POLLUTION PREVENTION OPPORTUNITY ASSESSMENT

        General Mail and Vehicle Maintenance Facility
               United States Postal Service
                      Buffalo, NY

                    September 1992


                                            B
        UNITED STATES                        "*V,    vC*
        POSTAL SERVICE                         "** J»R Of *

-------
                 CONTENTS
PREFACE






SECTION I	PROJECT SUMMARY






SECTION II	GENERAL MAIL FACILITY






SECTION III	VEHICLE MAINTENANCE FACILITY

-------
                                   PREFACE
This document presents the results of a Pollution Prevention Opportunity Assessment conducted



at the U.S. Postal Service's (USPS) General Mail Facility (GMF) and Vehicle Maintenance Facility



(VMF) in Buffalo, New York. The assessment was conducted for the Environmental Protection



Agency - Region II and the USPS - Northeast Region to investigate potential pollution prevention



alternatives for GMF mail processing operations and VMF vehicle servicing and refinishing



operations.







In particular, this document identifies and discusses the economic and technical feasibility of



potential source reduction  and recycling opportunities, and presents a limited implementation



plan.  Discussion  of potential barriers to implementing the identified options and



recommendations for future investigations into techniques to eliminate, reduce, or recycle wastes



from mail processing and vehicle maintenance operations is also incorporated.







It should be noted that although USPS facilities were the subject of the assessment, the



alternatives presented also apply to commercial package handling operations, as well as other



government and commercial vehicle servicing facilities.

-------
               PROJECT SUMMARY
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
     General Mail and Vehicle Maintenance Facility
            United States Postal Service
                    Buffalo, NY
                       by
     Science Applications International Corporation
              Falls Church, VA  22043
               Cincinnati, OH  45203
                  September 1992
            EPA Contract No. 68-C8-0062
        SAIC Project No. 01-0832-03-1006-010

-------
                                          ABSTRACT





     This report presents the results of a Pollution Prevention Opportunity Assessment (PPOA)



 conducted at the U.S. Postal Service's (USPS's) General Mail Facility (GMF) in Buffalo, New York. The



 PPOA was conducted of operations at the GMF (where mail is processed) and at the Vehicle



 Maintenance Facility (VMF) (where 1,200 postal vehicles are serviced and refinished). Waste generation



 at both facilities was documented and quantified. The reports identified potential source reduction and



 recycling initiatives as well as areas where further research is needed. The economic and technical



feasibility of selected opportunities and techniques to eliminate, reduce, or recycle wastes were



investigated. A limited implementation plan was developed.  Potential barriers to implementing the



identified options are described.

-------
                             TABLE OF CONTENTS


                                                                       Page


ABSTRACT	  j

INTRODUCTION	  1

PROCEDURE 	  2

RESULTS AND DISCUSSION	  3

CONCLUSIONS AND RECOMMENDATIONS	  7



                               LIST OF TABLES
TABLE 1. ESTIMATED SOLID WASTE GENERATION, USPS BUFFALO
        GENERAL MAIL FACILITY	  3
TABLE 2. ESTIMATED WASTE GENERATION, USPS VEHICLE MAINTENANCE FACILITY	  5
TABLE 3. COST/BENEFIT ANALYSIS FOR SELECTED OPTIONS 	  6
TABLE 4. ESTIMATED ANNUAL RETURN FROM SOURCE REDUCTION AND RECYCLING,
        USPS GMF, BUFFALO, NY 	  8
TABLE 5. POTENTIAL WASTE REDUCTION AND COST SAVINGS FOR SELECTED OPTIONS 	  9

-------
                                        INTRODUCTION





     The Environmental Protection Agency (EPA) Region II has established a Regional policy to actively



 pursue pollution prevention at Federal facilities.  The United States Postal Service (USPS) is committed



 to source reduction and recycling as sound environmental practices.  The USPS's goal is to reduce



 waste 25 percent (from 1992 levels) by December 1993 and an additional 25 percent by December 1995.



 Moreover, the USPS is committed to reducing the use of 17 hazardous chemicals identified by EPA's



 33/50 Program over the next 3 years.







     In response to its outreach efforts, EPA Region II received a request from the USPS for technical



 assistance.  A pollution prevention opportunity assessment was carried out of the GMF and the VMF



 operations at the Buffalo, New York, facility to identify source reduction and recycling options for both



 hazardous and nonhazardous wastes. This particular demonstration project is intended to serve as a



 model for establishing pollution prevention programs at other Postal Service facilities in the Northeast



 region, and potentially, in other parts of the country as well.  The results of the GMF and VMF



assessments are described separately in two companion reports  Pollution Prevention Opportunity



Assessment  General Mail Facility, and Pollution Prevention Opportunity Assessment Vehicle Maintenance



Facility.

-------
                                         PROCEDURE





     The assessment was conducted using the procedures outlined in EPA's Facility Pollution



Prevention Guide (EPA/600/R-92/088).  The assessment has two major phases. The first phase



quantifies current waste generation and management practices. The second phase identifies and



evaluates the feasibility of opportunities and techniques to eliminate, reduce, or recycle wastes. The



project includes:







     •   Selecting assessment targets;



     •   Assessing onsite pollution prevention capabilities;



     •   Generating pollution prevention options;



     •   Preparing a feasibility analysis of selected options;



     •   Preparing a limited implementation plan.







The PPOA Team that conducted the assessment was composed of employees from an outside



environmental  consulting firm  and USPS representatives.

-------
                                 RESULTS AND DISCUSSION

     General Mail Facility
     The Buffalo GMF processes 5 million pieces of mail a day. Three areas are responsible for
generating the majority of the facility's wastes: the offices, the mail sorting floor, and the unloading and
loading docks. The GMF generates approximately 537 tons of waste per year.  Approximately 253 tons
is cardboard.  Major waste streams are shown in Table 1. Machinery maintenance wastes (oil, grease,
and parts cleaning solvent) are also generated. The composition of much of the waste is undetermined.
Direct observation of the waste compactor contents was not possible due to safety concerns.  The
"missing" tonnage may include corrugated plastic containers, pallets, aluminum, or metals improperly
discarded instead of recycled.  Furthermore, disposal of many materials, such as pallets, plastic film, and
corrugated cardboard, at the Buffalo facility is not easily monitored and may have been underestimated.
Annual solid waste disposal costs are approximately $42,000.
                     TABLE 1. ESTIMATED SOLID WASTE GENERATION
                     USPS BUFFALO GENERAL MAIL FACILITY, 1991-1992

	WASTE STREAM	QUANTITY
 Cardboard                                                      253.5 tons
 Computer Paper                                                   2 tons
 Mixed Office Paper                                               46 tons
 Aluminum Cans                                                  0.6 tons
 Other Metals                                                     30 tons
 Plastic Film                                                      13 tons
 Undetermined                                                   191.9 tons

-------
The major recommended source reduction and recycling options are shown below. Discussions for
each of the options are included in the GMF report.

     •  Establishing recycling programs for each waste stream;
     •  Reducing packaging;
     •  Establishing a duplex copying policy;
     •  Improved waste management cost accounting;
     •  Improved employee involvement in pollution prevention;
     •  Changing procurement specifications.

Vehicle Maintenance Facility

     The Buffalo VMF operations include vehicle maintenance and automotive refinishing operations
typical of facilities of its kind.  The Buffalo USPS fleet includes 1,200 vehicles such as passenger cars,
trucks, and semi-tractor trailers.  Major waste streams generated from this facility are shown in Table 2.
Waste disposal costs are approximately $21,645 annually.

-------
                          TABLE 2.  ESTIMATED WASTE GENERATION
                     USPS BUFFALO VEHICLE MAINTENANCE FACILITY 1991

                           WASTE TYPE	    ANNUAL QUANTITY
                Oil Filters        .                    1,800 filters
                Lead Acid Batteries                    280 batteries
                Brakes                               1,200 -1.500 sets
                Cracked Corn Absorbent               30 - 60 gallons
                Soiled Rags                          8,515 rags
                Paint Equipment Cleaning Solvent       1,118 pounds
                Waste Paint/Thinner                   1,664 pounds
                Solvent  Brake Cleaner                  2,106 pounds
                Solvent  Engine Parts Cleaner            5,746 pounds
                Used Oil (engine, brake fluid,            2,830
                transmission fluid)
                Used Antifreeze                       300 gallons
                Radiators                            280 radiators

 A number of source reduction and recycling options were identified and are discussed in the full report.
 Major source reduction and recycling options are:
   • Switching to water-borne low volatile organic compounds (VOC) paints;
   • Using high volume low pressure (HVLP) spray guns;
   • Switching to aqueous cleaners.
   « Paint Mixer System
   • Gun Washer Station
   •  Operator Training


The economic feasibility of selected options is shown in Table 3.

-------
        TABLE 3. COST/BENEFIT ANALYSIS FOR SELECTED OPTIONS
 HVLP Paint Application System           ||il||^|Mg|lgS^||
 Total Annual Avoided Costs                              $11 , 1 96
 Net Annual Benefit                                     $8,138
 Pay Back Period                                       Immediate
lillf^
 Total Annual Avoided Costs                              $8.567
 Net Annual Benefit                                     $3,000
 Pay Back Period                                       Immediate

-------
                          CONCLUSIONS AND RECOMMENDATIONS








     Postal service employees have enacted a number of activities to reduce or recycle VMF and GMF



wastes. There are additional pollution prevention opportunities, identified in the reports, to further



eliminate or reduce wastes.  Painting operation and engine and brake parts washing are the biggest



pollution prevention opportunities at the VMF. Water borne  coatings and high transfer efficiency paint



delivery systems will eliminate or significantly reduce hazardous wastes and VOC emissions from



painting operations. Replacing organic cleaning solvents with aqueous parts washers and chemicals will



eliminate hazardous solvent wastes from engine and brake parts washing operations. Enacting these



options can potentially reduce annual hazardous waste generation by 5,954 pounds.







     Implementing options recommended in the two reports will assist the Buffalo facility  staff meet the



USPS goal to reduce 1992 waste levels by 25 percent by 1993 and an additional 25 percent by 1995.



Eliminating solvent borne paints will significantly reduce emissions of four EPA 33/50 target chemicals



generated during painting operations at the VMF.  The options identified in the report will  also reduce



operating costs by decreasing disposal costs. By implementing the options described in  the two report



the USPS has the potential to save over $100,000 on waste disposal costs as shown in Tables 4 and 5.



Additionally, there are unqualified benefits such as reduced liability, paper work, spills and spill



control/disposal costs, and future regulatory requirements. Potential barriers to implementing pollution



prevention options are discussed in the full  reports. Overall, there are no major barriers to implementing



many of the pollution prevention options. The options identified in the two reports are generally



applicable to the 350 vehicle maintenance and 270 general mail facilities nationwide.

-------
TABLE 4.  ESTIMATED ANNUAL RETURN FROM SOURCE REDUCTION AND RECYCLING
                   USPS GENERAL MAIL FACILITY, BUFFALO, NY
                ACTION
POTENTIAL MONETARY BENEFIT
Current Practices
Recycle laser printer cartridges
Recycle aluminum cans
Recycle scrap metal
Recycle loose cardboard (2)
Subtotal (current practices)
Additional Recommended Measures
Recycle plastic film
Subtotal (recommended measures)
Recently Implemented or Proposed
Recycle computer paper
Recycle mixed office paper
Replace paper hand towels with electric air
dryers (3)
Subtotal
Total
            $1,740
            $1,011
            $2,125
           $34,000
           $38,876

            $5,485
            $5,485

            $240
            $1,955
           $50,000

           $52,195
           $96,556
Notes:
1.   Monetary benefits include a $85 per ton avoided disposal cost and payment for
     recyclable materials (aluminum, plastic film, and computer paper). Disposal costs for
     other locations may differ significantly from this value.  Payment for recyclable materials
     is based on the September 1992 market in the Buffalo area.  Any use of these numbers
     must recognize the fact that markets for recyclable materials vary greatly with time and
     location.
2.   Cardboard  recycling commenced as a result of the preliminary assessment
     findings.
3.   Includes replacing hand towels at Buffalo GMF and Station Branches.

-------
  TABLE 5.  POTENTIAL WASTE REDUCTION AND COST SAVINGS FOR SELECTED OPTIONS
                    USPS, BUFFALO VEHICLE MAINTENANCE FACILITY
Option
Annual Waste Reduction
Potential
Annual Cost Saving Potential
Water Borne Paints


Aqueous Parts Washer



HVLP Paint Application System


Gun Washer Station
2,782 Ibs of hazardous waste
paint/solvent/thinner

3,163 Ibs of hazardous engine
and brake parts cleaning
solvent

50% less VOC emissions
30% less paint solid waste

75-90% less VOC emissions
$3,088 in reduced waste
disposal

Undetermined
$8,138 in reduced raw material
and waste disposal

$2,978 in reduced raw materials
and waste disposal

-------
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT

             GENERAL MAIL FACILITY

    United States Postal Service Facility, Buffalo, NY
                       by
      Science Applications International Corporation
                  Falls Church, VA
                   Cincinnati, OH
            EPA Contract No. 68-C8-0062
          SAIC Project No. 1-0832-03-1006-010


                  September 1992


             Technical Project Monitors

                 Mr. John Filippelli
                 U.S. EPA Region II
                   New York, NY

                   Mr. Ken Stone
                  U.S. EPA RREL
                   Cincinnati, OH
    RISK REDUCTION ENGINEERING LABORATORY
      OFFICE OF RESEARCH AND DEVELOPMENT
     U.S. ENVIRONMENTAL PROTECTION AGENCY
             CINCINNATI, OHIO 45268

-------
                          DISCLAIMER
The information in this document has been funded wholly or in part by the
United States Environmental Protection Agency under Contract 68-C8-0062
to Science Applications International Corporation.  It has been subjected
to the Agency's peer and administrative review and has been approved for
publication as an EPA document.

Mention of trade names or commercial products does  not constitute
endorsement or recommendation for use.

-------
                            ABSTRACT
This report presents the source reduction and recycling recommendations
resulting from a pollution prevention assessment conducted at the Postal
Service General Mail Facility in  Buffalo, New York. The assessment was
performed  under Work  Assignment 3-54  entitled U.S. Postal  Service
Operations Pollution Prevention Opportunity Assessment for the U.S. EPA
Region II and the United States Postal Service (USPS).

The assessment, conducted during the week of April 6,  1992,  followed
procedures in the U.S. EPA Waste Minimization Opportunity Assessment
Manual (EPA\625\7-88\003) and the United State Postal Service Recycling
Guide  and Waste Reduction Guide.  These procedures  encompass the
concepts contained in the U.S. EPA Facility Pollution Prevention Guide
(EPA/600/R-92/088). Technologies and techniques to reduce and recycle
wastes were evaluated for effectiveness.  This report identifies  potential
solid waste reduction and recycling initiatives and identifies areas where
further research is needed.

-------
                               TABLE OF CONTENTS


ion

  DISCLAIMER	   ii

  ABSTRACT	  Hi

  ACKNOWLEDGEMENTS  	vii

  INTRODUCTION  	1
       Background	1
       Purpose	1
       Site Description 	2

  PURPOSE AND BENEFITS OF POLLUTION PREVENTION  	2
       Pollution Prevention - Goals  	3
       Pollution Prevention - Benefits	3
       Pollution Prevention Opportunity Assessment Procedure  	4

  WASTE QUANTITIES AND DISPOSAL COSTS  	6
       Waste Generation	6
       Operations Generating Waste  	7
          Unloading and Loading Docks  	  9
          Mail Sorting Floor	  9
          Offices	  9
          Facility Maintenance	  9
          Computer Forwarding Systems/Undeliverable Bulk Business
            Mail Facility  	  10
          Cafeteria  	  10

  SOURCE REDUCTION AND RECYCLING OPTIONS ASSESSMENT	  10
       Existing Source Reduction and Recycling Activities  	  10
          Corrugated Cardboard Recycling   	  11
          Ferrous Metal and Aluminum Recycling	  11
          UBBM Mail	  11
          Laser Jet Printer Cartridges	  11
          Office Paper Recycling	  11
          Replacing Paper Towels with Electric Powered Hand Driers  	  11
          Energy Efficient Lighting	  12
       Additional Source Reduction and Recycling Opportunities 	  12
       Corrugated Cardboard	  12
          Develop Vendor Specifications  	".....  12
          Replace The Corrugated Trays  	  12
          Redirect Corrugated Cardboard Boxes  	  12
          Bale OCC for Recycling  	  12

                                        iv

-------
                                TABLE OF CONTENTS (continued)

 Section

            Plastic Corrugated Containers	• •  15
            Paper	  ]5
               Duplex Copying	  1J>
               Duplex Printing	•	  1^
               Distribution Copies	  15
               Replace Disposable Paper Markers with Reusable Markers	  15
               Recycle Paper 	  15
            Plastic Film and Strapping	  16
               Recycle Plastic Shrink Wrap	  16
            Pallets  	  16
               Replace Wood and Pressed Wood Pallets with Plastic Pallets	  16
               Recycle Pallets	  16
               Pressed Wood 	  17
            Rigid Plastic Containers	  17
               Recycle Plastic Containers  	  17
            Other Recycling Options	  17
            Building Maintenance Waste	  17
               Inventory Control and Better Housekeeping Practices	  18
            Cafeteria Wastes	  19
            General Waste Reduction Options	  19
               Procurement  	  19
               Waste Stream Characterization Study	  20
               Bulk Mail and Magazines/Life-Cycle Analysis Study	  20
               Water and Energy Conservation  	  20
               Improved Waste Management Cost Tracking	  21
               Promote Affirmative Procurement and Facilitate Recycling  	  21
               Employee Participation	  21
               Public Education   	:	  23
            Options Ranking	  23

      FEASIBILITY	  23
            Corrugated Cartons	  23
            Plastic Film and Strapping	  25
            Recycling	  26
            Potential Implementation Barriers  	  27
               Paper	  28
               Procurement  	   29

      IMPLEMENTATION PLAN	  29

      CONCLUSIONS	  29
           Applicability to Other GMFs	'...'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.  31

Appendix A. Worksheets

Appendix B. Sources

Appendix C. Factsheet

-------
                                         FIGURES


Number                                                                               Page

 1    Pollution Prevention Opportunity Assessment Procedure	  5

 2   Estimated Solid Waste Generation
     USPS Buffalo General Mail Facility, 1991-1992  	  8
                                          TABLES


Number                                                                               Page

 1    Components of the GMF Waste Stream  	  7

 2    Potential Source Reduction Options	  13

 3    Potential Recycling Options	  14

 4    General Waste Reduction Options 	  14

 5    Key Ways to Maintain and Improve a Pollution Prevention Program	  22

 6    Qualitative Ranking of Recommended Activities	  24

 7    Cost/Benefit Analysis for OCC Recycling  	  26

 8    Recycling Program Development  Factors	  28

 9    Implementation Plan 	  30

10    Estimated Annual Return from Source Reduction and Recycling  	  32
                                            vi

-------
                      ACKNOWLEDGEMENTS
Funding for this project was provided by the United States EPA and the
United States Postal  Service.   The  EPA  Office of  Research and
Development Risk Reduction Engineering Laboratory also cooperated and
assisted in this project.  Special thanks are extended to Jim Rusiniak,
Charlie Vidich, Kevin Ferguson,  and Mary Bordonaro of the  USPS and
John Filippelli, Steve Petrucelli, Palma Risler, and Ken Stone of the U.S.
EPA.
                               vii

-------
INTRODUCTION

Background

        The Environmental Protection Agency (EPA) Region II has established a regional policy to actively
pursue pollution prevention at federal facilities. In response to EPA Region II outreach efforts, the Postal
Service Northeast Region requested technical assistance to explore ways to reduce the amount of waste
generated at the general mail facility (GMF) located in Buffalo, New York.  This assessment was conducted
in response to the United States Postal Service (USPS) policy to practically reduce the amount of waste
generated at its facilities.  The Postal Service is committed to source reduction and recycling as sound
environmental practices.  USPS policy is to  reduce waste and pollutants at the source of generation.
Following source reduction, postal priorities  for solid  and liquid nonhazardous  and hazardous waste
management are recycling, energy conservation and recovery, waste treatment, and (as a last resort) waste
disposal (USPS Waste Reduction Guide. AS 552). The Postal Service's goal is to reduce the amount of
waste generated in 1992 by 25 percent by December 1993 and an additional 25 percent by December 1995.
A detailed explanation of pollution prevention and its benefits is discussed later in the report.  The Postal
Service and EPA are interested in using the findings of this study as a model for Postal Service facilities in
the Northeast region and potentially for mail facilities in other parts of the country as well.

