 CFR 761). Again, municipal disposal of PCB-contaminated
waste poses potential liabilities to the generator.
To minimize environmental impacts, fluorescent tubes can be recycled. The mercury containing
material is extracted and the glass and metal parts recovered for reuse or recycling. Before
disposing of fluorescent tubes or lighting ballasts, you should contact your state or local
regulatory agency for specific handling and disposal requirements. They may also have
information on fluorescent tube recycling in your state or area. Consult your local telephone
directory for phone numbers.
For information on Federal requirements, contact the following:
Resource Conservation Recovery Act (RCRA/Superfund/Right-to-Know Hotline
Phone: (800) 424-9346 or (703) 412-9810 in the Washington DC area.
Request documents such as EPA Fact Sheet: Options for Disposal of Lights that Contain
Mercury and Lighting Waste Disposal, a general document published by the EPA's Green Lights
Program on best management practices that includes recycling. Memoranda also are available
through the fax-on-demand system. Dial (202) 651-2060 from the fax phone receiver, press 1 to
order documents, press 11906 and 11907 (press 1 to confirm ordering each document), press # to
finish ordering, then press start on your fax machine.
Toxic Substances Control Act (TSCA) Assistance Information Hotline
Phone: (202) 554-1404 Request regulatory guidance on the management and disposal of
ballasts that contain PCBs.
Several fact sheets are available over the World Wide Web that contain background information
as well as lists of fluorescent tube and lighting ballast recyclers:
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U.S. Air Force Center for Environmental Excellence, PRO-ACT
http://www.afcee.brooks.af.mil/pro-act/main/proact4.htm
Select "Fact Sheets" from Home Page menu. Information in the PRO-ACT web site is public
domain. However, telephone inquiries and requests for research or information are only
available to Air Force users.
Enviro$en$e
http://es.mel.gov/techinfo/facts/lamps-fs.html
Fact sheet on disposal of spent fluorescent light tubes, developed by the Department of Public
Works, City of Los Angeles. Contains a list of additional resources.
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HAZARDOUS MATERIAL STORAGE STRUCTURES
Hazardous materials must be stored safely to prevent environmental releases through spills,
adverse health impacts, fire or explosion hazards, or adverse chemical reactions with
incompatible materials. Hazardous material storage is regulated at the Federal level by OSHA
(29 CFR 1910). OSHA regulations can be accessed on-line through the OSHA Home Page
(http://www.osha.gov); select Standards from the Home Page, OSHA Regulations (29 CFR),
then Part 1910. Hard copies of the regulations are available through the Govenment Printing
Office Order Desk, (202) 512-1800.
Hazardous materials also may be regulated on the state level as well as by local agencies
(county/city fire departments) who may require flammable/combustible materials to meet certain
storage requirements. Usually, these local ordinances will follow the National Fire Protection
Association (NFPA), Fire Protection Guide on Hazardous Materials (Pamphlets 325A, 325M, 49,
491F and 704M). Contact your local fire department or the NFPA, (800) 344-3555, for specific
requirements and copies of pamphlets.
Before purchasing or building a hazardous material storage structure, you need to understand the
quantities and types of hazardous materials that you will need to store. You need to obtain the
MSDS to understand fiammability and incompatibility issues so you can select the appropriate
storage structures. Decide how much material you must have on-hand in storage at any given
time and select the appropriate size storage structure. Keep in mind, if you implement a
hazardous material tracking program, you may need less storage area than past practices indicate.
An important issue in selecting a hazardous material storage structure is whether materials need
to be segregated due to their chemical compatibilities. Hazardous materials must not be
commingled with other materials which could produce heat or pressure, fire or explosion, violent
reaction, toxic dusts, mist, fumes or gases, or flammable fumes or gases. Incompatible materials
that cause heat generation or violent reaction include mixing an base with an acid. For example,
an alkaline cleaner or caustic liquid mixed with battery acid or other corrosive acids would cause
a violent reaction. Information on incompatibilities should be i.dentified on the MSDS. If there
are any questions regarding material compatibilities, contact your local environmental, industrial
hygiene, safety or fire department representative.
Hazardous material storage structures are available in a variety of sizes that meet varying
requirements at costs ranging from several hundred dollars to tens of thousands of dollars. Some
structures, such as flammable storage cabinets, may be stored indoors or outdoors. Other
structures are the size of small buildings, and have several compartments for separating
incompatible materials, and are generally stored outdoors. For vendor information on a range of
hazardous material storage structures, contact your local procurement office. Additional
information can be obtained from guides such as the Thomas Register of American
Manufacturers (available through the local library) and through environmental and fire protection
trade magazines (check your local environmental, safety, or fire protection office).
