xvEPA
                         United States
                         Environmental Protection
                         Agency
                         Research and Development
                                   Risk Reduction
                                   Engineering Laboratory
                                   Cincinnati, OH 45268

                                   EPA/600/S-92/063   OctobeTl992"
ENVIRONMENTAL
RESEARCH   BRIEF
          Waste  Reduction Activities and Options for an Electrical Utility
             Transmission System  Monitoring and Maintenance Facility
                                  Kevin Gashlin 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 the state of New Jersey. One of the sites selected
was an  electrical utility transmission  system monitoring and
maintenance facility which has the responsibility to monitor,
maintain, and repair the distribution system for the electrical
service provided in a defined geographical area by a regulated
public utility. A site visit was made in 1990 during which
several opportunities for waste minimization were identified.
Options identified for waste reduction included more accessible
inventory records to identify PCB-containing transformers,
changing procedures for vehicle oil  changes, a search for
alternatives for electrical connection degreasing, and change
to low-solvent or water-based coatings for transformer recondi-
tioning.  Implementation of the identified waste  minimization
opportunities was not part  of the program. Percent waste
reduction, net annual savings, implementation costs and  pay-
back 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
emissions, potential soil and groundwater contamination, solid
waste disposal, and employee health and safety have become
                        increasingly important concerns. The management and dis-
                        posal of hazardous substances, including both process-related
                        wastes and residues from waste treatment, receive significant
                        attention 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 operations
                        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 the New Jersey Institute of Technobgy (NJIT) assisted
                        in conducting the  assessments. This research  brief presents
                        an assessment of  a monitoring and maintenance facility for an
                        electrical utility transmission system (1 of the 30 assessments
                        performed) and provides recommendations for waste minimi-
                        zation 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 inhouse 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,  NJIPs 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 development
 of options was 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 com-
 mitment 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 devebped, the team offered assis-
 tance in the  technical review, inspections, and option develop-
 ment.

 No sampling or laboratory analysis was undertaken as part of
 these assessments.


 Facility  Background
 The  facility  has  the  responsibility to monitor, maintain, and
 repair the distribution system for the electrical service provided
 in  a  defined geographical area  by a  regulated public utility.
 Included among the  functions of the facility are response to
 accidents  involving company  equipment, service to a fleet of
vehicles, and repair, maintenance, and rebuilding of  transform-
ers. The facility studied is only one of several operated by the
company throughout its service area.
 Operational Processes
 Conceptually, the industrial activities at this facility  are  rela-
 tively simple. Company staff respond to accidents which may
 involve damaged  utility poles and broken transformers. They
 also have responsibility for regular inspection and maintenance
 of distribution lines and ancillary equipment. Maintenance and
 repair of a fleet of vehicles used in this operation is also carried
 out  at the facility. Finally,  repair, reconditioning, and rebuilding
 of transformers and similar equipment is a regular operation of
 this facility.

 The response to  accidents involves emergency  repair and
 replacement of equipment in the field and may involve clean up
 of leaking transformer oil  of which some may contain PCB's.
 This clean  up activity may result in substantial quantities  of
 waste,  not  only of oil which must be drained from damaged
 transformers, but also from soil or other materials which  may
 have been contaminated with the oil.

 The reconditioning operation for the transformers  involves
 draining the oil, repairing  any damaged components, painting
 them, filling them with fresh mineral oil, and putting them back
 into service.  The  painting  operation currently uses  aerosol
 cans of solvent-based paints.

 In the process of reinstalling the electrical equipment within the
 system, it is a standard practice to clean the electrical connec-
 tions with a solvent, usually 1,1,1-trichloroethane, to promote
 good contact by removal of any grease.

 The vehicle maintenance activities carried out at the facility
 include  fluid changes (resulting in waste streams of oil, anti-
 freeze, and  freon)  and metal part repair and replacement.


 Existing Waste Management Activities
 The company has already recognized some advantages and
 benefits of identifying and implementing  waste reduction and
 pollution prevention practices. A study was done which indi-
 cated that  the time  between vehicle oil changes could  be
 lengthened  without adversely affecting  the operation of the
 engines. Such a change would reduce the volume of waste oil
 generated at the facility. The company has  plans to acquire a
 recovery and recycling unit for the freon used in  vehicle air
 conditioning systems. Scrap metals recovered as part of the
 operations of the facility are sent out for secondary recovery
 and  not disposed of as waste.

 The  company has taken a conservative position with regard to
 transformer oil by making the initial assumption that all such oil,
 particularly that appearing  as leaks or spills, should be treated
 as if it  contained PCB's. Tests  are done subsequently to
 confirm this  assumption. Consequently, a significant volume of
 waste is initially listed  as PCB-containing and later reclassified.

 Other waste streams are sent for treatment and management
 offsite.


 Waste Minimization Opportunities
 The  type  of waste currently  generated by the  facility,  the
 source of the waste, the quantity of the waste and the annual
treatment and disposal costs are given in Table 1.