        The  project was initiated in January, 1992.  The assessment  team, comprised of SAIC staff,
conducted the onsite assessment of the Buffalo facility in March.  An initial briefing was held to acquaint
Postal Service officials with the assessment team members, discuss objectives of the site visit, and organize
the onsite information gathering process.   In addition, the assessment team gave a half day presentation
to Postal Service and EPA representatives from the Northeast region. The presentation covered pollution
prevention concepts, waste management issues of concern to the Postal Service, an overview of the
pollution prevention opportunity assessment process, and overall project goals. The assessment team spent
three days at the Buffalo facility and viewed  the areas where wastes are generated;  collected process
information; interviewed facility personnel; identified waste management procedures; identified procurement
procedures; gathered information concerning waste generation, disposal methods, and costs; and local
waste handling/reduction programs. A color slide  log of the assessment and accompanying text was
prepared.

        The assessment team continued to collect information by phone after the site visit. The assessment
team identified the most significant waste streams based on the quantity of waste generated, the chemical
constituents, and associated disposal costs. SAIC analyzed each process that generated a significant waste.
Analysts then identified and evaluated options for waste reduction for each process found at the Buffalo
facility using the Worksheets completed during the site assessment (see Appendix A).  In addition, team
members explored several options that  could also apply to other Postal Service facilities.

Purpose

        The purpose of this  project is to conduct a pollution prevention opportunity assessment to identify
source reduction and recycling options for both hazardous and nonhazardous wastes at the Buffalo GMF.
An opportunity assessment has four phases; a planning and organization phase, an assessment phase, a
feasibility analysis phase, and an implementation phase.   During the planning and organization  phase,
management commitment is secured, overall assessment goals are set, and the assessment program task
force is organized. The assessment phase involves quantifying current waste generation and management
practices.  This involves prioritizing and selecting assessment targets, collecting process and facility data,
selecting the assessment team members, reviewing data, generating options, and screening and selecting
options for further study.  The feasibility  analysis phase is a technical  and economic evaluation of the
selected options which are ranked and chosen for implementation. The implementation phase puts the
options into action.   This may require justifying  projects and  obtaining funding, installing equipment,
implementing procedures, and evaluating the performance of each option.

-------
        This report summarizes the results of the pollution prevention opportunity assessment and explains
soecrfic ootions and their associated costs and benefits. The Postal Service can use this report as the basis
for its pollution prevention implementation plan. Both source reduction and recycling alternatives have been
considered for the selected waste streams.

        The assessment covered both the GMF and the vehicle maintenance facility (VMF) which are
located at the Buffalo Postal Service site. The findings for each of these facilities are reported separately.
This report presents the findings from the assessment of the GMF.

Site Description

        The USPS  GMF, located at 1200 William Street, Buffalo, New  York, is situated on a  site  of
approximately 25 acres. A separate building housing the VMF is also located on the property. Both facilities
were designed and built to USPS specifications. The USPS leased the site beginning in 1963 and purchased
it in 1979.

        The Buffalo GMF is owned by the USPS.  The GMF consists of a three story office building and a
one story, 276,000 square foot mail processing floor. On the east and west sides of the building are docks,
each with more than fifty truck positions.  A leased, single story building at  1285 William Street, several
blocks away, houses the Computerized Forwarding System and the Undeliverabie Bulk Business Mail
(UBBM) operation.  The Buffalo  GMF is occupied 24 hours a day, seven  days a week, 365 days a year.
Normal employee occupancy on weekdays is 1,515;  Saturdays, 1,082; and  Sundays and holidays, 688.
During the month of December, approximately 200 additional temporary employees are on site. There are
118 office and supervisory employees and 10 individuals responsible for building maintenance.

        Nearly 2 million pieces of mail, including first and third class letters and flats* arrive for processing
at the GMF each day, while approximately 3 million pieces of mail are  sent out of the GMF for delivery to
recipients.  The Buffalo GMF serves as the Area Distribution Center for zip code areas 140-149; the State
Distribution Center for third class letters and flats for zip codes areas 130-149; the Mail Processing Center
for all 17 stations and branches in Buffalo; and the Sectional Center Facility for 104 Associate Offices. The
GMF serves as Parcel Post Distribution Center  for zip code areas 130-149; parcel post daily volume
averages about 24,000 pieces.

        In addition, all mail from the eastern seaboard destined for Canada is routed through the Buffalo
GMF.  As a major entry  point to and from Canada, Buffalo GMF provides space in the lobby and on the
workroom floor to U.S. Customs and serves as a concentration  center for mail transportation equipment.

PURPOSE AND BENEFITS OF POLLUTION PREVENTION

Prior to developing and  implementing a pollution prevention program, it  is imperative that a facility fully
understand pollution prevention and its components. The following sections  describe the goals, concept,
and  benefits of pollution prevention and the procedure for conducting an opportunity assessment similar
to those conducted under this project. The USPS has a series of pollution prevention related guides: Waste
Reduction  Guide  (AS 552),  Recycling Guide (AS 550), Stormwater Management Program Guide, and
Hazardous Waste Guide (AS 553).   These USPS guides  contain step by step assessment procedures,
suggested pollution prevention best management practices and technologies, and helpful worksheets. They
also explain USPS pollution prevention policies and waste reduction goals.  A comprehensive USPS facility
pollution prevention program will incorporate the policies, plans and programs contained in these USPS
documents.

-------
Pollution Prevention - Goals

        The ultimate goal of pollution prevention is to reduce present and future threats to human health
and the environment.  Pollution prevention is any  practice which reduces the amount of any hazardous
substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment
(including fugitive emissions) prior to recycling, treatment, or disposal; and any practice which reduces the
hazards to public health and the environment associated with the release of such substances, pollutants,
or contaminants (Pollution  Prevention Act of 1990).  Pollution prevention is a fundamental shift from
treatment of wastes.  Source reduction does not include any practice which alters the physical, chemical
or biological characteristics of the volume of a hazardous substances, pollutant, or contaminant through a
process  or activity which itself is not integral to and necessary for the production of  a  product or the
providing of a service.

        Pollution prevention is  a multimedia approach that minimizes or eliminates pollutants released to
land, air, and/or water without simply shifting pollutants from one media to another. Pollution prevention
is accomplished  by equipment or  technology  modifications;  process or  procedure  modifications;
reformulation or redesign of products; substitution of raw materials; and improvements  in housekeeping,
maintenance, training, or inventory control.

        Pollution prevention is the environmentally preferable option in the waste management hierarchy.
Pollutants that cannot be prevented should be recycled in an environmentally safe manner. Pollutants that
cannot be prevented or recycled should be treated in an environmentally safe manner.  Disposal or other
release into the environment should be utilized only as a last resort and  should be undertaken in an
environmentally safe manner.

        Recycling is using,  reusing, or reclaiming materials/waste, including processes  that regenerate a
material or recover a usable product from it (USEPA.  Facility Pollution Prevention Guide). There are many
ways materials can be reused  or reclaimed.  Reusing products, such as reusable beverage containers,
results in decreased  purchases  of raw  materials  and  reduces pollutants generated from making  new
products.  Offsite recycling is often affected by exterior influences, such as  market prices for recycled
products and availability of reclamation technology.

Pollution Prevention - Benefits

        Facilities gain both direct and indirect benefits by implementing pollution  prevention options as
demonstrated in the following benefits defined in the  U.S. Postal Service Waste Reduction Guide.

The Postal Service will benefit from waste reduction by:

        •       Significantly reducing the amount of  pollution released to the environment

        •       Obtaining reductions faster than might be achieved by waiting for statutes or regulations
               to take effect and by achieving permanent solutions where source reductions occur

        •       Providing the flexibility to choose cost-effective and environmentally sound solutions that
               will also result in improved efficiency and net economic growth

        •      Creating clear expectations in the form of a national goal for targeted chemicals

        •      Providing positive incentives through public recognition of its efforts and by working to
               identify regulatory barriers

        •      Saving capital

-------
        •      Minimizing paperwork                                               '

        •      Reducing liability                                                   ;

               Possibly changing the status of facilities that generate hazardous waste from Urge Quantity
               Generator to Small Quantity or Very Small Quantity Generator status

        •      Reducing long-term risks of an uncertain nature and scope-such as the cumulative effects
               of toxic substances-without waiting for research


        The analyses of source reduction and recycling options in this report focus primarily on the direct
 benefits to the Buffalo facility in savings in disposal, operational, and procurement costs.  However, the
 indirect benefits of pollution prevention may be equally significant. One indirect benefit is reduced liability.
 The USPS will lower its liability under Research Conservation and Recovery Act's (RCRA's) "cradle to grave"
 provisions and the provisions of the Federal Comprehensive Environmental Response, Compensation, and
 Liability Act (Superfund).  The RCRA and Superfund "cradle to grave" provisions stipulate that a generator
 remains responsible for all environmental damage resulting from its waste including damage that occurs after
 disposal.  Even the disposal of small quantities of hazardous wastes to a Superfund site could result in the
 Institution being responsible for costly future cleanup. Having less hazardous or toxic materials onsite will
 also mean reduced occupational hazards, and, therefore, improved worker health and safety. Finally, a
 pollution prevention program can generate good will in the community and workplace, enhance the USPS's
 public image, and foster environmental awareness among  employees.  By decreasing the amount of
 hazardous waste shipped offsite for disposal, the USPS may also reduce the costs associated with tracking
 and filing paper work required for hazardous waste manifests.

 Pollution Prevention Opportunity Assessment Procedure

        In general, this project follows the EPA procedures outlined in the Waste Minimization Opportunity
 Assessment Manual (EPA/625/7-88/003) and is consistent with the concepts contained in EPA's Facility
 Pollution Prevention Guide  and shown in Figure 1.  These  procedures are consistent with   the waste
 reduction approach contained in the United States Postal Service publications Waste Reduction Guide (AS
 552), Stormwater Management Guide.  Recycling Guide (AS 550) and Hazardous Waste Guide (AS 553).
 These USPS  guides contain step-by-step assessment  procedures, suggested pollution prevention best
 management  practices and  technologies,  and  helpful worksheets.   They also explain USPS pollution
 prevention policies and waste reduction goals.

 Pollution  prevention opportunity  assessments  have  four  phases:  1) planning and  organization, 2)
 assessment, 3) feasibility analysis, and 4) implementation (Figure 1). During the planning and organization
 phase, a commitment from management is ensured, overall assessment goals are set, and the assessment
 program task force is organized. The assessment phase involves quantifying current waste generation and
 management  practices, including collecting  process  and facility data, setting  priorities and selecting
 assessment targets, selecting assessment team members, reviewing data, generating options, and screening
 and selecting options for further study. The feasibility analysis  phase is a technical and economic evaluation
 of the selected options. Options are ranked and selected for implementation The implementation phase
 puts the options into action. This may require justifying projects and obtaining funding, installing equipment,
 implementing procedures, and evaluating the performance of each option. This report covers the first three
steps and provides the framework for implementation.

-------
                                     Establish Pollution Prevention Program
                                              • Executive Level Decision
                                           •  • Policy Statement
                                    	. Con»en«u« Building	
                                                Organize Program
                                                 • Name T«k Fora
                                                 • State Goal*
                                           Do Preliminary Assessment
                                                • Collet Data
                                                • Review She*
                                                • EataMiah Priorities
                                              Write Program Plan
                                              •  Conelder External Group*
                                              •  Define Objective*
                                              *  identify Potential Obstacle*
                                              »  Develop Sehedul*	
                                            Do Detailed Assessment
                                            • Mam Amianant Taamd)
                                            • Rtvkw 0«* md Sit»U)
                                            • Orqante* aid Document Information
                                       Define Pollution Prevention Options
                                                * PrepoM Option*
                                      	» Ber»en Options	
                                             Do Feasibility Analyses
                                                • T*chnio*J
                                                • Environmental
                                                * coonuci MC
                                            Write Assessment Report
                                               Implement the Plan
                                                  • S*l*ot Project*
                                                  • Obtrin Funding
                                                  « Install	
                                                Measure Progress
                                                  • Aoquir* Data
                                                  * Analvia Results
                                                      alyial
                                     Maintain Pollution Prevention Overview
Figure 1.  Pollution Prevention Opportunity Assessment Procedure.

-------
 WASTE QUANTITIES AND DISPOSAL COSTS                                        '.

 Determining the composition and quantity of waste provides a baseline description of waste type, quantity.
 and waste management costs.  This baseline information is used to identify the major wastes and evaluate
 source reduction and recycling opportunities. To determine the composition of the waste stream and waste
 generation rates,  the assessment team reviewed purchasing records and private waste hauler payment
 records, interviewed USPS employees, and made direct observations of waste container contents.  Direct
 observation of the  compactor contents was not possible due to access and safety concerns.   Waste
 generation rates and costs are estimates because complete information was not available. The purchasing
 records and waste hauler bills, although incomplete, were the best source of information on waste quantities
 and disposal costs.  Beyond total waste tonnage, very little data were available to quantify the individual
 waste streams generated within the GMF.

 Waste Generation

        Solid waste from GMF operations is collected from individual generation sites and placed into a 40
 cubic yard trash compactor. Before September 1992, the compactor was typically emptied (or "pulled")
 twice weekly by a commercial waste hauler, Downing Container Service, who delivers the waste to the
 Niagara Energy Complex, a waste to energy incinerator operated by Occidental Chemical.  Compactor
 contents are not monitored, so the contents of each pull has been estimated.  One full year of waste hauler
 bills were examined. The bills indicated that 507 tons of waste were collected from the GMF compactor
 from September 1991 through August 1992 and the average pull weight during that one-year period was 4.78
 tons.  Downing charges the USPS $405.20 for each compactor pull, or approximately $85 per ton. The
 annual charge for the collection and disposal of the GMF waste was approximately $43,000.

        In August 1992, the GMF began separating cardboard from the waste stream and collecting it for
 recycling.  Recycling cardboard significantly reduces the waste quantity disposed of in the compactor.
 Cardboard recycling has only been in place for a short period of time, but the annual quantity of cardboard
 diverted is estimated to be 253.5 tons. Due to the limited quantity of cardboard collection data available,
 this is a rough estimate. The actual quantity may be  significantly higher.

        Scrap metal (20 to 30 tons/year)  is collected separately in a 40  cubic yard  dumpster. This
 dumpster is removed once every two weeks at no cost by a private metal refining (smelting) company.
 Aluminum cans are also collected separately and returned for a refund of $0.05 per can. Aluminum can
 collection containers are placed throughout the GMF and approximately 1200 pounds (0.6 tons) of aluminum
 are collected annually.

        The components of the GMF waste stream are listed in Table 1. The exact composition and relative
 contribution of different waste types to the total annual  waste stream is unknown.   Figure  2 presents
 estimated waste quantities for the total GMF waste stream (excluding CFS/UBBM and cafeteria).  These
 values are based on review of worksheets completed by USPS employees, interviews with USPS employees,
 review of waste hauler records, and best professional judgement.

        Approximately 253 tons of corrugated cardboard is generated annually. Other major wastes include
 plastic film such as shrink wrap, stretch wrap and bags (13 tons) and mixed office paper (23 tons). It should
 be noted that of the 537 tons of waste generated annually, only 345 tons of the waste is identifiable (see
 Figure 2).  The "missing" tonnage may include corrugated plastic containers, pallets, aluminum, or metals
 improperly discarded instead of recycled. Furthermore, disposal of many materials, such as pallets, plastic
film, and corrugated cardboard, at the Buffalo facility is not easily monitored, consequently waste quantities
of these materials  may have been underestimated.

-------
Facility maintenance operations  generate used  oil and waste  parts  cleaning solvents as well as
miscellaneous cleaning and painting related wastes. Oil and used parts cleaning solvents are managed as
hazardous wastes.
                     TABLE 1.  COMPONENTS OF THE GMF WASTE STREAM
  Classification
 ^^^^^••^^•^"••"••"••••••i^
  Major components
  Minor Components
  Potentially hazardous components:
Specific Components
   OCC - old corrugated cardboard boxes and cartons

   Plastic film •  shrink wrap, stretch wrap and bags

   Plastic strapping

   Corrugated polypropylene boxes

   Pallets: plastic, pressed board and pine or hardwood

   Computer paper

   Mixed office paper

   Metals: machine parts, broken carts etc.
   Floor sweepings, primarily rubber bands and mixed
   colored paper

   Employee wastes • paper towels, polystyrene cups, fast
   food packaging, food waste, cigarettes

   Aluminum cans

   Laser printer toner cartridges
   Residue left in high density polyethylene bottles from inks,
   solvents and cleaning products

   Aerosol cans

   Parts cleaning solvents

   Paints and painting solvents
                  «

   Used oil
Operations Generating Waste

    There are four areas of the GMF which generate a majority of the facility's solid waste: the unloading
and loading docks, the mail sorting floor, the offices, and the facility maintenance. Auxiliary facilities such
as the cafeteria, the Computer Forwarding Systems (CFS)/ Undeliverable Bulk Business Mail (UBBM), and
the cafeteria, also have significant waste streams. The operations generating waste from each of these areas
and auxiliary facilities are discussed below.

-------
                                                 Cardboard 47%
    Computer Paper 0.4%

  Mixed Office Paper 8.5%

     Aluminum Cans 0.1%
          Other Metals 5.6%
               Plastic Film 2.4%
                                                         Undetermined 36%
                                      Total 537 tons
                WASTE STREAM
QUANTITY
  Cardboard
  Computer Paper
  Mixed Office Paper
  Aluminum Cans*
  Other Metals*
  Plastic Film
  Undetermined
253.5 tons
  2 tons
  46 tons
  0.6 tons
  30 tons
  13 tons
191.9 tons
*  These solid wastes were recycled throughout the period studied.
                          Figure 2. Estimated Solid Waste Generation.
                                USPS Buffalo GMF, 1991-1992

-------
Unloading and Loading Docks

        Mail is delivered to the GMF aboard trucks in packaged lots. The lots are unloaded onto the dock
and  transferred  inside where they are sorted, processed,  repacked and sent to a final  destination.
Corrugated cardboard, corrugated plastic, shrink wrap, stretch wrap, plastic strapping, and paper wastes
are generated during the unloading and  internal movement of incoming mail.  The plastic shrink wrap,
stretch wrap, and strapping wastes are generated from the pallets of incoming mail. Pallets (wood, wood
composite, and plastic) are used throughout the facility.  Pallets of outgoing mail are shrink-wrapped in the
handling area; the outgoing shrink-wrapped pallets produce waste for disposal by the receiving Associate
Offices (AO). Deliveries of supplies and materials are a primary source of corrugated cardboard.

Mail Sorting Floor

        Mail is moved from the unloading dock to the sorting floor. The wastes generated from the mail
sorting floor operation include rubber bands, paper, damaged corrugated cardboard and plastic trays and
floor sweepings.  A significant source of cardboard waste is the corrugated cardboard trays used in mail
distribution from the receiving dock to and within the mail processing area. Corrugated polypropylene boxes
are also used for internal distribution.  Computer printouts with carbon paper inserts are generated on the
mail sorting floor.  In addition, metal wastes (e.g. machine parts, broken metal cages)  and empty plastic
bottles from inks and solvents are generated during operation and maintenance of the sorting and canceling
machinery-  A container for collection of metal for recycling is located  in one corner of this area. Wastes
generated by employees in break areas, locker rooms and rest rooms include coffee cups, napkins, straws,
food, and paper towels.  Aluminum beverage cans are collected for recycling in  break areas.