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SUPPLIERS OF VEGETABLE OIL INKS
Vegetable oil inks offer several advantages over petroleum oil-based inks. Vegetable oil inks are
made from renewable agricultural resources and decrease use of non-renewable energy sources.
They have fewer volatile components, also known as volatile organic compounds or VOCs, that
produce air pollution. Overall, vegetable oil-based inks have fewer impacts to the environment.
The Vegetable Ink Printing Act of 1994 was enacted to increase the use of vegetable oil-based
inks used for printing Federal government documents. It states that Federal agencies may not
procure lithographic printing ink, if it contains less than the following percentages of vegetable
oil:
>• In the case of news ink, 40 percent.
*• In the case of sheet-fed ink, 20 percent.
> In the case of forms ink, 20 percent.
> In the case of heat-set ink, 10 percent.
The National Association of Printers and Lithographers has some general information on the use
of vegetable-based inks for their Association Members. Contact Customer Service at (201) 343-
0700 for more information.
The National Association of Printing Ink Manufactures (NAPIM) can provide a list of several
vegetable oil-based ink manufactures hi a given region. Contact Richard Incontro, NAPIM, 777
Terrace Ave., Hasbrouck Heights, NJ 07604, Phone (201) 288-9453, URL:
http://www.napun.com/ and specify your metropolitan or regional area.
The National Soy Ink Information Center has a strong identity as the information clearinghouse
and resource for soy ink manufacturers and users. The center was established in 1993 by the
Iowa Soybean Association (ISA). The center is fully funded by U.S. soybean producers. The
center manages the SoySeal program, fulfilling requests for SoySeal user agreements and
monitoring use of the SoySeal trademark. It also maintains relationships with soy ink
manufacturers, printers and buyers; advises on research needed for product development;
responds to trade media inquiries; leads soy ink and environmental seminars; and responds to
telephone inquiries. Contact Jo Patterson or Wilson Cunningham at the National Soy Ink
Information Center, 1025 Ashworth Road, No. 310, West Des Moines, IA 50265-3542, Phone:
(800) 747-4275, Fax: (515) 223-4331, E-mail: soyink@soyink.com, URL:
http://www.soyink.com/.
The two leading trade magazines in the ink industry, American Ink Maker Magazine and Ink
World, publish buyers guides that list vegetable-oil and other low-VOC inks. These trade
magazines should be available through your local printing organization.
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General information on pollution prevention in the printing industry is available through
Enviro$en$e (http://es.inel.gov). Select Enviro$en$b Industry Content Guides from the Home
Page, then select Commercial Printing and Graphic Arts. Links to many documents, including
those that address switching to vegetable or water-based inks can be found in the Frequently
Asked Questions (FAQs). Additional links to case studies, fact sheets, and technical information
are available through Core Documents.
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POLLUTION PREVENTION INFORMATION SOURCES
Pollution prevention information sources are widespread. There are Federal-, state-, regional,
and even local sources of pollution prevention information. At the Federal level, the U.S. EPA
Office of Pollution Prevention and Toxics (OPPT) distributes a variety of pollution prevention
information and oversees several pollution prevention initiatives. They publish the Pollution
Prevention News, available in hard copy or through the U.S. EPA Pollution Prevention Home
Page (see below for URL). OPPT also operates the Pollution Prevention Information
Clearinghouse (PPIC). It is a free, non-regulatory service which provides telephone reference
and referral, document distribution for selected EPA documents, and a special collection
available for interlibrary loan. Publications available from PPIC are listed on the U.S. EPA
Pollution Prevention Home Page (see below for URL).
Pollution Prevention Information Clearinghouse (PPIC)
Phone: 202-260-1023 (8:30 AM to 4:00 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 tune, 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$e
http://es.inel.gov/
Enviro$en$e is a "one-stop" repository for pollution prevention, compliance assurance, and
enforcement information and data bases. Included are pollution prevention case studies,
technologies, points of contact, environmental statutes, executive orders, regulations, and
compliance and enforcement policies and guidelines. Enviro$en$e has numerous links to other
Federal, regional, state, Industry and academic pollution prevention resources. Enviro$en$e is an
excellent "jumping off' point for additional pollution prevention information available on-line.
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