Table 2 shows the opportunities for waste minimization recom-
 mended for  the facility. The type of waste, the minimization
opportunity,  the possible waste reduction and associated sav-
ings, and the implementation cost along with the payback time

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are given in the table. The quantities of waste currently gener-
ated at the facility and possible waste reduction depend on the
level of activity of the facility.

K should be noted that the  economic savings of the minimiza-
tion opportunity, in most cases, results from the need for less
raw material and from reduced present and future costs asso-
ciated with  waste treatment  and disposal. It should  also  be
noted that  the savings  given  for each opportunity  reflect the
savings achievable when implementing each waste minimization
opportunity independently and do not reflect savings that would
result when the opportunities  are implemented in a package.
Also, no equipment depreciation is factored into the calculations.

The largest volume of waste from this facility is related to clean
up activities over which the facility has no direct control. A long
range answer is to improve the durability of  equipment, spe-
cifically in the  case of transformers, to decrease the likelihood
of leakage as a result of accidents and aging. An additional
facet of this situation is the  desire of the company to avoid any
negative perception of  contamination problems, and therefore
it is taking a very conservative position regarding clean up and
management  of spill situations. While such  a position  is  in
many ways laudable and  understandable, it  does add to the
waste management quantity when material is treated as haz-
ardous waste  when  other options  may be available,  such  as
                                     easy identification and location of hazardous materials through
                                     a tracking system.


                                     Regulatory Implications
                                     Changes  in reconditioning of electrical equipment may have
                                     regulatory  implications. There are penalties  incurred by the
                                     company for service disruptions. When a particular method has
                                     been shown by experience to be satisfactory in maintaining an
                                     acceptable  level of customer service, there is a reluctance  to
                                     make changes without a clear determination of superiority or at
                                     least of comparability. Therefore, some of the options identified
                                     in this  assessment will require evaluation and field trials before
                                     adoption.

                                     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
* Mention of trade names or commercial products does not constitute endorse-
 ment or recommendation for use.
Table 1. Summary of Current Waste Generation


Waste Generated          Source of Waste
Oil Spill and Leak
Residue

Waste Oil from
Electrical Transformers

Wastes Containing PCB
Motor Vehicle Oil

Painting Residue
                               Annual Quantity
                                 Generated
Primarily damage to transformers
155 Tons
Draining of oil prior to reconditioning    126 Tons
or decommissioning transformers

Primarily damage to transformers and   28 Tons
PCB recovery
Vehicle maintenance and repair

Transformer casing painting
2.7 Tons

   1 Ton
  Annual Waste
Management Costs

   $46,000
    100,000


    50,000


       400

      2000
                                                                                 •U.S. Government Printing Office: 1992— 648-080/60124

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Table 2.   Summary of Recommended Waste Minimization Opportunities

Waste Stream          Minimization Opportunity                 Annual Waste Reduction          Net       Implementation  Payback
Reduced                                                      Quantity         Percent    Annual Savings      Cost       Years *
Wastes Containing       Improved access to information           21 tons           75          $30,000        $20,000       0.67
PCB                   about the PCS content of
                       individual transformers.  A
                       computerized system of record
                       keeping is suggested.

(It should be noted that this does not represent a net reduction of waste. It merely moves a portion of a waste stream from one type of hazard category
to another less hazardous category.)

Motor Vehicle Oil        Change frequency of oil changes          0.7 tons          25            100             0
                       from 6000 mile to  7500 mile
                       intervals.

Painting Residue        Change from solvent-based              0.9 tons          90           1800            300         0.16
                       aerosol paint to brushed-on
                       water-based paint.

(It should be noted that this depends upon the availability ofawa ter-based coating with the necessary performance characteristics. It also ignores the
extra worker time needed to apply coatings by brushing as well as the possibility that coatings will have to be applied more regularly.)

Residues from          Modify design and construction           140 tons         50           70,000         unknown       unknown
Transformer Leaks       of transformers to reduce damage
and Repairs            and subsequent leaks and spills.

(It should be noted that this option will require substantial additional research by transformer manufacturers into why transformers fail and whether and
what changes can be made to improve their performance. Such research and design changes are beyond the present technical scope of the company.
Therefore only an approximation can be made. Certainly, because this is the largest waste category at the facility, effort should be made to identify
options.)

Chlorinated Solvent      Change to non-chlorinated                10 gal            100          none           none
from Electrical          solvent.
Contact Degreasing

(It should be noted that this option would have no effect on wastes manifested from the facility.  Rather it changes the category of use of a relatively toxic
material to one which is less toxic.  The total quantity of volatile material emitted to the air may stay the same or in fact may increase. Without tests of
performance it will not be possible to determine the amount to be used. It is often the case in substitution situations of this type that employee perception
plays a significant role in the quantity of material to be used. If the worker believes that the performance of the substitute is not as good as that of the
original material, then more of the material will be used.)
' Savings result from reduced raw material and treatment and disposal costs when implementing each minimization opportunity independently.
  United States
  Environmental Protection Agency
                                                                                                             FPA
  Center for Environmental Research Information                                                OCDUITM  ^ ^
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  Cincinnati,  OH  45268
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