Offices

        Substantial amounts of mixed, colored paper and white and green bar computer printouts are
generated by offices, such as Support Services. Individual work stations within the office building generate
the majority of the paper waste  from the GMF. The 128 person office and maintenance staff use thirty-six
printers and eight copy machines.  In addition, colored paper slips are  used to mark the destination within
the facility of boxes of mail for internal distribution.

Facility Maintenance

        The carpentry shop generates wood waste such as sawdust and scrap wood while the metal shop
generates scrap metal.   Facility maintenance also generates  plastic bags, plastic bottles and aerosol
cans/wastes from the disposal of cleaning supplies. Hazardous waste generated from facility maintenance
activities include paint wastes,  parts cleaning solvent (petroleum naphtha), used oil,  and miscellaneous
chemicals such as WD-40 and  cleaning compounds.  The exact quantity and composition of hazardous
waste generated at the GMF are unknown.  The major hazardous wastes are parts cleaning solvents and
used oil. Technicians clean parts using petroleum naphtha in solvent sinks.  The wastes are spent solvents,
a RCRA hazardous waste, and volatile organic compound  (VOC) emissions. The Postal Service contracts
with a commercial  service that leases and  maintains the  solvent sinks,  removes spent solvent, and
replenishes the sinks with fresh  solvent every six weeks at an annual cost of $569.

        Based  on a  waste solvent generation  rate of 20 gallons  every 6 weeks for a  52 week year,
approximately 170 gallons of waste solvent are generated annually.  Used oil from letter sorting and other
machinery is collected and transported to  the VMF where it is stored with VMF generated waste fluids prior
to removal by a commercial waste hauler.

-------
 Computer Forwarding Systems/Undeliverable Bulk Business Mall Facility

        All  undeliverable  mail  is  sent  to  the  facility  housing the  CFS  and the  UBBM  operations.
 Undeliverable first class mail is routed to the CFS section.  A computer search is performed to locate a
 forwarding address and a new address label is applied to the letter or parcel.  The readdressed mail is then
 sent on to its destination.  A very rigorous and thorough process is employed to locate a usable address.
 If an address cannot be located after this exhaustive effort, the mail is discarded. The Supervisor of trie CFS
 examines each piece of undeliverable mail and its "paper trail" prior to disposal to ensure that all possible
 effort has been made to deliver the item.

        UMMB (magazines, advertisements, promotional materials) is routed to the UBBM section.  Bulk
 business mail may be undeliverable because the resident or business has moved or because the sender
 delivered too many copies. The UBBM section staff determine if the addressee has requested second and
 third class mail to be forwarded, if so, the mail is forwarded. If no such request has been made, the UBBM
 is discarded.  Private direct marketing firms or private mailing companies often mail to all residents in a
 specific geographic area.  If the marketing firm  sends more copies than there are residents, the excess
 copies are delivered to the UBBM section where they are reviewed prior to disposal.

        Major waste streams from the  CFS/UBBM facility include  undeliverable mail, magazines and
 promotional materials,  label backing paper,  and  corrugated cardboard. Waste is disposed of into a four-
 cubic yard container that is collected twice weekly by Clinton Disposal Service at a cost of $23.09 per pull
 or $46.18 per week. Annual cost for collection and disposal from this facility is $2,401.36.

 Cafeteria

        Canteen Corporation operates the onsite cafeteria under  contract to the USPS. Canteen has
 contractual responsibility for the cafeteria's waste disposal. The cafeteria has already established corrugated
 cardboard and kitchen  grease recycling.  Principal wastes generated by this operation include food wastes,
 corrugated cardboard,  polystyrene plates, bowls and  cups, #10 bi-metal steel cans, one gallon translucent
 high density polyethylene (HOPE) jars, and paper. The cafeteria has three waste containers: an eight cubic
 yard container for recyclable corrugated cardboard, an eight-cubic yard garbage dumpster collected four
 times each week, and a container for recyclable grease. Annual collection costs are: $300 for the cardboard
 ($25 per month) and $6,800 for the eight-cubic yard  garbage container-($650  per month or just over $40
 per pull).  No data on the  grease recycling container was provided.

 SOURCE REDUCTION AND RECYCLING OPTIONS ASSESSMENT

        The Buffalo USPS employees have undertaken or will enact in the near future a number of source
 reduction and recycling activities.  The Buffalo GMF recycling program includes collecting old corrugated
 cardboard, ferrous metal, aluminum, and UBBM mail, and laser jet printer cartridges, and office paper for
 recycling.   Additionally, the USPS maintenance department is  investigating replacing paper  towels in
 washrooms with electric powered air hand  driers. The assessment identified other pollution prevention
 opportunities that build upon and expand the current pollution prevention activities.

 Existing Source Reduction and Recycling Activities

        A brief discussion of existing source reduction and recycling actions underway at the Buffalo GMF
follows.  Some  of these  activities were ongoing at the time of  the assessment.   Others have been
implemented as a result of the assessment site visit and preliminary findings.
                                               10

-------
Corrugated Cardboard Recycling

        The Buffalo GMF employees began recycling cardboard in (ate August, 1992.  A local recycling
company is providing the trailer to store the cardboard and pick up the cardboard at no cost to the Postal
Service. The GMF employees estimate they will collect approximately 253.5 tons of cardboard per year.
By separating the cardboard for recycling instead of disposing of it in the compactor the GMF has been able
to reduce the number of compactor pickups from twice a week to once every three weeks. The reduced
pickups are projected to save $34,000 per year in avoided disposal costs. Separating the cardboard versus
throwing it into the compactor has not required additional manpower. In fact, USPS personnel estimate that
recycling cardboard will require less labor since placing the cardboard in a trailer is more time efficient than
placing it in the compactor.

Ferrous Metal and Aluminum Recycling

        Scrap metal (20 to 30 tons/year) is collected for recycling from both the GMF and the VMF.  The
scrap metal is picked up by a private metal refining (smelting) company. Aluminum cans are also collected
throughout the GMF.

UBBM Mail

        The USPS has resumed separating UBBM mail for collection by a paper recycler. In the past UBBM
was collected for recycling, however, this service was discontinued by the hauler, reportedly due to poor
paper markets.  The USPS contacted the waste haulers, who agreed to restart UBBM collection. The hauler
will provide the trailer and pickup at no cost to the USPS.

Laser Jet Printer Cartridges

        The GMF currently recycles about five laser printer cartridges each month through TC Technologies,
860 Englewood Avenue in Buffalo. Empty cartridges are cleaned and recharged by the distributor.  The
USPS purchases the refurbished cartridges for reuse. Annual savings amount to $1,740 with approximately
60 cartridges recycled per year.  The Postal Service pays $49 for each recharged cartridge compared to
$78 to purchase a new cartridge, a savings of $29 per cartridge.

Office Paper Recycling

        Recycling efforts will be expanded to include mixed office paper and computer paper by the end
of September 1992. The mixed paper will be picked up by a recycler at no cost to the USPS. The USPS
may be paid for the  computer paper, depending on the local market, or it also will be picked up at no cost
to the USPS. The Buffalo GMF staff plans on expanding the recycling program to the AOs. As the GMF
staff gains experience with the recycling program they will begin backhauling cardboard, mixed paper, and
computer paper from the AOs to the GMF for collection by recycling companies. Separating out cardboard
from the AOs waste is expected to save $18,000 per year in reduced disposal costs.

Electric Powered Hand Driers

        Heightened attention to waste management and pollution prevention has paid off in additional
potential savings. As a result of the assessment process, the USPS staff investigated raw materials and
disposal costs for paper towels in the GMF and associate branch washrooms. The USPS spends $48,000
annually for paper towels used in the washrooms at the Buffalo GMF and Station branches. An additional
$2,000 is spent for disposal of the used towels. Buffalo GMF maintenance staff investigated replacing the
paper towels with electric powered air hand driers.  Buffalo  GMF employees determined they can replace
and install the new driers at the GMF and Station branches for a total  of $50,000.  This would eliminate the

                                              11

-------
 use of  paper towels at an annual savings of approximately $50,000. minus electricity 
-------
                      TABLE 2.  POTENTIAL SOURCE REDUCTION OPTIONS
         Waste                      Sources
        ——^—		r-	
Corrugated containers     Deliveries and internal
                          distribution
Paper



Plastic film

Plastic strapping

Pallets


Rigid plastic containers

Oils, adhesives, paints

Cafeteria Wastes
Individual work stations,
printers, copy machines,
internal distribution

Receiving dock and shipping
dock
Receiving dock and shipping
dock
Receiving dock and shipping
dock

Cleaning, maintenance
products and food service
Building maintenance

Food packaging
 Reduction Mechanisms
^MBn^^^__H^H^_^^H1H>.MHHB^^^_^^K^BH
 Advise vendors of reduced
 packaging specifications, use
 permanent distribution
 packaging, and reuse of
 packaging
 Initiate a duplex copying policy,
 duplex printing, and distribution
 policy, and reusable colored
 tags
 Use reusable containers

 Use reusable containers

 Eliminate wood and pressed
 wood pallets, specify only long
 life, reusable plastic pallets
 Require bulk deliveries in
 refillable containers
 Improve inventory control and
 housekeeping practices
 Give  customer discounts for
 using their own mug for
 beverages, make specification
 that only  reusable food service
 materials (e.g., plates and
 bowls) be used
                                               13

-------
                         TABLE 3. POTENTIAL RECYCLING OPTIONS
Waste
           Potential Recycling Market
Corrugated polypropylene
Paper
Plastic film
Plastic strapping
HOPE  containers (translucent)
HOPE  pallets
Pressed wood pallets

Polystyrene food service
Food waste
           Container manufacturer
           Local paper dealers
           Local plastic film manufacturer
           Local plastic film manufacturer
           Local recycling facility
           Pallet manufacturer
           Pallet manufacturer and local composting
           operation
           Recycling facility located in New Jersey
           Composting operations and donate to food
           banks
                      TABLE 4. GENERAL WASTE REDUCTION OPTIONS
             Method
                      Mechanisms
Procurement

Waste Stream Characterization
Study
Bulk mail/magazines

Water and Energy Conservation
Improved Waste Management Cost
Tracking
New Specifications
Employee Participation

Public Education
Purchasing policy for recovered content materials and
products
Perform waste composition study to base future
recommendations
Alternative pricing based on life cycle analysis of revenue from
bulk mailing to cost of disposal of undeliverable mail
Establish a comprehensive water conservation program

Inspect and repair toilets and sinks

Continue energy efficiency efforts to install fluorescent lighting
and interior storm windows
Establish separate account number for hazardous and solid
waste management costs

Charge waste management costs to generating department
Initiate new specifications for USPS goods
Educate employees on pollution prevention and source
reduction
Educate customers on effective waste management
                                            14

-------
Plastic Corrugated Containers

        Corrugated polypropylene containers are not widely collected for recycling at this time. However,
one manufacturer, Mills Industries, Inc. of Laconia, New Hampshire, stated that a consistent quantity of these
containers could potentially be recycled back into the same product.  The Postal Service may wish to
discuss this  option with the company that supplies the  containers or conduct further research into
establishing a market for recycling them. Appendix B includes the contact for Mills Industries, Inc.

Paper

        Paper waste can be reduced through a number of source reduction methods. Computer paper and
white office paper can be recycled.  Appendix B  contains contact information for local paper recycling
companies.

Duplex Copying

        The purchase price for a basic copy machine with duplex copying capability is no higher than a
machine with only single-sided capability. Whether the copies are on one side of the paper or two, the cost
to operate the machine is the same. Copier charges are based on the information scanned and duplicated;
for either single or duplex copies, the machine scans and reproduces the same amount of information.
Savings are realized in the amount of paper used.  Duplex copying can reduce paper expenditures by up
to 45 percent.  Double-sided copiers could be phased in as new machines are purchased.  Management
should establish and actively support a duplex photocopying policy.

Duplex Printing

        Printers that print on both sides of the paper are also available. Sometimes, existing printers can
be programmed to produce duplex copies.  Most  documents can be printed on both sides of the paper,
reducing paper purchases as well as paper waste.

Distribution Copies

        Paper waste can be reduced  by  limiting the number of copies of documents for distribution.
Consideration should always be given to whether multiple copies are necessary. For example, the computer
printout with carbon could be replaced with a recyclable, pressure sensitive NCR paper if multiple copies
are necessary or with a single sheet, recyclable computer paper if only one copy is needed. In many cases,
a single circulation copy can be passed on from one staff member to the next.  In addition, by using a
simple cover sheet containing the names of the appropriate individuals, supervisors can readily direct a
single document to a circulation list rather than requesting multiple distribution copies.

Replace Disposable Paper Markers with Reusable Markers

        Reusable rigid plastic or metal cards could be used to replace the colored paper destination slips.

Recycle Paper

        Recyclable computer printout, sorted white ledger and mixed colored ledger grades are generated
within the GMF. Local paper dealers will pay from $10 to $60 per ton for source separated computer paper
or will collect a mixed paper stream at $0 return. The recyclable paper would require separate collection
and storage.  GMF maintenance staff and other employees should be involved in the determination of how
many categories of paper separation are feasible and how to maximize the efficiency of a collection system.
The paper will have to be source separated at each desk, printer and copying machine and then collected

                                               15

-------
for separate storage.  Two local paper dealers are willing to place a container on site for paper and OCC
at no cost to the Postal Service (see Appendix B).

Plastic Film and Strapping

        Most plastic film (shrink wrap, stretch wrap) and strapping (polypropylene in an assortment of
colors) discarded within the GMF is removed from incoming mail.  The Buffalo facility must pay to dispose
of the material.  Mail shipped from Buffalo to AOs is shrink wrapped within the GMF, producing a disposal
issue for the AOs.  Plastic film purchases and wastes could be eliminated or severely reduced by switching
to reusable cloth or net bags, wheeled bins or metal cage containers for mail redistribution. Many of these
kinds of containers are already in use in the GMF and other Postal Service facilities.  Specifying reusable
containers for mail distribution could substantially reduce or even eliminate these wastes.

Recycle Plastic Shrink Wrap

        The  Rochester, New York Post Office is currently recycling shrink wrap,  stretch wrap and other
plastic bags and films through the local Mobil Chemical Company manufacturing facility. Mobil will pay the
GMF $.11 per pound for this material including pick up at the GMF, or $.12 per pound if the shrink wrap is
delivered to Rochester. The USPS could easily use its own transport equipment to arrange delivery of
plastic film to the Rochester Post Office where it could be consolidated with plastic collected by that facility.

Pallets

        At present, the Buffalo GMF uses three different kinds of pallets: pine, pressed  board and plastic.
The plastic pallets cost approximately $20 apiece; pressed wood pallets cost only $7  each.  The Postal
Service no longer purchases pine pallets,  although many were in evidence during the  assessment.
Deliveries to the GMF are made on pine pallets which are then reused by the Postal Service.

Replace Wood and Pressed Wood Pallets

        Plastic pallets, while more expensive to purchase initially, are more durable than wooden pallets.
Charles Aldred, USPS Program Manager for Mail Transport Equipment, reports that the  USPS Engineering
and Development  Center estimated a life of 50 trips for each  plastic pallet compared to  a five or six trip
average life for each pressed board pallet. Based on useable life, a plastic pallet would cost approximately
$.40 per trip;  the pressed wood pallet would cost between $1.17 - $1.40 per trip.

        Many wooden pallets  arrive as deliveries to the USPS.  The USPS does  not have to pay for the
purchase of these  pallets, but currently pays for their disposal. Purchasing only the durable plastic pallets
and eliminating the other two materials could reduce overall purchase and handling costs and reduce the
number of pallets requiring disposal, thereby reducing disposal costs.

Recycle Pallets

        The USPS purchases plastic pallets from Cadillac Products, inc. of Sterling Heights, Michigan. The
pallets are made from HOPE using twin sheet thermal forming. The HOPE has the potential to be recycled
back into new pallets.  The broken pallets are already separated and stacked for disposal within the GMF.
The  USPS should  complete a cost benefit analysis to  determine the advantages and disadvantages  of
returning these pallets to the manufacturer to be used as feedstock for new pallets. In addition, the Postal
Service can specify recycled content in all pallets.
                                                16

-------
Pressed Wood

        The USPS annually  purchases between  1.5 and 1.8 million  pressed wood pallets from Litco
International, Inc. of Vienna, Ohio. Mick Marsh of Litco International stated that the Postal Service required
Litco to perform a number of studies to determine the potential end uses of discarded pressed wood pallets.
Based on these analyses, Litco offered the USPS a contract under which Litco would take back and either
recycle or burn as fuel all the pallets sold to the Postal Service. However, the USPS has not acted on this
offer and continues to pay for local disposal of the pallets.

        Litco and the Agriculture Department of Ohio State University also performed extensive composting
studies and found that the pressed wood pallets can be safely composted.  Jim Rusiniak of the Buffalo GMF
indicated an interest in composting wood waste.  The Postal Service should complete a cost benefit analysis
to determine the advantages and disadvantages of the recycling and disposal options available for these
pallets.

Rigid Plastic Containers

        The USPS purchases cleaning and maintenance supplies as well as food service products in rigid
plastic containers.  Since there is a consistent,  long-term need for these products, the USPS should
investigate purchasing these  products in refutable  bulk containers.

Recycle Plastic Containers

        The GMF generates bottles from a variety of cleaning and maintenance products. U.S. markets for
clear and cloudy, unpigmented HPDE plastic are  paying between five and eight cents per pound.  Since
metals are already collected in a separate basket in the mail processing area, employees could be trained
to separate the translucent HOPE bottles into a separate small dumpster. A local recycler could service the
dumpster on an "on call" basis,  initially.  Once the quantity of HOPE in the waste stream  is identified, a
collection schedule could be developed.

Other Recycling Options

        The Postal Service could also explore recycling  options for materials including:

        •       aerosol cans

        •       fluorescent lights including the mercury ballasts (non-PCB)

        •       other non-container glass such  as windows and light bulbs

        •       additional metals

        •       freon in air conditioners


Building Maintenance Waste

        Facility maintenance  staff perform a variety of operations that use hazardous materials or generate
hazardous waste. These include painting, boiler room maintenance, and machinery repair and maintenance.
The store room (room B8) houses oils, grease, cleaning compounds, and adhesives.  During  the site visit,
the store room exhibited signs of neglect.  Drums and material were stored in  an unorganized manner,
                                                17

-------
unauthorized material (gasoline) was being stored; oil and grease spills were evident; material was stored
in unlabeled containers; and the expiration date of limited shelf life material was not recorded.

Inventory Control and Better Housekeeping Practices

        Strict inventory control procedures and good housekeeping practices can reduce waste caused by
expired  materials, spills and over-stocking. The following steps are recommended:

        •      Designate one employee as the Supply Manager (the Parts Manager is a typical choice) to
               be responsible for approving and ordering materials and ensuring that the supply room is
               kept neat and orderly. The Supply Manager checks the existing inventory to make sure that
               the item is not in stock prior to ordering or supplying the  material.

        •      Control access to the supply room by allowing only the Supply Manager to distribute the
               supplies to  the technicians.

        •      Keep liquid  stock on lower shelves to minimize contamination of other stock and prevent
               product loss from accidental falls.

        •      Clearly label all containers with their contents and expiration date. For example, a number
               of containers of adhesive compound were noted during the site visit. The adhesive has a
               shelf life of one year from the date of purchase. However, there was no purchase date on
               the adhesive containers so it was not evident whether the material had exceeded its shelf
               life. Purchase records should be reviewed to determine when the material was purchased.
               If it has been over a year, the company, supplying the adhesive should be contacted to see
               if they will take back the expired material. Expired materials can sometimes be reworked
               into new product at the manufacturing plant.  If the adhesive can not be returned, the GMF
               should determine if the  material is hazardous by  contacting the manufacturer.  If it  is
               hazardous,  it should be disposed of according to all appropriate state regulations.

        •      Distribute stock through "first-in, first out" practice - this is, the oldest  material should be
               used first.

