United States
Environmental Protection
Agency
Risk Reduction
Engineering Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/S-92/026 Oct. 1992
&EPA ENVIRONMENTAL
RESEARCH BRIEF
Waste Reduction Activities and Options for a State Department of
Transportation Maintenance Facility
Patrick Eyraud and Daniel J. Watts*
Abstract
The U.S. Environmental Protection Agency (EPA) funded a
project with the New Jersey Department of Environmental
Protection and Energy (NJDEPE) to assist in conducting waste
minimization assessments at 30 small- to medium-sized busi-
nesses in New Jersey. One of the sites selected was a State
Department of Transportation (DOT) maintenance facility. The
assessment process was coordinated by a team of technical
staff from the New Jersey Institute of Technology (NJIT) with
experience in process operations, basic chemical experience,
and knowledge of environmental concerns and needs. A site
visit was made in 1990 during which several opportunities for
waste minimization were identified. These opportunities include
antifreeze reconditioning and reuse, capture and reuse of chlo-
rofluorocarbons (CFC's) from vehicle air conditioning systems,
and modified spray-painting techniques. Implementation of the
identified waste minimization opportunities was not part of the
program. Percent waste reduction, net annual savings, imple-
mentation costs, and payback periods were estimated.
This Research Brief was developed by the Principal Investiga-
tors and EPA's Risk Reduction Engineering Laboratory in Cin-
cinnati, OH, to announce key findings of this completed as-
sessment.
Introduction
The environmental issues facing industry today have expanded
considerably beyond traditional concerns. Wastewater, air emis-
sions, potential soil and groundwater contamination, solid waste
disposal, and employee health and safety have become increas-
singly important concerns. The management and disposal of
hazardous substances, including both process-related wastes
and residues from waste treatment, receive significant atten-
tion because of regulation and economics.
As environmental issues have become more complex, the
strategies for waste management and control have become
more systematic and integrated. The positive role of waste
minimization and pollution prevention within industrial opera-
tions at each stage of product life is recognized throughout the
world. An ideal goal is to manufacture products while generat-
ing the least amount of waste possible.
The Hazardous Waste Advisement Program (HWAP) of the
Division of Hazardous Waste Management, NJDEPE, is pursu-
ing the goals of waste minimization awareness and program
implementation in the state. HWAP, with the help of an EPA
grant from the Risk Reduction Engineering Laboratory, con-
ducted an Assessment of Reduction and Recycling Opportuni-
ties for Hazardous Waste (ARROW) project. ARROW was
designed to assess waste minimization potential across a
broad range of New Jersey industries. The project targeted 30
sites to perform waste minimization assessments following the
approach outlined in EPA's Waste Minimization Opportunity
Assessment Manual (EPA/625/7-88/003). Under contract to
NJDEPE, the Hazardous Substance Management Research
Center at NJIT assisted in conducting the assessments. This
research brief presents an assessment of a State Department
of Transportation maintenance facility (1 of the 30 assess-
ments performed) and provides recommendations for waste
minimization options resulting from the assessment.
*New Jersey Institute of Technology, Newark, NJ 07102.
Printed on Recycled Paper
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Methodology of Assessments
The assessment process was coordinated by a team of techni-
cal staff from NJIT with experience in process operations,
basic chemistry, and environmental concerns and needs. Be-
cause the EPA waste minimization manual is designed to be
primarily applied by the in-house staff of the facility, the degree
of involvement of the NJIT team varied according to the ease
with which the facility staff could apply the manual. In some
cases, NJITs role was to provide advice. In others, NJIT
conducted essentially the entire evaluation.
The goal of the project was to encourage participation in the
assessment process by management and staff at the facility.
To do this, the participants were encouraged to proceed through
the organizational steps outlined in the manual. These steps
can be summarized as follows:
• Obtaining corporate commitment to a waste minimization
initiative
• Organizing a task force or similar group to carry out the
assessment
• Developing a policy statement regarding waste minimiza-
tion for issuance by corporate management
• Establishing tentative waste reduction goals to be achieved
by the program
• Identifying waste-generating sites and processes
• Conducting a detailed site inspection
• Developing a list of options which may lead to the waste
reduction goal
• Formally analyzing the feasibility of the various options
• Measuring the effectiveness of the options and continuing
the assessment.
