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
     BULK RATE
POSTAGE & FEES PAID
        EPA
   PERMIT No. G-35
Official Business
Penalty for Private Use
$300
EPA/600/S-92/026

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