        •       When possible, buy in bulk and pour materials into smaller containers for use in the shop
               using careful transfer procedures. All containers and drums should have self-closing, non-
               leak, safety  spigots for easy distribution and spill prevention.  Currently oil is dispensed
               from 55-gallon drums placed on their sides through a spigot.  Buckets and drip pans are
               used to collect the spilled oil. To prevent spillage of dripped oil the drums should be turned
               vertically and oil should be dispensed using a hand pump similar to the method  by which
               the material is dispensed in the VMF.

        •       Perform routine storage area inspections.

        •       Train technicians to maintain the smallest practical amount of hazardous materials in their
               work areas.

        •       Keep lids  on all drums to prevent potential spills.

        •       Have spill  control equipment available and ensure that employees know its
               location and proper use.

       •       Use excess  paint as a primer or base coat rather than disposing of it.

                                               18

-------
        •      Use water-based latex paints  in place of solvent-based paints when
               possible.


Cafeteria Wastes

        Bulk deliveries of beverages are made in "bag in box" containers. While minimizing individual
container disposal, these are not the most efficient bulk containers from a waste management perspective.
Permanent, refillable containers would eliminate this waste.

        To encourage employees to think about waste reduction, the cafeteria could offer a reduced price
on beverages if the customer brings his or her own mug. Perhaps a five cent discount would encourage
Postal Service employees to participate.  The Postal Service or Canteen might consider selling or giving
away reusable mugs with a Postal Service logo.

        The cafeteria presently recycles cardboard and kitchen grease.  The principal cafeteria waste is
polystyrene food service (e.g.  plates and trays).  Markets  for polystyrene recycling  have increased
substantially in recent years.  The USPS should consider modifying the cafeteria contract to require recycling
of this material as well  as food and beverage containers, if economically viable markets exist.  Or, through
the contract mechanism, the Postal Service could prohibit the use of disposable items and  specify the use
of washable, reusable food service and the installation of a dishwasher.

        Other materials for which viable recycling markets exist include the #10 steel cans and translucent
HOPE jars in which foodstuffs are delivered. These materials are easily separated in the kitchen, and local
recycling markets are available.

        Canteen could explore a composting option for the food waste and paper products. Garrett Dolan
or Jim Gilbert at the New York State Department of Economic Development in Rochester can provide
contacts and assistance. Also, the New York State Department of Environmental Conservation, Division of
Solid Waste,  Region  IX has  a Buffalo office  that  maintains records of local markets for recyclable
commodities. Another method of reducing food waste is  by donating excess food to a  local homeless
shelter or food bank.

General Waste Reduction Options

Procurement

        To comply with the Resource Conservation and Recovery Act, Section 6002, Federal Procurement,
and  Executive Order 12780, October,  1991, Federal Agency Recycling and the Council of Recycling and
Procurement Policy, the USPS has begun to develop an Affirmative Procurement Program. The GMF could
establish vendor certification and internal and external promotion of a purchasing policy to give preference
to products and materials with recovered content. These procurement policies potentially increase the
possibility that products and packages will  be manufactured with recovered material, thus reinforcing
markets for the materials the Postal Service will be recycling.  Procurement specifications for paper and
paper products, retread tires, rerefined lubricating oil, building insulation products, and cement and concrete
should reflect EPA guidelines.

        The  Buffalo GMF is authorized to establish voluntary standards for procurement of other items
manufactured with recovered materials.  For example, GMF purchasing staff could review procurement
specifications to eliminate any that discriminate against products containing recovered material.  Employees
and vendors should be aware that all paper products, from white ledger to toilet tissue can be purchased


                                               19

-------
 with recovered contents.  This procurement policy should extend to contractors including the cafeteria,
 which should order napkins and other paper products with 50 percent recovered content.

        The USPS  could use procurement as a tool to support the development of pollution prevention
 programs. Specifications and standards that give preference to virgin materials or materials that cannot be
 reused or recycled should be eliminated. The USPS could develop a policy giving preference to non-toxic
 products, whenever performance and safety standards can be met. While the Postal Service is reviewing
 specifications related to the Procurement Guidelines, a more general  review of procurement  policy is
 recommended.

        A policy that gives preference to non-toxic products and packages would facilitate changes in USPS
 procurement specifications that could reduce the toxicity of the waste stream. For example, USPS could
 specify non-aerosol containers for cleaning and maintenance products, except those specific applications
 for which no non-aerosol exists.  The propellents used in pressurized aerosols are primarily butane and
 propane,  both of which are generally  toxic;  in most cases, pump spray or liquid products could be
 substituted. This procurement policy would effectively reduce or eliminate the use of disposal of aerosol
 containers.

 Waste Stream Characterization Study

        A full-scale waste composition study would proyide real,  accurate numbers on which future
 recommendations could be based.  This data would identify cost, justify  capital improvements and lead to
 improved operations. To ensure accurate, long-range planning for future waste management, the Postal
 Service could conduct a rigorous waste composition analysis at the Buffalo GMF.  A composition analysis
 would accurately identify the quantities  and sources of each waste material.  Waste containers  could be
 numbered or color coded by operation.  Then, specific waste containers could be selected for a complete
 composition analysis in which the diverse waste components are separated and weighed to verify exactly
 what materials and  in what quantities specific materials are generated by  each operation. An alternative
 composition analysis technique would require employees to sort and weigh one or more compactor loads.
 This approach would determine the relative percentages of specific materials in the waste stream but would
 not target their sources.

 Bulk Mail and Magazines/Life-Cycle Analysis Study

        UBBM constitutes a substantial input to the CFS/UBBM waste stream.  The USPS is  reluctant to
 impose restrictions on bulk mailing because of the revenues generated.  However the USPS incurs a cost,
 unqualified at this time, to process, transport and dispose of UBBM.  A life-cycle analysis to compare the
 revenue from bulk business mail to the costs of UBBM would quantify the cost to handle, transport and
 dispose of UBBM.  Comparing this cost to the revenue gained from bulk mailing fees will identify the net
 benefit or cost for the entire life cycle of UBBM.  Based on this analysis, the USPS could consider including
 the cost of transporting, handling and disposing of undeliverable mail in the bulk mailing fees. To reduce
 the amount of UBBM the Postal Service could require regular updating of mailing lists especially for third
 and fourth class mail. Currently, the Postal Service provides a mailing list maintenance service,  however,
 it is not well advertised. The USPS has an active dialogue with trade associations and bulk mailing concerns
through regular meetings. The national implications of these options warrant that they be more appropriately
discussed at upper  management levels within the USPS.
                    V
Water and Energy Conservation

        The Buffalo GMF and VMF jointly used 1,564 gallons of water and  discharged 2,229 gallons to the
sewage system from January 1991 through March  1991.  The water and sewer bill for this quarter was
$3,793.68. A comprehensive water conservation program will conserve water and reduce USPS costs. This

                                               20

-------
would include regular inspection and repair of sinks and toilets.  As a first step, water meters could be
installed to record water usage in high water use areas such as the vehicle washing equipment area.

        The GMF staff has actively implemented energy conservation efforts by installing fluorescent lighting
and interior storm windows. These commendable efforts should be continued.  Consideration should also
be given to motion or sound sensitive lighting.

Improved Waste Management Cost Tracking

        The  results  of the waste stream characterization study recommended above would  provide
information to facilitate waste tracking.  Designating a separate account number for hazardous and solid
waste management costs would improve the USPS's ability to identify and track waste management costs.
Under the present  system waste  management costs are folded into  the overall  service account.
Identification and tracking of specific waste management costs is difficult. Designating a specific account
number for waste management costs has a number of benefits. It would allow the USPS to more easily
monitor waste management costs over time. Sudden or gradual increases in waste management costs
could signal changes in waste generation operations or improper waste management practices that should
be  investigated.  USPS  staff could associate waste management costs with  individual operations or
departments.  The USPS should also consider apportioning or "charging" waste management costs to the
department generating the wastes.   Making each department aware of and responsible for waste
management costs provides an additional incentive to reduce waste.

        More focused waste management cost accounting also eases the tracking of economic impacts
of waste reduction options on waste management costs. Waste management is often a hidden cost.  By
explicitly identifying these costs, facilities  can weigh the costs and benefits of different waste reduction
options and,  more importantly, quantify savings or losses from instituted waste reduction techniques.

Promote Affirmative Procurement and Facilitate Public Recycling

        All paper products distributed by the Postal Service could be manufactured with recovered materials
and promoted as recycled and recyclable.  The Postal Service currently distributes one envelope and one
stamp which are made from recycled paper, water-soluble inks, and water-soluble adhesives. Additionally,
nineteen postcards printed on recycled paper are currently available from the Postal Service.  The Postal
Service could expand this to initiate new specifications  that would  encourage procurement of products
containing  recovered materials and enhance the recyclability of the waste stream.  For example, the Postal
Service could require that windows in envelopes be made of recyclable cellulose rather than non-recyclable
plastic.  A price advantage could be offered to bulk mailers who certify that the paper and envelopes used
contain a minimum of 50 percent recovered paper.

Employee Participation

        Active support and participation by all USPS employees is critical to the GMF's pollution prevention
program.  Implementing the recommendations presented in this report hinges  on employee commitment.
A major factor in implementing and sustaining source reduction and recycling efforts is employee education.
USPS staff need to understand why pollution prevention is important and how they can help.  Management
must communicate pollution prevention goals and activities and find avenues to  solicit worker input on ways
to improve the program. Establishing and maintaining a successful source reduction and recycling program
requires constant effort and monitoring. A proactive training program and  open communication can help
ensure proper performance.  Table 5 lists key ways to maintain and improve a pollution prevention program.
Appendix C contains a fact sheet about pollution prevention at USPS GMFs. This factsheet provides USPS
employees with information  on  how to reduce or recycle wastes from GMF operations.
                                              21

-------
        Pollution Prevention Resources and Training Opportunities in  1992 (EPA/560/8-92-002) is an
 extremely helpful document that provides guidance on successful employee involvement and training. This
 document is an annual guide containing information about publicly-sponsored pollution prevention resources
 and training opportunities available across the U.S.  Its  goal is to  provide a single source of pollution
 prevention options to those interested in learning more about such strategies.

        The document contains information such as 1) available training courses or contacts who are willing
 to share experiences about establishing new training opportunities,  2) availability of pollution prevention
 publications and videos, 3) Federal and State contacts, 4) availability of university research and training, and
 5) Federal, State, and nonprofit organizations that can provide additional pollution prevention information
 and technical assistance.  Additional information can be  obtained by accessing the Pollution Prevention
 Information Clearinghouse (PPIC), which offers a wide range of free information services.

      TABLE 5.  KEY WAYS TO MAINTAIN AND IMPROVE A POLLUTION PREVENTION PROGRAM
  General Goals
Specific Methods
  Integrate pollution prevention into
  corporate planning
  Provide ongoing staff education
  programs
  Maintain internal communication
 Reward personnel for their success in
 pollution prevention
 Provide public outreach and education
 about pollution prevention efforts
Assign pollution prevention accountability to the operating
units where waste is generated

Track and report program status

Conduct an annual program evaluation at the corporate
level
Make pollution prevention awareness program a part of new
employee orientation

Provide advanced training

Retrain supervisors and employees
Encourage two-way communication between employees and
management

Solicit employees' pollution  prevention suggestions

Follow-up on suggestions
Cite accomplishment in performance reviews

Recognize individual and group contributions

Grant material rewards

Consider pollution prevention a job responsibility subject to
review
Submit process releases on innovations to local media and
to industry journals read by prospective clients

Arrange for employees to speak publicly about pollution
prevention measures in schools and civic organizations.
ouuii-e.
                unuuun planning ouiae {trA May 1992)
                                               22

-------
Complimentary copies of the manual as well as additional information on the PPIC can be obtained by
calling the Pollution Prevention Information Clearinghouse Hotline at (703) 821-4800 or writing to:

        Pollution Prevention Information Clearinghouse
        Technical Information Service
        c/o Science Applications International Corporation
        7600 A Leesburg Pike
        Falls Church, VA 22043

Public Education

        The USPS could use its lobby space to educate customers about effective waste management.
The USPS should promote its own source reduction and recycling program by publicizing the amount of
waste reduced, and resources and energy saved.

Options Ranking

        Ranking is the process of classifying pollution prevention options for further study and action. Each
option is judged against a set of criteria. The criteria list the major positive and negative factors influencing
implementation.   These  criteria  take  into account  environmental, economic,  and implementation
considerations identified from the site visit, interviews with USPS employees, and information taken from the
worksheets. The qualitative ranking system is based on the assumption that each option will have either
a positive (more efficient, more cost effective, more resource conservative), neutral, or negative (more labor
intensive, more expensive, incompatible) effect on current operations.  Using a system of one through  five,
with three as a neutral point, each option was ranked. The ranking results are shown in Table 6.  Ranking
the options creates a prioritized list of recommended  pollution prevention projects that the USPS might
pursue. Options with the highest scores are the most immediately effective and/or the easiest to implement.
Some pollution prevention options were not ranked because they have very low capital costs, the benefits
of each option are not easily quantified, or the option does not lend itself to the ranking criteria.  While
unranked, these options are included in the implementation plan discussion.

FEASIBILITY

        A limited technical and economic feasibility assessment for each of the major source reduction and
recycling options was undertaken. This section discusses capital and/or operation and maintenance costs
associated with the option, operational differences, wastes reduced/eliminated, and implementation barriers.
The discussion will focus on the different types of waste materials.

Corrugated Cartons

        Corrugated cardboard is a substantial GMF waste. Source reduction and recycle options for this
waste are readily accessible for this waste. Replacing corrugated cardboard and polypropylene cartons with
longer life plastic cartons can lead to economic benefits.  Cardboard or fiberboard  trays cost $0.32 each
and have a six month life expectancy with a per month cost of $0.05. The corrugated plastic trays cost from
$1.10 to $1.50 each and have  a life expectancy  of one to ten years, depending  on the manufacturer.
Assuming a five year life expectancy and a cost of $1.30, the corrugated plastic tray costs $.02 per month.
Over  a five year period, corrugated plastic trays are found to be a  more cost effective choice than the
corrugated paper trays. The GMF should request the longer life corrugated plastic trays instead of the
shorter life corrugated cardboard cartons.
                                               23

-------
                                TABLE 6.  QUALITATIVE RANKING OF RECOMMENDED ACTIVITIES




CRITERIA
Compatibility with
existing operating
procedures
Capital cost
Conserve
resources
Additional labor
requirements
Additional space
requirements
Ease of
Implementation
Implementation
period
Extent of current
use In Industry
Reduction of
disposal costs
TOTAL



Recycle
corrugated
cardboard
3


3
5

3

3

5

5

5

5

37
Recycle
shrink wrap,
stretch
wrap, other
film,
strapping
3


3
5

3

3

5

5

5

5

37


Recycle
computer
and office
paper
2


3
5

2

2

3

5

5

5

32


Recycle
corrugated
plastic
boxes
3


3
5

3

2

4

2

2

5

29

Recycle high
density
polyethylene
(HOPE)
bottles
2


3
5

3

2

2

4

4

5

30


Purchase
only HOPE
pallets and
recycle them
2


3
5

3

3

1

1

2

5

25



Recycle
pressed
wood pallets
3


3
5

3

3

4

2

4

5

32



Backhaul
reeyclables
from AOs
2


3
S

2

3

2

3

4

3

27


Establish
affirmative
procurement
program
2


3
5

3

3

2

2

2

3

25



Expand APP
to
contractors
3


3
5

3

3

2

2

2

3

26


Duplex
copying
policy and
training
2


2
5

4

3

3

4

4

4

31
5 = very positive
4 = positive
3 = neutral
2 = somewhat negative
1 = very negative

-------
        Another option is to replace both kinds of disposable containers with reusable metal or rigid plastic
containers.  If these containers are damaged beyond repair, the metal containers could be recycled within
the current metal recycling program and the rigid plastic containers have the potential to be recycled back
into the same product.

        Local paper dealers will collect loose corrugated cardboard from the GMF at no charge and zero
payment.  However, paper dealers will pay a $20 premium per ton for baled corrugated cardboard. With
either option, the waste collection system  would not require alteration, since the maintenance staff could
remove OCC from the waste and  deposit it into a separate container or into the baler.   It would be
necessary to set aside a bay for the storage container and additional storage space for the bales of OCC.

        Table 7 is a cost/benefit  analysis  of recycling loose and baled corrugated cardboard.  It appears
that recycling loose OCC represents the  best option at this time.  However,  if the premium for baled
corrugated cardboard or the volume of material generated by the GMF increases, the cost of a baler may
be justified.

Plastic Film and Strapping

        Plastic film is another large component of the GMF waste stream that can be readily recycled.  The
Buffalo GMF could follow the lead of the Rochester New York Post Office which is currently recycling shrink
wrap, stretch wrap and other plastic bags and films through the local  Mobil Chemical  Company
manufacturing facility.  Mobile Chemical Corporation will pay the GMF $0.11 per pound for this material if
they collect  it at the GMF  and $0.12 per pound if the material is  delivered to the recycling facility in
Rochester. The Buffalo GMF generates approximately 90-100 pounds of plastic film per day for an estimated
annual payback of $4,380. The annual avoided disposal figure would  be $1,105.  Total annual return to the
Postal Service for recycling  plastic film would be $5,485.

        The plastic shrink wrap can be collected as mail is unwrapped while other plastic films can be
separated from mixed waste on the dock. Transportation to the recycling facility can be accomplished
through the regular movement of  mail and equipment between the GMF and the Rochester Post Office, or
Mobile Chemical Corporation can collect it. To initiate this recycling option, the Buffalo GMF should deliver
the film to the Mobile Chemical Corporation facility in Rochester or allow Mobile Chemical Corporation to
collect it in Buffalo.  Once this decision has  been made, a container for the film can be located near the
compactor and recycling can begin.

        Plastic film presents a disposal problem not only for the Buffalo GMF but for all AOs receiving
shrink-wrapped  mail from Buffalo.   Replacement of shrink-wrap with  permanent, reusable distribution
packaging would represent an initial capital cost, but over time would eliminate the cost of purchasing the
plastic film, the labor and electricity used to shrink wrap the pallets as well as the disposal costs for Buffalo
and the AOs.

        Mobile Chemical Corporation may also be willing to accept the polypropylene plastic strapping for
recycling. This option requires further discussion with Mobile Chemical Corporation. However,  separation
of the strapping on the dock is readily implemented.  The Postal Service could maximize the recyclability
of the plastic strapping  by  purchasing only one resin and  color of strapping.  A larger  quantity  of a
consistent commodity is more easily marketed, than the mixture of three different  colors of strapping that
is currently being generated. Apparently,  different strapping machines require different sizes of strapping
and the sizes are differentiated  by color.  The Post Service could standardize the  strapping machinery to
facilitate recycling of the strapping.
                                                25

-------
                   TABLE 7.  COST/BENEFIT ANALYSIS FOR OCC RECYCLING
  Recycle OCC
Baled                          Loose
  Equipment Transportation                   $8500                            0
  Installation                            baler purchased

  Electric power                            <$10/year                         0
                                      89 kilowatt hrs./yr.

  Labor                                    $4292                            0
                                    (4.5 hours per week @           (Net decrease in labor
                                       $ 18.34 per hour)             compared to disposal in
                                                                        compactor)


  Baling wire                                 $570                             0

  Routine maintenance                        $250                             0

  Total Annual Operating and                 $5,122
  Maintenance Costs                                                          0

  Avoided Costs                            $34,000                       $34,000
                                 (Reduce compactor pick-up     (Reduce compactor pick-up
                                 @ $405.20/pick-up from bi-     @ $405.20/pick-up from bi-
                                  weekly to once every three     weekly to once every three
                                           weeks)                         weeks)

  Revenue                             $5,060 (253 tons @                     0
                                         $20.00/ton)

  Total Benefit                               $39,060                        $34,000

  First Year Benefit =                         $25,438                        $34,000
  Return - Cost                         ($39,060 - $13,622)

  Year 2 and Following Benefit                $33,938                        $34,000
                                       ($39,060 - $5,122)
Recycling

        Recycling is an option for a number of different materials generated at the GMF and presently
disposed of. The following discussion provides an overview of establishing a recycling system by identifying
the major recycling system considerations and factors.