Not every facility was able to follow these steps as presented.
In each case, however, the identification of waste-generating
sites and processes-, detailed site inspections, and develop-
ment of options were carried out. Frequently, it was necessary
for a high degree of involvement by NJIT to accomplish these
steps. Two common reasons for needing outside participation
were a shortage of technical staff within the company and a
need to develop an agenda for technical action before corporate
commitment and policy statements could be obtained.
It was not a goal of the ARROW project to participate in the
feasibility analysis or implementation steps. However, NJIT
offered to provide advice for feasibility analysis if requested.
In each case, the NJIT team made several site visits to the
facility. Initially, visits were made to explain the EPA manual
and to encourage the facility through the organizational stages.
If delays and complications developed, the team offered assis-
tance in the technical review, inspections, and option develop-
ment.
Transportation Maintenance
The major activity at the facility is the maintenance of vehicles
used by the Department, including automobiles and trucks, and
to a more limited extent, large machinery used by the Depart-
ment such as mowers. Other activities that are carried out at
the facility include wood shop, metal shop, and collection and
reuse or disposal of no longer useful materials. Because of the
diversity of the activities at the facility, it is difficult to develop a
unified schematic plan of material flow and waste generation.
Therefore, each operating area was examined individually for
the purpose of identifying waste reduction opportunities.
The management of the facility has already taken solid con-
structive action to strengthen waste management practices
and to institute waste reduction policies. For example, used oil
and tires are forwarded to a vendor for recycling. There is a
strong effort to identify and begin to use materials with reduced
levels of toxicrty in the facility's operations. Moreover, it is clear
from discussions with the management and personnel at the
facility that there is a commitment to the concept of pollution
prevention and to putting it to work in their operations.
Waste Reduction Opportunities
OH
From 12 maintenance facilities in the DOT system, approxi-
mately 14,000 gal of used oil are produced each year. More
than half of that amount is generated- at three facilities. The
study facility during fiscal year 1989 generated approximately
2700 gal of used oil. As indicated previously, the facility prac-
tices recycling as the preferred management technique for
waste oil.
The oil handling procedure at present is to collect used oil in
small drums near work stations and to periodically, or as
needed, transfer the contents to a larger storage tank. When
that larger tank is filled a contracted recycler removes the
contents and takes it offsite.
While this handling approach is reasonably routine and in
keeping with industry practices, three challenging concerns
were identified which, if addressed, have potential for improv-
ing the overall effectiveness of this waste reduction initiative.
The recycler occasionally observes that the storage tank con-
tains oil/water mixtures. The presence of such mixtures will, in
the best case, reduce the value of the used oil or, in the worst
case, cause the recycler to reject the entire contents. Such
rejection results in a substantial quantity of waste that would
have to be treated as a hazardous waste. It is important,
therefore, to determine the source of the water and to modify
procedures to reduce the chances of introducing water into the
oil.
The cause of the water entering the oil has not been investi-
gated, therefore, it is not known precisely what happens at this
facility. There are three possible sources of water that could
lead to this situation. Water may be mixing with the oil while it
is in the vehicle. This would probably be a rare situation. When
encountered, it is recommended that the drained oil be main-
tained separately from the bulk of the oil awaiting pickup for
recycling. Such separation would minimize the volume of the
mixture, protecting the value of the larger quantity of used oil
and minimizing the quantity of material that may need special
handling. Alternatively, water may be entering the oil during the
time it is kept in the smaller receiving containers near the work
stations. This would imply that water is being added to the
containers. If the addition is being done by employees for the
sake of convenience, it is recommended that a two-fold initia-
tive be undertaken to inform the technical staff of the importance
of keeping water from the oil and to assure that there are
convenient and appropriate alternative disposal routes for
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aqueous wastes. There is also a possibility that water enters
the collection containers as a result of precipitation leaking in
while the containers are exposed to the elements while await-
ing transfer to the large collection tank. In this event, it would
be important to assure that appropriate covers are available for
each of the small collection containers and that the covers are
used effectively and regularly.