        Setting up a recycling program can require an investment of both time and money. The first step
is designing a collection program. Each employee must have access to recycling collection containers and
must understand what materials are acceptable.  Equipment may be necessary to process the recyclables.
An area must be set aside to store the recyclables before they are taken to a market.  Before collection can
begin, the staff must locate a reliable market that will accept or purchase each recyclable commodity.
Recycling markets are traditionally  unstable, with frequent fluctuations in the amount paid  per ton of
                                              26

-------
recyclable material.  Often, the recycler will accept the material but pay nothing at all or charge a fee to
collect and process the material.

        Access to markets willing to accept or purchase recyclable materials may represent a barrier to the
implementation  of some of the  recommended recycling  options.   Collection  programs are readily
implemented, but are useless without an appropriate recycling infrastructure. For some materials, distance
from the markets may represent a significant barrier; for others, local markets may provide a significant
return on the material. Recycling operations  can be  profitable; the key is knowing the market options.

        It is best not to base an evaluation of recycling on the potential sale of the recyclables.  In many
cases, even if a charge is incurred, the program may still be economically beneficial. Attention should focus
on the potential avoided cost of  disposing of the  materials.  For the Buffalo GMF, each ton. of material
delivered to a recycler at no cost represents a potential $85 savings in avoided disposal fees. Over the past
ten years, the cost of solid waste disposal has risen far more rapidly than the rate of inflation. Because of
new environmental standards imposed by the Clean Air Act and the Land Disposal Rule, it will be more
expensive to operate landfills and incinerators in the future.   Projections suggest that disposal costs will
continue to exceed the rate of inflation for the foreseeable future.

        In addition to collecting materials for recycling at the Buffalo location GMF management could also
implement a program to backhaul recyclables from AOs to the GMF for consolidation and marketing. This
would  make it easier to implement a broad scale recycling program and would eliminate the need for each
office to initiate market arrangements.

        For each potentially recyclable material, staff of the Buffalo GMF will need to answer a series of
questions shown in Table 8.  Thorough attention to  program development will ensure the success of the
recycling efforts.

Potential Implementation Barriers

        Implementing an option may require overcoming economic, technical, and/or policy barriers. This
sections identifies potential barriers to implementing  the identified pollution prevention options. Reduction
in the  number of corrugated containers  and pallets, and the amount of plastic film  and strapping is
hampered by the need to purchase long-life, reusable alternatives for these materials. A major barrier to
waste reduction is the Postal Service procurement policy that focuses on short-term rather than life-cycle
costs.  For example, the Postal Service allocates a specific amount of money for the purchase of a specific
number of pallets or corrugated distribution  packages. If the immediate purchase price of the reusable
alternative is higher, the Postal  Service will not purchase it even If the long-term, life cycle costs are lower.

        Another barrier to replacing corrugated containers with longer life corrugated plastic trays is the
inconsistent quality of the corrugated plastic trays. Some vendors  provide high quality, long-life products
while other vendors provide lower quality, shorter life trays from which the handles frequently rip and  are
easily crushed or torn. The corrugated plastics industry does not have an industry-wide agency to ensure
consistency in product quality while the fiberboard quality is ensured by the Technical Association of Pulp
and Paper Industries.

        The major barrier to recycling pressed wood, plastic pallets and the corrugated plastic distribution
bins is the distance to the market.  In each case, the manufacturer of the product accept it for recycling,
but the markets are located at a distance from Buffalo. The long-term environmental and economic benefits
of recycling these items require further research.
                                                27

-------
                    TABLE 8. RECYCLING PROGRAM DEVELOPMENT FACTORS
  Development Factor
Questions to be Answered
  Education
  Internal Collection
  External Collection
  Transportation and Markets


  Cost


  Revenue

  Waste Removal
How will current employees, new employees and visitors to the facility
be informed of their responsibilities in relation to the recycling
program?  Who will monitor program successes and failures? How will
this information be circulated? What, if any, enforcement procedures
will be used?

How will the material be collected from individuals? Will there be a box
on or next to each work station? a box in each office or area? several
drop-off containers in break rooms or hallways? reverse vending
machines?

How frequently and by whom will the recyclable material be collected
from the containers?  Where will it be taken? Is processing necessary?
Is processing equipment available?  If interim on-site storage is
necessary, where and in what kind and size container?

Who will remove the recyclables from the GMF? Where will they be
taken?

Will the GMF pay any costs for the collection, transportation and/or
marketing of the recyclable(s)?

Will the GMF receive any revenue generated by recycling?

Will the waste removal system change as a result of recycling?  Are
different kinds or sizes of containers needed?  Will trash be picked up
more or less frequently?
 Paper

        Recycling computer  and mixed  office paper is limited only by the  implementation process.
 Decisions about collection containers and custodial responsibilities must be resolved and the staff educated.
 In addition, local markets for recycled paper should be investigated and haulers selected before a paper
 recycling program can be implemented.  However, paper recycling could be in  place in a relatively short
 amount of time.

        Once a recycling program is initiated, a waste hauler should  be contacted to arrange an on-call
 schedule for compactor pulls. The GMF staff should keep detailed records of the percent the compactor
 is filled and the length of time between pulls. As the waste reduction and recycling programs expand, the
 compactor can be replaced with a smaller, less costly container.

        Reduction in the amount of paper being discarded can be accomplished immediately. The Buffalo
 GMF has sufficient duplex copying capability, and the remaining single-sided machines can be replaced with
 machines with duplex capability as they are wear out.  In addition, a new duplex copying  policy should be
 implemented through a simple policy statement from the Postmaster.  This should be reinforced through
training and supervision.
                                              28

-------
Procurement

        The Buffalo GMF may be able to change specific local procurement language to increase bulk
deliveries of supplies.  However, if these items are acquired through the USPS Requiring Office, the time
required to implement such a change will be significant.

IMPLEMENTATION PLAN

        Table 9 lists source reduction and recycling options as either immediate, intermediate or long-term
options based on the ease of implementation. Immediate options require relatively little effort and capital,
intermediate options require an intermediate amount of planning, decision-making and capital expenditure,
and long-term options require developing or modifying policies at the regional or national  USPS level,
working with other Agencies, or establishing new programs. The factors influencing the ease or difficulty
of implementation were discussed in the Feasibility section. A more in-depth, USPS implementation plan
could be developed using the information in the Feasibility section and Table 9 as a start.

CONCLUSIONS

        USPS Buffalo  employees have enacted a number of source reduction and recycling activities.
These include installing energy saving fluorescent lighting and interior storm windows; collecting cardboard,
UBBM, ferrous metal, and aluminum for recycling; and purchasing reconditioned printer cartridges.  These
activities have significantly reduced waste disposed from the GMF. Additional pollution prevention activities
scheduled for enactment  at the GMF are collecting white and mixed office paper for recycling and replacing
paper towels in washrooms with electric powered air hand driers.  Current and planned pollution prevention
practices, excluding energy savings, will save the USPS an estimated $96,556 annually,  as shown in Table
10. These estimated annual returns were calculated based on recycling and disposal markets in the Buffalo
area in September 1992.  Recycling cardboard alone is projected to divert approximately 253 tons of solid
waste from the waste to energy incinerator and save an estimated $34,000 in avoided disposal fees annually.
In addition, collecting cardboard for recycling has reduced waste by over 50 percent, surpassing the USPS
requirement that facilities reduce 1992 waste levels by 25 percent by 1993.

        Implementing the pollution prevention opportunities identified in this report can further eliminate
wastes  and reduce operating and disposal costs.  Projected  cost savings from recycling plastic film are
estimated at $5,485 annually. Cost savings from the other options are not quantifiable  due to incomplete
data on waste quantities.  Affirmative procurement could further reduce solid waste by specifying minimum
packaging.  Affirmative procurement also closes the recycling loop by supporting markets for recycled
goods.

        The Buffalo GMF has several characteristics that favor a successful pollution prevention program:

        •      A core of enthusiastic and committed USPS staff

        •      Top level commitment to pollution prevention as  shown in pollution  prevention
               policies and waste reduction goals

        •      Buffalo GMF management commitment as shown by their participation in this project

        •      Adequate quantities of recyclable materials to interest recycling vendors

        •      Adequate storage space for recyclable materials and containers

        •       Local markets for most recyclable wastes

                                               29

-------
                                TABLE 9. IMPLEMENTATION PLAN
  Ease of Implementation
Options
  Immediate Implementation/     Paper reduction through duplex copying and routing slips
  Low Barriers
                               Plastic film recycling

                               Find aerosol container substitutes

                               Recycle toner cartridges

                               Improved inventory control and better housekeeping practices

                               Improved waste management cost tracking

                               Public education

                               Employee training program
  Intermediate Implementation/   Investigate purchasing a cardboard baler
  Medium Barriers
                               Establish a recycling program for mixed office paper and computer
                               paper
  Long-Term Implementation/     Modify procurement policy to encourage purchase of long-life
  High Barriers                  materials (for corrugated containers, pallets, plastic film and strapping)

                               Modify procurement policy to prohibit aerosol containers and increase
                               bulk deliveries

                               Study recycling potential for pallets and plastic distribution bins

                               Modify cafeteria contract to promote source reduction and recycling

                               Investigate bulk mail policy to modify mailing rates based on  USPS's
                               lifecycle  costs of UBBM

                               Recycle aerosol cans

                               Recycle fluorescent lights including the mercury ballasts  (non-PCB)

                               Recycle other non-container glass such as windows and light bulbs

                               Recycle additional metals
        Though barriers to implementation may be encountered, such as USPS current procurement policy
and uncertainty of a reliable market for recycling materials, most pollution prevention options presented
remain viable.  A few of the options require Postal Service action at the national level.  Items such as
pressed wood pallets and corrugated cardboard trays are acquired indirectly by the Buffalo GMF through
the USPS National Requiring Office. For certain other items, vendor specifications that favor recyclability,
                                               30

-------
recycled content, or minimal packaging can be generated at the Buffalo GMF but will have a greater impact
if developed nationally.

Applicability to Other GMFs

        Many of the options outlined in this  report could  be implemented at the other 270 GMFs in the
United States. Waste reduction options, such as recycling laser printer cartridges and conserving water,
require little or no capital  investment. Other options may require the purchase of equipment such as
collection bins for recyclables, energy-efficient lights, storm windows, or duplex copiers. Given the similarity
of operations at GMFs, the recommendations contained in this report, including the estimated net annual
benefits and payback, should be generally applicable to the other GMFs. Because factors such as the
availability and strength of recycling markets vary  regionally, DSPS facilities  outside the Buffalo area are
advised to research such conditions carefully  before making investments in recycling equipment. Disposal
costs and markets for recyclables are likely to be significantly different in other areas or at other times.  For
example, there is a Mobil Chemical Company manufacturing facility within 100 miles of the Buffalo GMF that
will purchase and recycle plastic film. A market for plastic film may not be available in many other areas.
When recycling  markets are available, it is important to consider benefits  such as avoided disposal costs
and reduced liability even if the USPS facility receives no payment (or is subject to a minimal fee) for the
recyclables.
                                                 31

-------
 TABLE 10.  ESTIMATED ANNUAL RETURN FROM SOURCE REDUCTION AND RECYCLING
                             USPS G.MF, BUFFALO, NY
Action                                             Potential Monetary Benefit
Current Practices
Recycle laser printer cartridges                                $1.740
Recycle aluminum cans                                      $1.011
Recycle scrap metal                                         $2,125
Recycle loose cardboard                                     $34,000
Subtotal (current practices)                                  $38,876

Recommended Measures
Recycle plastic film                                          $5,485
Subtotal (recommended measures)                           $5,485

Recently Implemented or Proposed
Recycle computer paper                                      $240
Recycle mixed office paper                                   $1,955
Replace paper hand towels with electric air                     $50,000
dryers (2)

Subtotal                                                   $52,195
Total                                                      $96,556
Notes:
                                   
-------
 APPENDIX A




WORKSHEETS

-------
Firm USPS
Site  Buffalo. NY - GMF
Date April 1992
                                          Waste Minimization
                                        Assessment Worksheets
Proj. No..
                                Prepared By_

                                Checked By_
                                                                   Sheet _1_ of  1  Page  1  of _1_
        Worksheet
           S2
 SITE DESCRIPTION
vvEPA
Firm: U.S. Postal Service
Plant: Buffalo New York
Department: General Mail Facility
Area:
Street Address: 1200 Williams Street
City:  Buffalo
State/ZIP Code:  NY
Telephone:  (   )
Major Products:     U.S. Mail processing facility
 SIC Codes:
 EPA Generator Number:
 Major Unit or:
 Product or:
 Operations:  The Buffalo GMF Serves as the area distribution center for zip code areas 140-149, the state

 distribution for flats and 3" class mail for zip code 130-149, the mail processing center for all 17 stations and

 branches in Buffalo, and the Sectional Center Facility for 104 associate offices.	^^^
 Facilities/Equipment Age:  Occupied site since 1963.

-------
Firm USPS
Site Buffalo. NY - GMF
Date Aon! 1992
Waste Minimization
Assessment Worksheets
Proj. No.
Prepared Bv
Checked Bv
Sheet 1 of _J_Page 1 of _^
Worksheet
  S6
WASTE STREAM SUMMARY
&EPA
Attribute
Waste ID/Name:
Source/Origin
Component/or Property of Concern
Annual Generation Rate (units tons )
• Overall
• Component(s) of Concern
Cost of Disposal
• Unit Cost ($ per: S90/ton)
• Overall (per year)
Method of Management2
Priority Rating Criteria3
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Relative
Wt. (W)









Sum of Priority Rating Scores
Priority Rank
Description'
Stream No.jl
Cardboard
Docks sorting floor
Solid waste
> 200
> 200
N/A
$90/ton

$18.000
Solid waste
incinerator
Rating (R)
N/A
High
Low
High
Low
Low
High
N/A
N/A
Z(RxW)
RxW










High
Stream No._1_
Computer paper
Offices
Solid waste
2
2
N/A
$90/ton

$180
Solid waste
incinerator
Rating (R)
N/A
High
Low
Low
Low
Low
High
N/A
N/A
Z(RxW)
RxW










High
Stream No._1_
Office paper
Offices
Solid waste
> 23
> 23
N/A
$90/ton

1,970
Solid waste
incinerator
Rating (R)
N/A
N/A
Low
Medium
Low
Low
High
N/A
N/A
Z(RxW)
RxW










High
'For example, sanitary landfill, hazardous waste landfill, onsite recycle, incineration, combustion with heat
recovery, distillation, dewatering, etc.
2Rate each stream in each category on a scale from 0 (none) to 10 (high).

-------
Firm USPS
Site Buffalo. NY - GMF
Date April 1992
                                   Waste Minimization
                                 Assessment Worksheets
   Proj. No..
                             Prepared By_

                             Checked By_
                                                        Sheet _1_ of  1  Page  2 of 4
      Worksheet
         S6
WASTE STREAM SUMMARY
&EPA
Attribute
Waste ID/Name:
Source/Origin
Component/or Property of Concern
Annual Generation Rate (units tony )
• Overall
• Component(s) of Concern
Cost of Disposal
• Unit Cost ($ per: $90/ton )
• Overall (per year)
Method of Management2
Priority Rating Criteria3
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Sum of Priority Rating Scores
Relative
Wt. (W)










Priority Rank
Description1
Stream No. 1
Plastic Film
Loading Docks
Solid waste
13
13
N/A

$90/ton
$11,700
Solid waste
incinerator
Rating (R)
N/A
High
Low
High
Low
Low
Medium
N/A
N/A
KRxW}
RxW










Medium
Stream No. 1
Pallets
Loading Docks
Solid waste
Unknown

N/A

$90/ton
Unknown
Solid waste
incinerator
Rating (R)
N/A
Unknown
Low
Unknown
Low
Low
Medium


Z(RxWJ
RxW










Medium
Stream No. 2
Bulk Mail
Undeliverable bulk
business mail
Solid waste
4 yd*/3 days

N/A

$23 per pull
$2,400
Solid waste
Incinerator
Rating (R)
N/A
Medium
Low
Medium
Low
Low
Low
N/A
N/A
Z(RxW)
RxW










Medium
Tor example, sanitary landfill, hazardous waste landfill, onsite recycle, incineration, combustion with heat
recovery, distillation, dewatering, etc.
'Rate each stream in each category on a scale from 0 (none) to 10 (high).

-------
Firm USPS
Site Buffalo. NY - GMF
Date Aoril 1992
Waste Minimization
Assessment Worksheets
Proj No.
Prepared Bv
Checked Bv
Sheet _1_ of _1_Page 3 of _i
Worksheet
~  S6
WASTE STREAM SUMMARY
v>EPA
Attribute
Waste ID/Name
Source/Origin
Component/or Property of Concern
Annual Generation Rate (units 	 )
• Overall
• Component(s) of Concern
Cost of Disposal
• Unit Cost ($ per: Poll. )
• Overall (per year)
Method of Management2
Priority Rating Criteria3
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Relative
Wt. (W)









Sum of Priority Rating Scores
Priority Rank
Description1
Stream No._2_
Cans
Cafeteria
Solid waste
Unknown
Unknown
N/A

$40
$6,800
Solid waste
incinerator
Rating (R)
N/A
High
Low
Low
Low
Low
High
N/A
N/A
ZfRxW}
RxW










Medium
Stream No._2_
Polystyrene
Cafeteria
Solid waste
Unknown
Unknown
N/A

$40
$6,800
Solid waste
incinerator
Rating (R)
N/A
High
Low
Low
Low
low
Medium
N/A
N/A
ZfRxW}
RxW










Medium
Stream No.J_
Foodwaste
Cafeteria
Solid waste
Unknown
Unknown
N/A

$40
$6.800
Solid waste
incinerator
Rating (R)
N/A
High
Low
High
Low
Low
Low
N/A
N/A
Z(RxW)
RxW










Low __
'For example, sanitary landfill, hazardous waste landfill, onsite recycle, incineration, combustion with heat
recovery, distillation, dewatering, etc.
2Rate each stream in each category on a scale from 0 (none) to 10 (high). 	

-------
Firm USPS
Site Buffalo. NY - GMF
Date April 1992
        Waste Minimization
      Assessment Worksheets
   Proj. No..
Prepared By_

Checked By_
                                                        Sheet  1  of _J_Page  4 of 4
      Worksheet
         S6
WASTE STREAM SUMMARY
           &EPA
Attribute
Waste ID/Name:
Source/Origin
Component/or Property of Concern
Annual Generation Rate (units 	 )
• Overall
• Component(s) of Concern
Cost of Disposal
• Unit Cost ($ per: )
• Overall (per year)
^MM^BMMH^HHMHHMM^B^
Method of Management2
Priority Rating Criteria3
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Sum of Priority Rating Scores
Relative
Wt. (W)










Priority Rank
Description1
Stream No. 3
Spilled Oil/Out dated
chemicals
Equipment
maintenance
Oil
Unknown
•••••M™^^™^™™^™.™ MaaMaaaaaaaaWBIBaMMBM .^^
Unknown


Unknown
^^^^^••^••im^H^^^^^^^^^^^^^^^^^^^^^^^^^^^M
Unknown
Recycle
Rating (R)
High
Unknown
High
Small
Medium
Medium
High
N/A
N/A
Z0?xW
Rx W










High
Stream No. 3
Solvent
Equipment
maintenance
Petroleum naptha
•••^•^•••••^•^^^^^^••••^•••••••••••••••••••M^^^^^M
Flammable

$65. 75/service
-$600
Incineration
Rating (R)
High
High
High
Low
High
High
Medium
N/A
N/A
Z(RxW)
RxW










High
Stream No.
•


•••••••••••••••••••••••••••••^^^^^^^^••••••••••••^••••^••••H


M^^H^^^^MB^^^^^^^^^^^^^^^^^^^^^^^^^^OBH

Rating (R)









Z(RxW)
RxW











Tor example, sanitary landfill, hazardous waste landfill, onsite recycle, incineration, combustion with heat
recovery, distillation, dewatering, etc.
"Rate each stream in each category on a scale from 0 (none) to 10 (high).

-------
     APPENDIX B




INFORMATION SOURCES

-------
                                          Appendix B
                                      Information Sources
SOURCES FOR:

Corrugated polypropylene containers

Mills Industries, Inc.
167 Water Street
Laconia, New Hampshire 03246
(603) 528-4217

Paper recycling

Domtar Fiber Products, Inc.
Recycling Division
3241 Waiden Avenue
Depew, New York 14043
(716) 681-1560

Modern Recycling Inc.
P.O. Box 209
Model City, NY 14107-0209
(716) 754-8226

Ramcol Fibres Inc.
226 Ohio Street
Buffalo, NY 14204

Plastic pallets

Cadillac Products, Inc.
7000 East 15 Mile Road
Sterling Heights, Ml 48311
(313) 264-2525

Pressed wood pallets

Litco International inc.
1411 Youngstown-Kingsville Road
Vienna, OH 44473-0150
(216) 539-5433
Recycling Assistance

The New York State Office of Recycling Market
Development will  assist the Postal Service in
exploring recycling opportunities. Contact

Garrett Dolan and  Jim Gilbert,
Market Development Specialists
NYS Department of Economic Development
Office of Recycling Market Development
111 East Avenue
Rochester, NY 14604
(716) 325-1944

The New York State Department of Environmental
Conservation, Division of Solid Waste, Region IX
maintains a record of all local recycling programs
and their current markets. They can be reached
at:

600 Delaware Avenue
Buffalo, NY 14202
(716) 847-4585

-------
APPENDIX C




FACTSHEET

-------
                            General
                            Mail
                            Facility
•  WHAT IS THE WASTE PROBLEM?

     Every year, each of us produces more than a half ton of
solid waste, while business and industry generate an equal
amount on our behalf. That's a total of one ton of waste per
year for every man, woman and child in the United States. A
portion of this waste is recycled, a small amount is inciner-
ated, but most, more than 80 percent nationwide, is buried in
landfills. Unfortunately, landfill capacity is diminishing
while waste generation rates continue to rise.

     Mail facilities add to this waste burden by generating
large quantities of both hazardous and nonhazardous waste.
Typical items in the waste stream include:
    • various grades of paper from bulk mailings and general
     office activities
    • cardboard (corrugated and greyboard)
    • pallets (fiberboard, plastic, wood)
    • newspapers
    • magazines
    • food service wastes
    • oil and solvents from
     maintenance of ma-
     chinery and boiler
     room
    • other maintenance wastes: light bulbs, floor sweepings,
     bathroom cleaning wastes
•   HOW DOES THIS AFFECT YOU?

     Because of the similarity in operations at General Mail
Facilities (GMF), waste streams and waste issues are com-
parable to those found at the Buffalo GMF; therefore, the
Buffalo facility is used as a case study to exemplify waste
problems and pollution prevention opportunities.

     The Buffalo General Mail Facility (GMF) handles
•nore than 1.7 million pieces of incoming mail each day, in-
:luding 1st and 3rd class letters and flats, and delivers more
than 2.8 million pieces of 1st and 3rd class letters and flats to
mail recipients. In addition, daily parcel post volume aver-
ages 23,866 pieces. By 1995, these volumes are projected to
increase by 10 percent.  Operations at the GMF include
mechanized mail processing, mail distribution, and retail ser-
vices. Food service is provided by a private contractor.

     Most of the solid waste from the Buffalo GMF is bur-
ied in landfills in Erie and Niagara Counties. Some of the
waste is incinerated, however this incinerator ash is also sent
to these landfills. Rising transportation and disposal costs, as
well as reduced landfill capacity, make solid waste disposal
an important long-term planning issue.

     State and municipal legislation will also affect solid
waste planning. The New York State Solid Waste Manage-
ment Act of 1988 requires municipalities to adopt laws or or-
dinances mandating separation of recyclable or reusable ma-
terials from solid waste by no later than September 1,1992.
The City of Buffalo has already adopted  a local  law which
mandates residential, commercial, and institutional recycling.
In addition, municipalities are required to meet the state goal
of 50 percent reduction, through reuse and recycling of waste
by 1997.

       To  address these waste management issues, the Postal
Service is committed to source reduction and recycling as
sound environmental practices. Source reduction is a multi-
media approach that minimizes or eliminates waste released
to land, air, and/or water without simply  shifting pollutants
from one media to another.  The Postal Service considers
source reduction to be the most preferred environmental
management technique for dealing with a waste generation
problem. For those wastes that cannot be reduced at the
source, the Postal Service recommends that generators con-
sider recycling as the next best optioa

     In the Postal Service Waste Reduction Guide (AS
552), the Postal Service set an overall goal to reduce waste 25
percent from 1992 levels by December 1993 and an addi-
tional 25 percent by December 1995. Further, the Postal Ser-
vice plans to reduce the use of the 17 hazardous chemicals
that have been identified by EPA's 33/50 Program by 1995.
•  WHAT CAN YOU DO?
     Various options have been identified
that may result in the reduction of waste     ultTED STATES
discarded from GMF operations. The fol-   posm SERVICE
lowing is a brief description of source reduction techniques to
consider.

     SOURCE REDUCTION
     Source reduction, reduces the amount of waste or the
toxicity of the waste at the source, that is, before the waste is

-------
  generated. This can be accomplished through changes in the
  purchasing and the use and disposal of products and materi-
  als. Source reduction includes specifying less packaging or
  more recyclable packaging, reduced toxicity or increased du-
  rability in products, and reduced consumptioa These source
  reduction activities can be accomplished by:
     • buying materials in bulk
     • specifying reusable packaging
     • specifying durability
     • avoiding disposable items
     • reusing common products (including cups, utensils,
       and pens)                                     ,
     • using non-toxic cleaning products
     • repairing, rather than replacing items
     • using double-sided copies and limiting computer print-
       outs
       RECYCLING
       Recycling recovers a waste from one process and re-
 uses it in the same or in another process in an environmen-
 tally safe manner. Recent development of Buffalo area mar-
 kets for recyclable materials makes recycling efforts more
 economically feasible for the commercial sector. Some com-
 monly recycled materials in the GMF waste stream include
 office paper, glass, aluminum, used oil, cardboard, pallets,
 magazines, and newspapers. By separating cardboard for re-
 cycling, the Buffalo GMF has cut the amount of waste by ap-
 proximately 50 percent and saved $34,000 annually in
 avoided disposal costs.

      Purchasing products made from or containing recov-
 ered material or products that can be recycled helps to create
 and sustain recycling markets.  Federal Procurement Guide-
 lines urge Federal agencies to establish an affirmative pro-
 curement program for recycled content products or material.
 Items containing recovered material that can be used at
GMFs  include office paper, cardboard, plastic, metal, and
glass products.
      CONSERVATION
      Conservation can result in reduced energy and water
consumption. An energy audit can identify ways to conserve
energy and cut energy expenditures. Some methods of re-
ducing energy consumption include:
    •  Replacing old bulbs with energy efficient light bulbs
    •  Installing motion-sensitive lights
    •  Turning off lights and machines not in use
    •  Installing programmable thermostats

      COMPOSTING
      Organic solid waste can decompose under proper con-
ditions to form a useful soil supplement A composting pro-
gram can be designed to handle most organic wastes, includ-
ing food wastes. High quality compost can often be used by
businesses for landscaping.
•   REFERENCES
      The following is a list of references that provide addi-
tional information on the solid waste problem, and the ben-
efits of source reduction and recycling.
    1.   Waste Reduction Guide, USPS, (AS 552), Feb. 1992
    2.   Recycling Guide, USPS (AS 550), August 1991.
    3.   Hazardous Waste Guide, USPS (AS 553), May
        1992.
    4.   America Recycles: An Overview. GSD&M. No-
        vember 8,1989.
    5.   Managing Solid Waste: Answers for the Foodser-
        vice Operator. National Restaurant Association.
    6.   The Municipal Solid Waste Dilemma: Challenges
       for the 90's. USEPA, Municipal and Industrial Solid
        Waste Division, Office of Solid Waste. July 1991.
    7.   Decision-Makers Guide to Solid Waste Manage-
        ment. USEPA, Office of Solid Waste and Emer-
        gency Response. November 1989.
    8.   Beyond 40 Percent: Record-Setting Recycling and
        Composting Programs.  Institute for Local Self-Reli-
        ance:i991.
    9.   Salvaging the Future: Waste-Based Production. In-
        stitute for Local Self-Reliance. 1989.
   10.   Facing America's Trash: What Next for Municipal
        Solid Waste? Office of Technology Assessment. Oc-
        tober 1989.
   11.   The Solid Waste Dilemma: An Agenda for Action.
        USEPA, Office of Solid Waste. February' 1989.

   Funding provided by the United States Environmental
  Protection Agency and the United States Postal Service

-------
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT

         VEHICLE MAINTENANCE FACILITY
     UNITED STATES POSTAL SERVICE FACILITY
                  BUFFALO, NY
                       by
      Science Applications International Corporation
                  Falls Church, VA
                  Cincinnati, OH
            EPA Contract No. 68-C8-0062
         SAIC Project No. 01-0832-03-1006-010
              Technical Project Monitors

                 Mr. John Filippelli
         U.S. Environmental Protection Agency
                     Region II
                   New York, NY
                Mr. Kenneth R. Stone
         U.S. Environmental Protection Agency
         Risk Reduction Engineering Laboratory
                  Cincinnati, OH
    RISK REDUCTION ENGINEERING LABORATORY
     OFFICE OF RESEARCH AND DEVELOPMENT
     U.S. ENVIRONMENTAL PROTECTION AGENCY
             CINCINNATI, OHIO 45268

-------
                          DISCLAIMER
The information in this document has been funded wholly or in part by the
United States Environmental Protection Agency under Contract 68-C8-0062
to Science Applications International Corporation.  It has been subjected
to the Agency's peer and administrative review and has been approved for
publication as an EPA document.

Mention of trade names  or commercial products does  not constitute
endorsement or recommendation for use.

-------
                            ABSTRACT
This report  presents the results of a pollution  prevention opportunity
assessment conducted at the Vehicle Maintenance Facility for the U.S.
Postal Service's office in Buffalo, New York.  The assessment was
performed  under Work Assignment  3-54 entitled  U.S.  Postal Service
Operations  Pollution Prevention Opportunity Assessment for the U.S.
Environmental Protection Agency (EPA) and the United States  Postal
Service (USPS).

The assessment, conducted  during the week of April 6,  1992,  followed
procedures  in the U.S.  EPA Waste Minimization Opportunity Assessment
Guide (EPA 625/7-88/003). These  procedures are encompass the
concepts  in the U.S. EPA Facility Pollution Prevention  Guide and the
United State Postal Service Recycling Guide (AS 550) Waste Reduction
Guide (AS 552) and Hazardous Waste Guide (AS 553). Technologies and
techniques to reduce and recycle hazardous and nonhazardous wastes
were  evaluated for effectiveness.  This report identifies potential source
reduction and  recycling initiatives and  identifies  areas where  further
research is needed.

-------
                               TABLE OF CONTENTS
ion

   DISCLAIMER

   ABSTRACT
   ACKNOWLEDGEMENTS .......................                                vHi
          1.  INTRODUCTION  .............................. '.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.  1
                 Background  ................................................  1
                 Purpose [[[  1
                 Site Description  .............................................  2
          2.  PURPOSE AND BENEFITS OF POLLUTION PREVENTION '....'.'.'.'.'.'.'.'.'.'.'.'.'.  2
                 Pollution Prevention - Goals  ................... . ...... ; .........  2
                 Pollution Prevention - Benefits ...................................  3
                 Pollution Prevention Opportunity Assessment Procedure  ...............  4
          3.  PROCESS REVIEW  ..............................................  4
                 Painting Operations  ..... .....................................  4
                 Automotive Maintenance and Repair Operations ......................  6
          4.  SUMMARY OF VMF WASTE  GENERATION ........................... . .  6
                 Painting Operations  ..........................................  7
                 Automotive Maintenance and Repair Operations ......................  8
          5.  OPTIONS ASSESSMENT  .........................................  11
                 Existing Pollution Prevention Practices ............................  11
                        Automotive Maintenance and Repair .......................  11
                 Recommended Source Reduction and Recycling Options ..............  12
                        Options  ............................................  12
                 Options for Painting Operations .................................  12
                        Low VOC Paints (Water Borne and High Solids Coatings) ........  13
                        High Volume Low Pressure (HVLP) Paint Application System  .....  13
                        Paint Mixer System ....................................  13
                        Gun Washer Station  ...................................  13
                        Operator Training  .....................................  14
                        Paint Can Reduction and Recycling ........................  14
                        Buffing Pad Cleaner  ................. : .................  14
                        Onsite Distillation and Recycling of. Paint Related Solvent ........  14
                 Options for Vehicle Maintenance and Repair Operations ...............  14
                        Aqueous Chemicals and Parts Washers .....................  14
                        Operating Practices for Parts Cleaning .......................  15
                        Onsite Solvent Distillation and Recycling .....................  15
                        Onsite Antifreeze Recycling ..............................  "16
                        Inventory Control and Better Housekeeping ............. . .....  16
                        Improved Waste Management Cost Tracking .................  17

-------
                      Additional Options 	•	   19
                      Options Ranking	'.	   19
               6.  FEASIBILITY ANALYSIS	   22
                      Low VOC Paints, (Water Borne Coatings)  	   22
                      High Volume Low Pressure (HVLP) Paint Application System	   23
                      Gun Washer Station	   26
                      Aqueous Chemicals and Parts Washers	   28
                      Onsite Solvent Distillation and Recycling of Solvents  	   28
                      Onsite Antifreeze Recycling	   30
                      Potential Barriers  	   31
               7.  IMPLEMENTATION PLAN	   33
               8.  CONCLUSION	   34
                      Applicability to Other VMFs	   36
Appendix A. Worksheets

Appendix B. Estimated Uquid and Solid Wastes

Appendix C. Alternative Coatings Article

Appendix D. Factsheet

Appendix E. Economic Feasibility of Washwater Recycling System

Appendix F. Acme Product Information

Appendix G. Vendor Information

Appendix H. Analysis of Alternative Coatings

Appendix I. Onsite Distillation Recycling Unit Information

-------
                                     LIST OF FIGURES





Number                                                                             Page



1      Pollution Prevention Assessment Procedure	:	  5



2      Estimated Liquid Hazardous Waste Generation (USPS Buffalo VMF 1991)	  9



3      Estimated Annual Solid and Hazardous Waste Management Costs	  10
                                             VI

-------
                                        LIST OF TABLES
Number
                                                                                         Page
 1      Estimated Annual Solid Waste Generated from Vehicle Maintenance Operations
       (USPS Buffalo, New York)	  9

 2     Key Ways to Maintain and Improve a Pollution Prevention Program  	  18

 3     Qualitative Ranking of Selected Options	  20

 4     Water Borne Non-Electrocoating	  23

 5     Coating Usage, Solid Waste Generation and VOC Emissions
       as a Function of Transfer Efficiency	  24

 6     Cost/Benefit Analysis: HVLP Paint Application System	  25

 7     Cost/Benefit Analysis: Gun Washer Station  	  27

 8     Cost/Benefit Analysis: Solvent/Thinner Distillation Unit	  29

 9     Cost/Benefit Analysis: Small Antifreeze Recycling Unit	  31

10     Potential Barriers to Pollution Prevention Options	  32

11     Implementation Plan	  33

12     Potential Waste Reduction and Cost Savings for Selected Options
       (reductions are compared to current practices)  	  35
                                               VII

-------
                      ACKNOWLEDGEMENTS
Funding for this project was provided by the United States EPA and the
United States Postal Service.    The  EPA  Office of  Research and
Development Risk Reduction Engineering Laboratory also cooperated and
assisted in this project.   Special thanks are extended to Jim Rusiniak,
Charlie Vidich, Kevin Ferguson,  and Mary Bordonaro of the USPS and
John Filippelli, Steve Petrucelli, Palma Risler, and Ken Stone of the U.S.
EPA.
                                 viii

-------
INTRODUCTION

Background

       The Environmental Protection Agency (EPA) Region II has established a regional policy to actively
pursue pollution prevention at federal facilities. In response to EPA Region II outreach efforts, the United
States Postal  Service Northeast Region requested technical assistance to explore ways to reduce the
amount of waste generated at the general mail facility and the vehicle maintenance facility located in Buffalo
New York. The United States Postal Service (USPS) is committed to source reduction and recycling as
sound environmental practices.  USPS policy is to reduce waste and pollutants at the source of generation.
Following source  reduction,  postal priorities for  solid and liquid nonhazardous and hazardous waste
management are recycling, energy conservation and recovery, waste treatment, and (as a last resort) waste
disposal  (USPS Waste Reduction Guide. AS 552).  The Postal Service's goal is to reduce waste 25 percent
from 1992 levels by December 1993 and an additional 25 percent by December 1995. In addition, the Postal
Service is committed to reducing by 1995 the use of 17 hazardous chemicals identified by EPA's 33/50
Program. A detailed  explanation of pollution prevention and  its benefits is presented below.  The Postal
Service intends  to use the results of this study to serve as  a model for Postal Service facilities in the
Northeast region, and if possible, in other parts of the country as well.

       The project  was  initiated in January, 1992.  The assessment team,  comprised of SAIC staff,
conducted the onsite assessment of the Buffalo facility in March, 1992.  An initial briefing was held to
acquaint Postal Service officials with the assessment team  members, to discuss site visit objectives, and to
organize the onsite information gathering process.  In addition,  the assessment team gave a half day
presentation to  Postal Service and  EPA representatives  from the Northeast region.  The  presentation
provided an overview of pollution prevention concepts, waste management issues pertinent to the Postal
Service, an explanation of the pollution prevention opportunity assessment process,  and a discussion of
overall project goals.  The assessment team spent three days at the Buffalo facility and viewed the areas
where wastes are generated;  collected process information; interviewed facility personnel; identified waste
management  procedures; identified procurement procedures; gathered information concerning waste
generation, disposal  methods and costs; and local waste handling/reduction programs. A color slide log
of the assessment and accompanying text was prepared.

       The assessment team continued to collect information  by phone after the site visit. The assessment
team identified the most significant waste streams based on the quantity of waste generated, chemical
constituents, and  associated disposal  costs. Analysts then  identified and evaluated options for waste
reduction for each process found at the Buffalo facility using the assessment worksheets completed during
the site assessment.  Appendix A contains worksheets completed by USPS staff and used in this report.
In addition, team members explored several options that could also apply to other Postal Service facilities.

       The assessment covered both the general mail facility and the vehicle maintenance facility which
are located  at the Buffalo Postal  Service site. The findings for each of these two facilities are reported
separately  This report presents the findings from the assessment of the vehicle maintenance facility.
Findings for the general  mail facility are found in the report entitled, Pollution  Prevention Opportunity
Assessment General Mail  Facility.

Purpose

       The purpose of this project is to conduct a pollution prevention opportunity assessment to identify
source reduction and recycling options for both hazardous and nonhazardous wastes generated at the
vehicle maintenance facility.  This report summarizes the results  of the  pollution prevent,™ opportunrty
assessment and explains specific options and their associated costs and benefits. The Postal Serv.ce can

-------
 use this report as the basis for its pollution prevention implementation plan.  Both source reduction and4
 recycling alternatives have been considered for the selected waste streams.