The third possibility is that the large collection tank itself is
used in such a way that water can occasionally enter. Possibili-
ties that could be checked include accidental addition of waste
streams other than used oil, precipitation entering the tank
because of leaking covers or seals, and other leaks in the body
of the tank itself. Because the appearance of the oil/water
mixture is sporadic, it seems most likely that the cause is one
of occasional leaks from an improperly closed cover or an
accidental addition by a staff member.
The second concern deals with the relationship between the
generator and the contractor who has the responsibility to pick
up the collected waste oil and to take it offsite for processing.
To assure the smooth and effective operation of the recycling
process, it is important that the large collection tank be emptied
before it is completely full. This not only demonstrates to the
staff of the facility that the recycling process is working but
continues to provide capacity for the used oil generated from
ongoing vehicle maintenance activities. When the large tank is
not emptied regularly, an unintentional, but strong, message is
sent to the staff that the management of the facility does not
consider oil recycling to be a particularly important activity and
interest and compliance on the part of the staff will fall off.
Because of difficulties within the purchasing process in bidding
and contracting for the services of an oil recycling vendor, and
not because of disinterest by management, the large tank is
not always regularly emptied. It is recommended that this
process be reexamined from the perspective of making it more
responsive to the time needs of the capacity of the tank and to
the incentives for encouraging responsible waste reduction
actions on the part of the staff.
The third area of concern is that of oil spills. Certainly, any
spilled oil which cannot be recovered in an appropriate physi-
cal condition cannot be recycled. Currently oil spills are managed
with an adsorbent material such as "Speedy-dry*," which is
sprinkled over the spill, swept up, and treated appropriately.
There are three major sources for such spills: 1) inability to
collect all of the used oil draining from a vehicle being serviced,
2) oil dripping from engine parts, and 3) leaks and spills
occurring during oil transfer. The source of most of the spills
could not be identified within the limited timeframe of conduct-
ing the assessment. Observation or record keeping of spill
causes should aid in pinpointing possible corrective actions.
For example, if spills occur during drainage, it may be desirable
to use a larger catch basin to facilitate lining it up with the drain
on the engine. It may be advantageous to encourage 1he use
of metal or plastic pans to receive oily engine pads and
disposable parts such as oil filters to assure that any oil which
leaks from them can be recovered and added to the recycling
stream. In general, most identifiable spills occur during the
transfer of materials from one container to another or in the
process of moving materials from one place to another. To
promote spill prevention, therefore, it is important to minimize
such transfers. Where it is necessary to transfer used oil from
one container to another, it is desirable to use a drip pan or
spill collector to retain any spillage and allow it to be returned
to the recycling stream. When it is necessary to move contain-
ers, the moving process should use closed containers to prevent
liquid loss and should minimize the chances of the containers
tipping or falling.
A longer-term option leading to reduction in oil usage could be
explored. It is certain that if the time between oil changes could
be lengthened, then less used oil would be generated. Length-
ening the time between oil changes, however, is a difficult
unilateral move by those responsible for vehicle maintenance.
There are potential complications with engine warranty condi-
tions; motor oil manufacturers may need to change their formu-
lations and product use recommendations. The issue may be
an important one to raise and may have more impact if opera-
tors of large vehicle fleets or associations of such large users
bring it to the attention of the appropriate manufacturers and
encourage them to respond.
Antifreeze
Engine antifreeze is typically a solution of ethylene glycol in
water and also contains certain additives to inhibit corrosion.
Current practice is to drain the cooling system periodically and
to replace the antifreeze solution with fresh liquid, discarding
the old. Records available at the facility demonstrate that over
the period 1985 through 1989, an average of 5100 gal/yr of
antifreeze was purchased for use throughout the network of
maintenance facilities. Usually, about 40% of all such pur-
chases are used at the facility studied. Therefore, we can
assume that about 2000 gal/yr of commercial antifreeze is
used there. Of course, the volume of the waste stream would
be larger because the coolant in the engine is a water solution,
often about a 1:1 mixture.