 Site Description

        The USPS General Mail Facility (GMF) and Vehicle  Maintenance Facility (VMF) are located in
 separate buildings at 1200 William Street, Buffalo, New York, a site encompassing approximately 25 acres.
 Both facilities were designed and built to USPS specifications.  The USPS began leasing the site in 1963 and
 purchased it in 1979. The VMF is located in a one story building that covers 121,061 gross square feet with
 10,100 square feet of office space. The VMF maintains a fleet  of 1,200 vehicles. Approximately 734 of the
 vehicles are city  based and the remaining 464 are based in the associated offices. Types of vehicles used
 by the Postal Service range from light delivery vehicles to tractor trailers. Vehicle maintenance is performed
 by 32 automotive technicians. Facility working hours are 5:00 am to 11:30 p.m. Monday through Saturday.
 The major operations are vehicle repair and servicing and painting.

        The floor space at the VMF is divided into a five separate areas: 1) an office space  area, 2) a storage
 area, 3) a painting area, 4) a service bay area, and 5) a vehicle power-washing area.  The painting, service
 bay, and vehicle power-washing areas are the sources of the  largest volumes of wastes generated at this
 facility.  As a result,  this report will focus on these operations at the facility.

 PURPOSE AND  BENEFITS OF POLLUTION PREVENTION

        Prior to developing and implementing a pollution prevention program, it is imperative that USPS
 employees understand pollution prevention and its components.  The following sections describe the goals,
 concept, and benefits of pollution prevention and the procedure for conducting an opportunity assessment
 similar to those conducted under this project.  The USPS has a series of pollution prevention related guides:
 Waste Reduction Guide (AS 552), Recycling Guide (AS 550). Stormwater Management Program Guide, and
 Hazardous Waste Guide  (AS 553).  These  USPS guides contain step by step  assessment procedures,
 suggested pollution prevention best management practices and technologies, and  helpful worksheets.  They
 also explain USPS pollution prevention policies and waste reduction goals. A comprehensive USPS facility
 pollution prevention program will incorporate the policies,  plans and programs contained in these USPS
 documents.

 Pollution Prevention - Goals

        The ultimate goal of pollution prevention is to reduce present and future threats to human health
 and the environment. Pollution prevention is any practice which reduces the amount of any hazardous
 substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment
 (including fugitive emissions) prior to recycling, treatment, or disposal; and any practice which reduces the
 hazards to public health and the environment associated with the release of such substances, pollutants,
 or contaminants (Pollution Prevention Act  of  1990).  Pollution prevention is a fundamental shift from
 treatment of wastes.  Source reduction does not include any  practice which alters the physical, chemical
 or biological characteristics of the volume of a hazardous substances, pollutant, or contaminant through a
 process or activity which itself is not  integral to and necessary for the production of  a product or the
 providing of a service.

        Pollution prevention is a  multimedia approach that minimizes or eliminates pollutants released to
 land, air, and/or water without shifting pollutants from one  media to another. Pollution  prevention is
 accomplished by equipment or technology modifications, process or procedure modifications, reformulation
 or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance,
training, or inventory control.

-------
       Pollution prevention is the environmentally preferable option in the waste management hierarchy.
Wastes that can not be prevented should be recycled in an environmentally sound manner. Pollutants that
cannot be prevented or recycled should be treated in an environmentally safe manner. Disposal or other
release into the environment should be utilized  only as a last resort and should be performed in  an
environmentally safe manner.

       Recycling is using, reusing, or reclaiming materials/waste, including processes that regenerate a
material or recover a usable product from it (USEPA. Facility Pollution Prevention Guide).  There are many
ways materials can be reused or reclaimed.  Reusing products, such as reusable beverage containers,
results in decreased purchases  of  raw materials and reduces pollutants generated  from making new
products.

Pollution Prevention - Benefits

        Facilities gain both direct and indirect benefits by implementing pollution prevention options. The
following were presented in the U.S. Postal Service Waste Reduction Guide.

The Postal Service will benefit from waste reduction by:

        •       Significantly reducing the amount of pollution released to the environment.

               Obtaining reductions faster than might be achieved by waiting for statutes or regulations
               to take effect and by achieving permanent solutions where source reductions occur.

               Providing the flexibility to choose cost-effective and environmentally sound solutions that
               will also result in improved efficiency and net economic growth.

                Creating clear expectations in the form of a national goal for targeted  chemicals.

                Providing positive incentives through public recognition  of its efforts and by working to
                identify regulatory barriers.

                Saving capital.

                Minimizing  paperwork.

                Reducing liability.

                Possibly changing the status of facilities that generate hazardous waste from Large Quantity
                Generator to Small  Quantity or Very Small Quantity Generator status.

                Reducing long-term risks of an uncertain nature and scope-such as the cumulative effects
                of toxic substances-without waiting for research.

        The analyses of source reduction and recycling options in this report focus primarily  on the direct
 benefits to the Buffalo facility  in savings in disposal, operational, and procurement costs.  However the
 indirect benefits of pollution prevention may be equally significant.  One md.rect benefrt s reduced habrtrty.
 The LISPS will lower its liability under RCRA's "cradle to grave" provisions and the Provisions of the Federal


                                 ^

-------
 cleanup.  Having less hazardous or toxic materials on-site will also mean reduced occupational hazards;.
 and, therefore, improved worker health and safety. A pollution prevention program can generate good will
 in the community and workplace, enhance the USPS's public image, and foster environmental awareness
 among employees.  By decreasing the amount of hazardous waste shipped offsite for disposal, the DSPS
 may also reduce the costs associated with tracking and filing paper work required for hazardous waste
 manifests.

 Pollution Prevention Opportunity Assessment Procedure

        In general, this project follows the EPA procedures outlined in the Waste Minimization Opportunity
 Assessment Manual (EPA/625/7-88/003) and is consistent with the concepts contained in EPA's Facility
 Pollution Prevention Guide (EPA/600/R-92/088) and shown in Figure 1.  These procedures are consistent
 with the waste reduction approach contained in the DSPS publications Waste Reduction Guide (AS 552),
 Recycling Guide (AS 550), and Hazardous Waste Guide (AS 553).

        Pollution prevention opportunity assessments have four phases: 1) planning and organization, 2)
 assessment, 3) feasibility analysis, and 4) implementation.  During the planning and organization phase, a.
 commitment from management is ensured, overall assessment goals are set, and the assessment program
 task force is organized.  The  assessment  phase involves quantifying current waste generation and
 management practices, including collecting process and facility data, setting priorities and selecting
 assessment targets, selecting assessment team members, reviewing data, generating options, and screening
 and selecting options for further study. The feasibility analysis phase is a technical and economic evaluation
 of the selected options.  Options are ranked and selected for implementation. The implementation phase
 puts the options into action. This may require justifying projects and obtaining funding, installing equipment,
 implementing procedures, and evaluating the performance of each option. This report covers the first three
 steps and provides the framework for implementation.

 PROCESS REVIEW

        Approximately 2,500 to 3,000 routine maintenance or unscheduled repair jobs are performed at this
 vehicle  maintenance facility per year.   Some of the major  operations that take place include:

               vehicle painting (partial and/or touch-up work)

               automotive maintenance, repair, and washing

               fueling

        This report  will focus on operations  at the vehicle painting and automotive repair and washing
 stations. Fueling operations were not evaluated as part of this assessment due to limited resources and are
 not discussed in this report.

 Painting Operations

        The Buffalo VMF painting operation services approximately 1,200 vehicles.  Vehicles are inspected
every six months to determine if painting and/or body repair work is required. Approximately 700 vehicles
per year receive partial or touch-up painting maintenance.  In 1991, approximately 500 complete vehicles
were painted. The USPS is in the process of replacing, over a three year period, the quarter ton jeeps with
Long Life Vehicles (LLVs). Phasing-in the LLVs has increased the number of vehicles requiring a complete
paint job.  As delivered by the supplier the LLVs are equipped with a coat of primer paint. At the VMF they

-------
                                  Establish Pollution Prevention Program
                                          • Executive Laval Decision
                                          • Policy Statement
                                 	.Consensus Building
                                            Organize Program
                                             • Name Task Foroe
                                             * State Goals
                                       Do Preliminary Assessment
                                            •  Collect Data
                                            •  Review Site.
                                            •  Establish Priorities
                                           Write Program Plan
                                          • Consider External Group*
                                          • Define Objective!
                                          • Identify Potential Obstacles
                                          e Develop Schedule	
                                         Do Detailed Assessment
                                         •  Name Assessment Team!*)
                                         •  Review Data and SKe(s)
                                         •  Organize and Document Information
                                   Define Pollution Prevention Options
                                             •  Propose Options
                                  	•  Screen Options	
                                         Do Feasibility Analyses
                                             •  Technical
                                             •  Environmental
                                             *  Eo
                                        Write Assessment Report
                                           Implement the Plan
                                               •  Select Projects
                                               •  Obtain Funding
                                               •  Install	
                                            Measure Progress
                                               • Acquire Data
                                               * Analyze Results
alyze
                                  Maintain Pollution Prevention Overview
         Figure 1   Pollution Prevention Assessment Procedure.
Source: EPA Facility Pollution Prevention Guide (EPA/600/R-92/088)

-------
 are painted Postal Service colors. As the phase-in is completed the number of vehicles requiring an entire
 paint job is expected to decrease. The long term impact on the number of vehicles requiring painting is ,
 uncertain.  On average the jeeps were repainted every three years.  If the LLV paint is more durable they ,
 may not have to be painted as frequently.

        Materials and equipment frequently used and purchased by the USPS to maintain their painting
 operations include: four or five different colors of paint; solvents for paint thinning; a spray gun to apply the
 paint; a sander to prepare an area of the vehicle for painting; lacquer thinner to clean spray guns used to
 apply paint to vehicles; solvents for cleaning; paint equipment; paint filters; and masking paper, used to
 protect areas of the vehicle not intended for painting.

        Vehicle painting has several steps.  First, vehicles are visually inspected and,  if necessary, a solvent
 degreaser is  applied by hand to remove any oil or grease from the area to be painted. Secondly, the area
 is sanded using a sand-vac and lightly polished. Finally, the area is primed and painted.  Most body work
 (i.e., dent and collision damage repair) is performed offsite by a contractor, small jobs are performed at the
 VMF. Best professional judgement is used to determine the amount of paint mixed for each job. Four to
 five colors are used:  gray for primer, black, off-white or beige (for LLVs), and white.  Paint is applied using
 an airless spray gun system (Sharpe Model 479).  Paint guns are cleaned with lacquer thinner in a solvent
 sink.

 Automotive Maintenance and  Repair Operations

        Automotive maintenance and repair operations include routine scheduled maintenance as well as
 unscheduled repairs. USPS directives determine a vehicle's maintenance needs based on the vehicle's
 mileage.  (Selected USPS  directives were reviewed by the assessment team and  the fluid  replacement
 schedule appeared to be  reasonable).  At scheduled intervals, each vehicle is sent to the VMF for a
 maintenance that  may include oil changes, check-ups and additions of other fluids (e.g., transmission, brake,
 and antifreeze), carburetor cleaning, as well as replacement of worn or broken parts (e.g., batteries, shock
 absorbers,  radiators, tires, mufflers, electrical components, or windshields).

        In addition to repairs and tune-ups, Postal Service vehicles are washed to maintain the cleanliness
 of the fleet. Vehicle washing takes place in three locations. Mail delivery vehicles (LLVs and jeeps) and
 small and medium sized trucks are washed in an industrial vehicle washing station located in a covered area
 next to the VMF building.  A power washer (Graco brand) located in the VMF area is used to wash vehicles
 prior to their  being repaired, and to clean large parts.  Large trucks are washed in the VMF parking lot by
 a commercial vehicle washing firm.

        Frequently used materials and equipment at the VMF include: engine oil and oil filters;  transmission
 fluid; brake fluid; antifreeze; carburetor cleaner; cleaning solvents; as well as parts such as batteries, shock
 absorbers,  brakes, radiators, tires, tire rims, mufflers, electrical components, and windshields. In addition
 small amounts of adhesives and epoxies,  and cleaning compounds (for  the power  washer), are also
 purchased.  Petroleum naphtha solvent is used for cleaning engine parts.  Brake parts are cleaned in an
 organic solvent. Both engine and brake parts are cleaned in solvent sinks or parts washers. There are four
 engine parts washers and three brake parts washers onsite.

 SUMMARY OF VMF WASTE GENERATION

        Determining the composition and quantity of wastes provides a baseline description of waste type,
quantity, and  waste management costs. This baseline information is used to identify the major wastes and
evaluate  source reduction and recycling opportunities.  To assess waste generation from the VMF, the
assessment team reviewed assessment worksheets, hazardous waste manifests, and  interviewed Postal
Service  employees.  Prior  to the site visit,  Postal Service employees were provided with assessment

-------
worksheets to record raw material inputs, hazardous and nonhazardous waste quantities generated, disposal
methods and costs (see Appendix A).  Information used for this report was based on hazardous waste
manifests covering a three month  period, from January to March, 1992. According the USPS employees
this three month period represents typical waste generation rates and management costs at the VMF.  These
records were  used to estimate annual waste generation  rates and  costs.  Although incomplete, the
worksheets and hazardous waste manifests were the most accurate source of information available that
described waste quantities and disposal costs at this facility. Nonhazardous solid waste, such as cardboard,
plastic, paper, and glass, are generated at the VMF. Disposing of these wastes from the VMF are paid for
as part of the overall General Mail  Facility disposal costs.  A discussion of the quantities and management
costs as well as pollution prevention options for these wastes are found in the companion report Pollution
Prevention Opportunity Assessment General Mall Facility.  Painting and  maintenance and repair operations
at the VMF use several types of hazardous material, and generate a number of hazardous wastes.

        The Postal Service has voluntarily committed to  reducing their emissions of the seventeen toxic
chemicals targeted under the U.S. EPA 33/50 Program. Five 33/50 Program chemicals are used by USPS
in the VMF.  Of these, four are found in paints used by the USPS painting operations (toluene, xylene,
methyl ethyl ketone, and methyl isobutyl ketone).  Lead is contained in lead acid batteries and  radiators.
The 33/50 Program is EPA's voluntary pollution prevention initiative to reduce national pollution releases and
off-site transfers of 17 toxic chemicals by 33 percent by the end of 1992 and 50 percent by the end of 1995.
The Agency is inviting companies to participate by examining their own industrial processes to identify and
implement pollution prevention practices for these chemicals. The Program aims to reduce releases and
off-site transfers of a targeted  set of 17 chemicals from a national total of 1.4 billion pounds in 1988 to 700
million pounds by 1995, a 50 percent overall reduction. In addition to the 17 target chemicals listed below,
EPA also encourages companies to reduce releases of other pollutants.


           •       Benzene                         •       Methyl  Ethyl  Ketone

           •       Cadmium and Compounds         •       Methyl  Isobutyl Ketone

           •       Carbon Tetrachloride              •       Nickel and Compounds

           •       Chloroform                       •       Tetrachloroethylene

           •       Chromium and Compounds        •       Toluene

           •       Cyanide and Compounds          •       1,1,1-Trichloroethane

           •       Lead and Compounds             •       Trichloroethylene

           •       Mercury and Compounds          •       Xylenes

           •       Methylene Chloride

 Painting Operations

        RCRA hazardous wastes generated from painting operations include waste paint, paint thinner, and
 paint equipment cleanup solvent. The Postal Service contracts with a commercial service that leases and
 maintains the  solvent sink used to clean painting equipment.  The company removes spent solvent and
waste paint, and replenishes the sinks with fresh solvent  at scheduled  intervals.

        Paint is applied with an airless spray gun. Approximately 70 percent of the sprayed paint is lost due
to overspray, bounce  back or atmospheric emissions. The painting area is periodically swept to remove
 overspray paint solids which have accumulated on the floor. The paint solids are disposed of in the trash.
Atmospheric emissions from painting (i.e., the evaporation of volatile organic compounds (VOCs) contained

-------
in the paint and cleaning solvents) are collected and filtered by the ventilation system and emitted to the
atmosphere. The paints used in the VMF are formulated with approximately five pounds of VOC per gallon.
The majority of these VOCs are lost during the spraying operation and as the paint is dried. Nonhazardous
wastes from painting operations include paint cans, aerosol cans, masking tape, and paint filters.

Automotive Maintenance and Repair Operations

       Automotive maintenance and repair operations generate a variety of RCRA hazardous wastes; used
oil and filters (transmission, brake fluid, engine oil), antifreeze, lead acid batteries, and soiled absorbent
(cracked corn).  Waste oil is stored onsite and periodically removed by a commercial 'service that re-refines
the oils and sells them back to the  Postal Service. Oil filters are drained and shipped offsite to a commercial
waste hauler. Used antifreeze is stored onsite and disposed of as a hazardous  waste. Batteries are sent
offsite to a battery reclaiming operation.  Small spills of engine fluids or other liquids are absorbed using
cracked corn which is removed by a commercial waste management service.

       Used solvents from cleaning engine  and brake parts are characteristic  RCRA hazardous wastes.
The Postal Service contracts with a commercial service that leases and maintains the solvent sinks, removes
spent solvent, and replenishes the sinks with fresh solvent at scheduled intervals.  The shop floor is
periodically hosed down with water or cleaned with a commercial floor scrubbing machine.  Floor washwater
is disposed of down floor drains to an oil and water separator and then discharged to the sanitary sewer.
Sludge from the oil and water separator is periodically removed and disposed of as a hazardous waste.

       A number of different nonhazardous  wastes are also generated.  Non-repairable equipment such
as brakes, shocks, radiators, tires, tire rims, mufflers, electrical components, and windshields are removed
and replaced.  Metal parts such as wheel rims and mufflers are collected and  sent to a metals recycler.
Tires are sent to a tire shredding operation. Large truck tires are sent to a tire retreader and sold back to
the USPS. Repairable parts such as brake calipers/rotors/drums, alternators, fuel pumps, carburetors, and
power train components are removed and replaced. The broken parts are sold to a commercial service that
rebuilds or repairs the equipment  and sells the restored equipment back to the  USPS.

       Table 1  presents estimated solid waste quantities of some of the wastes  generated, by waste type.
Figure 2  presents estimated volume of liquid hazardous  waste generated at the Buffalo VMF.  Figure 3
estimates annual solid and  hazardous waste  management  costs.   A detailed  break-down of each
wastestream including quantity generated, management method, annual disposal cost and the source of the
data is found in Appendix B. Table 1, Figures 2 and 3, and Appendix B  are based on information obtained
from the worksheets described earlier, supplemented by interviews and waste manifest data.

                   TABLE 1. ESTIMATED  ANNUAL SOLID WASTE GENERATED
                         FROM VEHICLE MAINTENANCE OPERATIONS
                                  USPS BUFFALO, NEW YORK
                 Waste Type	Annual Quantity
                 0" Filters                       1,374 Ibs or approximately
                                                1,800 filters
                 Lead Acid Batteries              280 batteries
                 Brakes                         1,200 -1,500 sets
                 Cracked Corn Absorbent         30-60 gallons
                 Soiled Rags                     8,515 rags
                 Radiators                       280 radiators

-------
                 Oil  57.5%
                                                         Antifreeze 6.2%
                                                    Paint Related Waste  9.7%
  Engine & Brake Parts 26.6%
                     Total 4,917 gal/year
WASTE TYPE
Used Antifreeze
Used Oil (engine, brake fluid,
transmission fluid)
Engine Parts Cleaning Solvent1
Brake Parts Cleaning Solvent1
Painting Equipment Cleanup •
Solvent 2
Waste Paint/Thinner3
GENERATING
AREA
Service Bays
Service Bays
Service Bays
Service Bays
Painting
Painting
WASTE VOLUME
(GAL/YR)
300
2,830
957
351
202
277
Notes:
               1.      Assumes 1 gallon of waste solvent equals 6 Ibs.
               2.      Assumes 1 gallon of waste solvent equals 5.5 Ibs.
               3.      Assumes 1 gallon of waste solvent equals 5 Ibs.
       Figure 2. Estimated Liquid Hazardous Waste Generation.
                      USPS Buffalo VMF 1991

-------
                       Absorbent 2.9%
                  Soiled Rags
    Paint Equipment
    Cleaning Solvent 11.5%
Waste Paint/Thinner 3%
                              Engine Parts Cleaning Solvent  17.2%
                                                                     Oil Filters 11.9%
                   Radiators 32%
                                                                      Used Tires  8%
                                                               Brake Parts Cleaning Solvents 10.5%
                                   Total $21,645/year
                              WASTE1
                Paint Equipment Cleaner Solvent3
                Waste Paint/Thinner3
                Engine Parts Cleaning Solvents3
                Brake Parts Cleaning Solvents3
                Soiled Rags
                Absorbent Cracked Corn
                Radiators
                Oil Filters
                 Used Tires
               Notes:
               1.
               2.
               3.
                                  ANNUAL DISPOSAL
                                       COSTS2
                                        $2,496
                                        $ 592
                                        $3,744
                                        $2,262
                                        $"596
                                        $  590
                                        $7,000
                                        $2,565
                                        $1,800
The following waste streams are not included in the table because the VMF does
not pay for disposal:  batteries, antifreeze, brakes, oil
Sources of data include USPS and waste manifests.
Costs include solvent, servicing, and disposal.
             Figure 3.  Estimated Annual Solid and Hazardous Waste Management Costs.