There could be a significant impact on the quantity of waste
generated from the facility by initiating a program leading to
reuse or recycling of the antifreeze solution that is drained from
vehicle engines. There are commercial systems available that
will prepare drained antifreeze solution for reuse by filtration,
pH adjustment, and additive addition, if necessary. In addition,
more glycol can be added if necessary to maintain a low
freezing point.
In theory, such reconditioning and reuse could continue indefi-
nitely. Purchase and use of virgin ethylene glycol should de-
crease significantly. This reuse approach should result in sav-
ings from avoided replacement costs and from avoided dis-
posal costs. It is recommended that use of such a system be
considered.
Freon and Other Chlorofluorocarbons (CFC's)
Freon and other CFC's are present at the facility because of
their use in vehicle air conditioning systems. They have been
recognized as significant contributing factors in the depletion of
ozone in the upper atmosphere. International accords have
been signed leading to controls on the production and use of
these materials. The primary effect of the accord will be to limit
severely the production of the CFC's that will have the second-
ary effect of raising the price of the materials. Therefore, in
addition to the major importance of preventing the release of
the CFC's for environmental reasons, there will be a significant
economic incentive to encourage recovery and reuse of these
materials.
* Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
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Based upon purchase data, the use of CFC's at the facility is
about 140 Ib/yr. As is typical for the vehicle maintenance
industry, there are two substantial pathways for the loss of the
material to the atmosphere. The first is loss through leaks that
develop in the air conditioning systems in the vehicles. Fre-
quently, the vehicles are presented for servicing with the com-
plaint that the air conditioning system is not working, usually
because a large proportion of the CFC charge has leaked out.
The second pathway results from what has been in the past an
industry-wide repair procedure of recharging the system with
fresh CFC, locating the leak, discharging the CFC to the
atmosphere, repairing the leak, and recharging the system with
fresh CFC. Occasionally, it has been necessary to repeat the
procedure when the system had more than one leak.
Two options can be proposed to address these procedures.
Loss prevention through leak prevention appears to have po-
tential for reduction in the use of CFC. This would require
development of a regularly scheduled preventative mainte-
nance inspection of all vehicle air conditioning systems to
guard against the development of major leaks. Second, during
the repair stage, rather than venting CFC to the atmosphere, it
would be preferred to use a commercial CFC capture and
reuse device. Such devices are capable of connection to the
vehicle system for recovery of the CFC and have the ability to
purify the material to quality standards that qualify it for reuse.
Paint
The painting operations at the facility have a relatively small
volume of throughput because the staff is responsible not only
for coating application but for surface preparation as well. The
relatively small quantity of wastes from the surface preparation
activities is largely handled as solid waste. Any wastes such as
paint strippers containing solvents that may be hazardous are
treated appropriately. The larger quantity of wastes comes
from the painting operation itself. A wide variety of objects are
painted during the year requiring that several varieties of coat-
ings be kept on hand. Nevertheless, the painting operation has
also made constructive steps in the direction of pollution pre-
vention by shifting away from solvent-based coatings to water-
based materials. Current stocks of coatings include 85 gal of
water-based paints and 215 gal of solvent-based paints.
The movement away from solvent-based coatings will become
easier as manufacturers broaden the availability of water-based
coatings with necessary performance characteristics. Reduc-
tion in the use of solvent-based coatings can be expected to
reduce the quantity of solvent released to the atmosphere and
reduce the volume of solvent used for equipment cleaning.
Because much of the painting is done using spray techniques,
there is value in considering options that have potential to
reduce the quantity of waste generated as a result of
overspraying. While it was not possible to determine the amount
of coating lost at this facility due to overspraying, in some
studies, losses of up to 50% of the coating used have been
found. Some options that have potential to reduce overspray
include use of electrostatic spray systems, use of air assisted
airless spray guns in place of air spray guns, and reduced air
pressure in the coating system.
Tires
There is an active program for recycling used tires. The study
facility serves as a collection point for used tires from through-
out the system. A contractor periodically picks up the collected
tires and takes them offsite for recycling. About 95% of the
tires are obtained from the vehicles of the Department, the
other 5% are found abandoned along the roadside.
It is assumed that the recycling contractor removes any recap-
pable tires from the collection before beginning any destructive
recycling process. Typically, tires from large vehicles have
more value after recapping than do automobile tires because
of lack of commercial demand for the latter. The accumulated
tires at the facility represent a very broad range of types and
sizes because of the diversity of vehicles which the organiza-
tion uses. Moreover, because of the frequency with which the
vehicles drive near curbs in carrying out their activities, there is
an increased amount of sidewall wear as compared with tread
wear that would be observed in a more typical on-the-road
vehicle. This increased level of sidewall wear would be ex-
pected to reduce the potential for recapping, which depends
upon a satisfactory sidewall integrity.
A potential waste reduction option would be to increase the
useful life of the tire in service on the vehicle. In those situa-
tions where tires eventually must be replaced because of
sidewall wear, a modified tire rotation procedure of actually
turning the tire around to equalize wear on both sides of the
tire may extend the life. Obviously, this needs to be done in
such a way that safety issues are not compromised. Additional
emphasis in training programs concerning the importance of
avoiding contact with curbs may also have a beneficial effect.
As part of a concerted waste management initiative for the
facility, a drum-crushing apparatus has been acquired. It is
proposed to use the device to reduce the volume of waste from
this source as well as other departments in the organization.
While the use of such a device has potential for making this
waste stream more manageable, it cannot be considered a
waste minimization option. It is a volume reduction activity.
Furthermore, it has potential for additional complexities. Clearly,
staff will have to be trained in the proper operation of the
equipment as well as in proper sorting and separation of drum
types that will facilitate the reuse of the materials of construc-
tion of the crushed drums.
In addition, it will be important to develop procedures to assure
that any residues of hazardous materials have been removed
from the containers before crushing. This will require some
training to assure employee identification of any containers that
may have held hazardous materials. In some situations, the
containers may require triple rinsing to assure removal of the
contents. Ideally, such rinsing should be done at the operating
facility where the container is emptied. Moreover, the rinses
may have to be handled as a hazardous waste and in any
event will require appropriate environmental management.
A better approach would be to look at two other options for
drum management that may reduce the number of waste
drums. One approach would be to consider the reuse of the
containers either within the facility or through a drum salvage
company. A second option would be to require the purchase of
materials in returnable containers that are sent back to the
manufacturer for refilling when empty. Many suppliers are now
offering this shipping arrangement.
Other Waste
The facility serves as a collection point for other types of scrap
such as damaged traffic control devices including aluminum
poles. Similar types of wastes can come from the metal shop
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at the facility. It is expected that periodically a contractor will
remove these materials from the site for recycling. There ap-
pears to be an operational problem here, however, again
related to the contracting procedures. Lengthy delays have
been encountered in identifying and contracting with an appro-
priate recycling outlet. These delays can result in the accumu-
lation of more material at the facility than can be appropriately
housed. When storage capacity is exceeded, a powerful psy-
chological disincentive to waste minimization is sent to the
staff, by raising questions about the level of commitment of
management to the concept. It is recommended that contract-
ing procedures be reviewed to overcome this complication.
Training and Employee Incentives
An ultimate goal of an organizational waste reduction/pollution
prevention program is to institutionalize it, that is, to make the
idea of waste reduction a part of the everyday thinking and
actions of each employee. A key aspect of this has been found
to be a training program for every employee. The training could
include discussions and illustrations of the corporate commit-
ment to waste reduction, the types of waste currently generated
at the facility and the areas within the facility where they are
generated, the methods of storage, treatment, and disposal
required for these wastes, the costs of treatment and disposal,
and some examples of waste reduction success stories at the
facility or at other corporate sites. Such training could be
incorporated into the general employee safety training pro-
grams at the facility.
Some discussion of the importance of each employee to the
continuing waste reduction effort is also valuable. Companies
such as DuPont, Monsanto, Dow Chemical, and 3M have
found that the development of an incentive and recognition
program for waste reduction ideas developed and submitted by
employees has been very successful. Obviously, the employ-
ees who carry out the activities are the ones most directly
responsible for generating waste. They typically have the best
ideas for reducing the amount of waste created. The compa-
nies named above, among others, reward such ideas mon-
etarily or provide other recognition in newsletters or posters. A
similar program at this facility might have value.
Because a waste reduction program is not a one-time activity,
continuous employee training and awareness raising is impor-
tant. Regular monitoring and reporting of waste reduction re-
sults can facilitate the on-going effectiveness of the program
with employees.
Conclusion
The waste reduction opportunity assessment process has con-
firmed that the facility has already initiated several positive
actions leading to waste reduction/pollution prevention. Several
options have been identified that could result in additional
reductions in waste generation in the areas of used oil, anti-
freeze solution, CFC's, and coatings. Some administrative com-
plexities in the area of contracting with recycling facilities have
also been identified.
It is recommended that the feasibility of these options be
investigated by the facility. It is further recommended that
employee training programs be broadened to include more
material on the importance of pollution prevention actions within
the facility.
Summary of Waste Minimization Opportunities
Table 1 presents the type of waste currently generated by the
plant, the sources of waste, the quantity of waste, and the
annual treatment and disposal costs (where known and avail-
able).
Table 2 presents the opportunities for waste minimization iden-
tified during the assessment. The types of waste, the minimiza-
tion opportunities, and possible waste reductions are presented
in the table. When available or estimable, the associated sav-
ings, implementation costs, and payback times are usually
determined. However, because the feasibility analysis was to
be carried out by the staff of the facility, that information was
not readily available for this assessment.
This Research Brief summarizes a part of the work done under
cooperative Agreement No. CR-815165 by the New Jersey
Institute of Technology under the sponsorship of the New
Jersey Department of Environmental Protection and Energy
and the U.S. Environmental Protection Agency. The EPA Project
Officer was Mary Ann Curran. She can be reached at:
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Cincinnati, OH 45268
Table 1. Summary of Generated Wastes
Waste Generated
Waste oil
Antifreeze solution
Source of Waste
Motor vehicle engines
Motor vehicle engine
Annual Quantity
Generated
2700 gal
4000 gal
Annual
Costs
($54 profit)
$7,300
Chlorofluorocarbons
Paint Solvents
cooling systems
Motor vehicle air 130 Ib
conditioning systems
Spray painting operation 300 gal
No management
cost
No management
cost
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Table 2. Summary of Waste Minimization Options Identified
Waste Generated
Waste Oil
Antifreeze Solution
Chlorofluorocarbons
Paint Solvents
Minimization Opportunity
Fluid analysis to stretch
out oil changes. Control
water content of used oil.
Initiate use of reconditioning
and reuse technology.
Initiate use of capture and
reuse technology.
Continue change to water
based coatings. Use new
hardware to minimize over
spray.
Annual Waste Reduction Net Annual
Quantity Percent Savings
Implementation Payback
Cost Years*
675 gal
4000 gal
130 Ib
100 gal
25
100
100
33
$2,690"
7,300
1,300
600
$5,000
12,000
5,000
1,300
2.0
1.7
3.8
2.1
'Savings result from reduced raw material and treatment and disposal costs when implementing each minimization opportunity independently.
" After the initial fluids analysis cost, there will be continuing costs for more analyses and improved record keeping.
•fru.S. GOVERNMENT PRINTING OFFICE: 1994 - 550-067/HOI8I
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United States
Environmental Protection Agency
Center for Environmental Research Information
Cincinnati, OH 45268
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POSTAGE & FEES PAID
EPA
PERMIT No. G-35
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EPA/600/S-92/026
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