                                               10

-------
OPTIONS ASSESSMENT

        The Buffalo VMF employees have undertaken or will enact in the near future a number of source
reduction and  recycling activities.  These practices are briefly described.  The  assessment  identified
additional pollution prevention opportunities that build upon and expand the current pollution prevention
activities.  The specific opportunities are also discussed.

Existing Pollution Prevention Practices

        The VMF painting staff already have a number of good operating practices to minimize equipment
cleanup wastes.  Separate  paint cups are used for the different color paints.  Additionally, the technician
schedules painting so that  vehicles requiring lighter color paint are painted before those requiring darker
paint. He scrapes out the paint cup and collects unused paint for reuse prior to cleaning the equipment in
the solvent sink.  Other existing pollution prevention practices are:

        •       Excess paint is saved in one gallon containers and reused on the next appropriate job.

               Parts washing takes place irva solvent sink.  The sink recirculates "dirty" solvent to give the
               paint spray gun an initial rinse prior to a final rinse with clean solvent.  The spent cleaning
               solvent is recycled offsite by a commercial waste management firm.


Automotive Maintenance and Repair

        The automotive repair and maintenance operation also implements a variety of important pollution
prevention measures. As a result of the assessment site visit and preliminary findings the VMF staff have
determined that they can reduce the number of engine and brake parts washers by  three to four units.
Assuming the frequency of  pickups does  not increase for the remaining parts washers this will significantly
reduce  hazardous waste generation. Additional pollution prevention activities include:

               Purchasing re-refined engine oil for use in all vehicles.

               Sending used tires to a tire recycler and purchasing retread tires for trucks.

               Sending repairable parts such as generators offsite to be rebuilt.

               Eliminating methylene chloride in brake cleaner solutions and chlorinated solvents in parts
               cleaners.

               Using recirculating solvent sinks to reduce solvent use.

               Recycling spent brake cleaning solvent and parts cleaning solvent  offsite.

               Collecting used oil (brake fluid, transmission fluid, engine oil) for offsite recovery (re-refining
               or incineration for energy recovery).

               Recycling batteries through an outside contractor who recovers the lead and acid.

               Recycling metal parts, such as wheel rims,  by sending them to a smelter.
                                                11

-------
 Recommended Source Reduction and Recycling Options

        The assessment team identified additional options for reducing or eliminating wastes for both the
 painting operation and the maintenance and repair operations. Pollution prevention options for cardboard
 office paper and glass are discussed in the companion report Pollution Prevention Onpnrtunfty Assessment
 General Mail Facility. The focus of this section is on reducing hazardous wastes.          	

 Options

 Painting Operations Waste:

               Low VOC Paints, (water borne or high solids coatings)

               High Volume Low Pressure (HVLP) Paint Application System

        •       Paint Mixer System

               Gun Washer Station

               Operator Training

               Paint Can Reduction and Recycling

        •       Buffing Pad Cleaner

        •       Onsite Solvent Distillation and Recycling


 Automotive Maintenance and Repair Waste:

        •       Use of Aqueous Parts and  Brake Cleaner

               Good Operating Practices for Parts Cleaning

               Onsite Solvent Distillation and Recycling

               Onsite Antifreeze Recycling

               Inventory Control and Better Housekeeping

               Improved Waste Management Cost Tracking

               Employee Participation in Pollution Prevention


Options for Painting Operations

        Paint wastes account for approximately 11.8 percent of the total liquid hazardous waste generated
at the VMF and approximately half the hazardous waste management costs. Major hazardous wastes from
paint application are paint, equipment cleaning solvents and VOC (volatile organic compounds) emissions.
VMF facilities have two major options for reducing painting-related waste. First, switch to low VOC emitting
coatings such as water borne paints.  Second,  use high transfer efficiency delivery systems, such as a HVLP

                                               12

-------
 spray gun, to reduce the amount of paint required for completing the job.  Water borne coatings and HVLP
 spray system can significantly reduce both VOC emissions and liquid hazardous waste generation from the
 Buffalo VMF operations.

        The Clean Air Act amendments will impose stronger VOC emissions standards on industry. As a
 result facilities performing automotive  painting will have to pay closer attention to their associated VOC
 emissions.  Many states such as California and New York have begun establishing VOC emissions levels
 for paints used in auto refinishing.  New York State expects to promulgate regulations in November, 1992
 setting the VOC emissions level for entire vehicle painting jobs at 5 Ibs/gal and VOC emissions for touch-up
 repair work at 6.2 Ibs/gal. The emission standard for New York City is currently 5 Ibs/gal. (New York State
 Department of Environmental Conservation, Bureau of Air Resources. Ms. Ton! Norfleet in conversation with
 Dina Li (SAIC-July 9,1992). Switching to water borne coatings and using a HVLP system will significantly
 reduce VOC emissions from the Buffalo VMF painting  operations.

 Low VOC Paints (Water Borne and High Solids Coatings)

        There are a  number of  alternative low VOC emitting paints or coatings available.  These include
 water-borne electrocoating, water borne non-electrocoating, two component high solids, single component
 high-solids, and isocyanate free paint.  A  recent article in Products  Finishing magazine reviewed these
 coatings and is enclosed in Appendix C. Water borne non-electrocoating coatings are most compatible with
 VMF operations and offer the USPS the  greatest opportunity to significantly eliminate paint related hazardous
 waste.

        Water borne coatings are formulated with water versus organic solvents. The average solvent based
 coating such as that used  at the Buffalo VMF  contains 5-6 pounds of solvent per gallon.  Water borne
 coatings contain between 0.5 to 3.4 pounds of solvent per gallon.  Use of water  borne coatings  significantly
 reduces VOC emissions.  Water borne coatings clean up with soap and  water, totally eliminating organic
 solvent clean up waste.

 High Volume Low Pressure (HVLP) Paint Application System

        HVLP spray guns use a high volume of air delivered at low pressure to atomize paint. Conventional
 air assisted guns propel paint from 35 - 80 psi, in contrast, the HVLP guns run  at 8 -10 psi. The decrease
 in pressure results in significantly reduced paint loss due to bounce-back and overspray.  HVLP guns and
 other high transfer efficiency equipment reduce raw material costs since  less paint is needed to cover the
 same area. Higher transfer efficiency equipment also improves product quality because visibility in the spray
 booth is clearer. In addition, the decrease in over-spray leads to cost savings in terms of less frequent filter
 changes and faster booth clean-up.

 Paint Mixer System

        The amount of paint needed for a job and the mixture of paint thinner to paint is presently measured
 by the painter using best professional judgement.  Depending on the painter's experience this  can result in
 improperly formulated paint and/or left over or surplus paint. Commercially available paint mixers accurately
 measure and weigh the amount of paint that needs to be mixed according to manufacturers specifications.

 Gun Washer Station

        Spray guns and equipment are currently washed by hand in an open solvent sink. Dirty solvent is
 used for initial cleaning followed by a final  flush with fresh solvent. The operator controls the amount of
solvent used. Gun washer stations are enclosed sinks with specially designed mounting stations for holding
spray guns, cups and lids,  hoses, pots and other accessories.  The  primary  advantages to  using a gun

                                               13

-------
washer station Instead of manually cleaning the guns in a parts washer sink are a substantial reduction in
solvent use, lower time and labor costs, and a reduction in occupational hazard and VOC emissions.

Operator Training

       In-house operator training can reduce paint wasted due to poor spraying technique. Proper spray
technique achieves a 50 percent overlap In paint coverage. Over spray from air assisted guns is decreased
by keeping the air pressure low and the spray gun perpendicular to the surface. Videotaping the operator
while he is painting is a valuable training tool.

Paint Can Reduction and Recycling

       Paint is presently purchased in quart or gallon metal containers. Empty paint cans are drained and
thrown away in the trash. It may be possible to order paint in 5 gallon reusable plastic pails or totes. When
empty the pail would be picked up by  the supplier. Since the VMF requires a large quantity of a limited
number of colors, buying in bulk may prove feasible. Unless the product is likely to dry out or expire before
being consumed, the existing paint supplier should be contacted to see if they offer bulk purchases in
reusable containers.

       It may be possible to recycle empty metal paint cans. In some cases the bottom of the can may
have to be cut out to ensure all paint  has been removed.  The VMF staff should determine whether the
smelter at which scrap metal is being recycled will  accept empty paint cans as well.

Buffing Pad Cleaner

       A simple device is available on the market for cleaning buffing pads used to polish the newly painted
vehicles.  The buffing pad is strapped  into place on top of a machine the size of a ten gallon drum. A
rotating disk brushes off the paint dust contained in the pad, which can be re-used rather than disposed of.

Onsite Distillation and Recycling  of Paint Related Solvent

       This option is discussed  in the  vehicle maintenance and repair section that follows.

Options for Vehicle Maintenance and Repair Operations

Aqueous Chemicals and Parts Washers

       Brakes and engine parts are currently cleaned  in seven solvent sinks or parts washers. Parts
washers are self-contained baths with  recirculating and/or agitated compartments.  Solvent recirculates
continuously from the solvent drum to the solvent wash tray where the parts are cleaned.  Although using
solvent sinks helps minimize solvent or cleaning solution use and losses, the diverse problems associated
with solvent use dictate that solvents should only be used when no other cleaner is suitable for the job.

       Engine and brake parts cleaning is a significant source  of hazardous waste.  Based on waste
production and costs experienced from  January through the end of March 1992,5,746 pounds (957 gallons)
of hazardous solvent waste from 4 engine parts cleaning sinks and 2,106 pounds (351  gallons) of solvent
waste from 3 brake cleaning sinks are produced annually, at a cost of $3,744 and $2,262 per year,
respectively.  These charges cover solvent cleaner replacement costs and waste treatment. Solvent sink
maintenance and solvent waste  disposal costs represent approximately one third of the  VMF's total
hazardous waste management costs.
                                               14

-------
        The appropriate cleaning option depends on how clean parts need to be. The first option should
 be mechanical cleaning such as hand brushing. Many parts need only be cleaned to remove dirt and grime
 to allow the mechanic to visually inspect the part.  Other parts require more thorough cleaning.  Where
 possible, aqueous or biodegradable cleaning solutions should be used instead of solvent based compounds
 to eliminate the hazards associated with solvent degreasing systems.  Other parts such as bearings must
 be extremely clean to ensure top  performance.  Solvent typically has superior cleaning performance to
 aqueous cleaners. However, all parts may not need to be super clean. The VMF manager should evaluate
 how clean parts need to be to see if it is possible to replace some or all of the existing solvent sinks with
 aqueous parts washers.

        The primary advantage of using an aqueous cleaning  system is that it reduces the occupational
 hazard and waste management costs associated with solvent parts cleaning. Aqueous cleaners have been
 found to  be a viable substitute for many parts  cleaning  operations  currently using solvents.   These
 detergents, acids, and alkaline compounds displace the oil rather than dissolving it in organic solvent.  A
 cleaning chemical should  be used that readily releases or separates the collected oil.  Aqueous cleaning
 chemicals are used in parts washers that use mechanical cleaning action including ultrasonic, air agitated,
 pressure circulating pump, or hydraulic action parts washers.

 Operating Practices for Parts Cleaning

        When no substitute is available for solvent cleaners, emphasis should be placed  on minimizing
 solvent waste generation by:

        •      Eliminating the need to use the solvent by first  determining whether cleaning is necessary
               and  just how clean a part needs to be.   Rigorous chemical cleaning should only be
               performed when parts require it (i.e., bearings, engine internals, etc.).  Stationary structural
               members  typically require cleaning only for inspection.

        •      Minimizing losses associated  with inappropriate usage,  equipment leaks or spills, and
               evaporation. These losses can range from 25 to  40 percent of total solvent  use.  The
               addition of drip trays to both solvent sinks and hot tanks would help  reduce these losses.


               Determine if parts and brake cleaning solvent  can  be serviced on a less
               frequent basis.  Monitor cleaning activity and test solvents to determine if
               they are spent.  Replace solvent when it is  spent rather than based on a
               scheduled pickup.


        Since the majority of the wastes coating engine parts are removed during the initial exposure of a
 part to the wash solutions, a two stage cleaning operation using two washing devices in series may be used
 to reduce the time needed to clean a heavily soiled part while  maximizing solvent potential.

 Onsite Solvent Distillation  and Recycling

        In the event the USPS continues to use solvent borne paints and  solvent parts cleaning solutions,
 an on-site distillation unit is a possible method to reduce solvent waste. Paint and paint related wastes total
 479 gallons per year, solvent parts cleaning wastes total 1,308  gallons per year.  The annual disposal cost
 for paint wastes and  solvents is $9,094.  Avoided disposal costs and a reduction in new product purchase
 costs make distillation an attractive alternative.  Four types  of liquid wastes are amendable to onsite
 recycling at the VMF:  paints, thinners, petroleum naphtha, and the brake cleaning solvent. These materials
would be distilled onsite and reused.  Distillation would be done in batches, e.g.,  paint related waste would

                                                15

-------
be distilled separately from petroleum naphtha. Distilled paint related waste can be used as paint thinner
and or paint equipment clean up. Distilled petroleum naphtha and brake cleaning solvents would be reused
for parts cleaning.

Onsite Antifreeze Recycling

        Engine coolant is a mixture of 50 percent ethylene glycol and 50 percent water.  As the coolant
circulates through the vehicle it gradually becomes contaminated and loses its cooling capacity. Industry
is taking a closer look at on-site antifreeze recycling equipment in light of the higher costs of virgin antifreeze
and the disposal costs associated with disposing of antifreeze as a hazardous waste.  Many local sewer
districts no longer accept antifreeze in the sewer system.

        The VMF buys 750 gallons of antifreeze per year at a cost of $1500 ($2.00/gal).  The Buffalo VMF
supplies approximately 450 of the 750 gallons of antifreeze to Associate Offices.  Management of used
antifreeze is the responsibility of the Associate Office VMF staff. The Buffalo VMF generates approximately
300 gallons of waste antifreeze annually which is managed  as a hazardous waste.  Recycling antifreeze
onsrte is an option to reduce waste antifreeze and raw material costs.

Inventory  Control and Better Housekeeping

        Strict inventory control procedures can reduce waste caused by expired materials,  spills and over-
stocking.  The following steps are recommended:

                Designate one employee as the Supply Manager (the Parts Manager is a typical choice)
                responsible for approving and ordering materials.  The Supply Manager checks the existing
                inventory to make sure that the item is not still in stock.

                Control access to the supply room by only allowing the Supply Manager to distribute the
                supplies to the technicians.

                Keep liquid stock on the lower shelves to  minimize  contamination of other stock and
                product loss from accidental  falls.

                Clearly label all unmarked containers with their contents and expiration date.

                Distribute stock by giving out the oldest material  first.

                When possible, buy in bulk (e.g., antifreeze) and pour materials into smaller containers for
                use  in the shop using careful transfer  procedures.  All  containers and drums should have
                self-closing, non-leak, safety spigots for easy distribution and spill  prevention.

                Perform  routine storage area inspections.

                Train technicians to maintain the smallest amount of hazardous  materials in their work
                areas.

                Use  dirty rags instead of cracked corn absorbent to clean up small spills
                and  drips.

                Employees should be trained in proper spill  prevention and control
               techniques so they know how to prevent  spills as well as contain them.
               Spill  kits should be located in  areas where spills have occurred in the past.

                                                16

-------
               USPS employees should know the location of spill prevention kits and how
               to properly use them.

               Where possible, all containers dispensing hazardous materials should be
               fitted with self-closing, safety valves.  Waste oil  receptacles and other
               collection devices should be used to collect drips.

 Improved Waste Management Cost Tracking

        Designating a separate account number for hazardous and solid waste management costs would
 improve the USPS's ability to identify and track waste management costs. Under the present system waste
 management costs are folded into the overall VMF service account. This makes it difficult to identify and
 track waste management costs.  Designating a specific account number for waste management costs has
 a number of benefits.  It would allow the USPS to more easily monitor waste management costs over time.
 Sudden or gradual increases in waste management costs could  signal changes in waste generation
 operations or improper waste management  practices that should be  investigated.   USPS staff could
 associate waste management costs with individual operations or departments.  The USPS should also
 consider apportioning or "charging" waste management  costs to the department generating the wastes.
 Making each department aware of and responsible for waste management costs adds an additional incentive
 to taking steps to reduce waste.

        More focused waste management cost accounting also supports the tracking of economic impacts
 of waste reduction options on waste management costs. Waste management is often a hidden cost.  By
 explicitly identifying these costs, facilities can weigh the costs and benefits of different waste reduction
 options and, more importantly, quantify savings or losses from instituted waste reduction techniques.

 Employee Participation in Pollution Prevention

        Active support and participation by all USPS employees is critical to the VMFs pollution prevention
 program.  Implementing the recommendations presented in this report hinges on employee commitment.
 A major factor in implementing and sustaining source reduction and recycling efforts is employee education.
 USPS staff need to understand why pollution prevention is important and  how they can help. Management
 must communicate pollution prevention goals and activities and find avenues to solicit worker input on ways
 to improve the program.

        Establishing and maintaining a successful source reduction and recycling program requires constant
 effort and monitoring. A proactive training program and open communication can help ensure proper
 performance.  Table 2 lists key ways to maintain and improve a pollution prevention program. .Appendix
 D contains a factsheet about pollution prevention at USPS VMFs. This factsheet provides USPS employees
 with information on how to reduce or recycle wastes from GMF operations.

        Pollution Prevention Resources and Training Opportunities in 1992  (EPA/560/8-92-002) is  an
 extremely helpful document that provides guidance on successful employee involvement and training.  It
 is an annual guide containing information about publicly-sponsored pollution prevention resources and
 training opportunities available across the U.S. It's goal is to provide a single source of pollution prevention
 options to those interested in learning more about such strategies.

        The document contains information such as 1) available training courses or contacts who are willing
to share experiences about establishing new training opportunities, 2)  availability of pollution prevention
 publications and videos, 3) Federal and State contacts, 4) availability of university research and training, and
5) Federal, State, and nonprofit organizations that can provide additional pollution prevention information
and technical assistance.  Additional information can be obtained by accessing the Pollution Prevention
Information Clearinghouse (PPIC), which offers a wide range of free information services.
                                               17

-------
       Complimentary copies of the manual as well as additional information on the PPIC can be obtained
by calling the Pollution Prevention Information Clearinghouse Hotline at (703) 821-4800 or writing to:

       Pollution Prevention Information Clearinghouse
       Technical Information Service
       c/o Science Applications International Corporation
       7600 A Leesburg Pike
       Falls Church, VA 22043.
     TABLE 2.  KEY WAYS TO MAINTAIN AND IMPROVE A POLLUTION PREVENTION PROGRAM
 General Goals
Specific Methods
 Integrate pollution prevention into
 corporate planning
 Provide ongoing staff education
 programs
 Maintain internal communication
 Reward personnel for their success in
 pollution prevention
 Provide public outreach and education
 about pollution prevention efforts
Assign pollution prevention accountability to the operating
units where waste is generated

Track and report program status

Conduct an annual program evaluation at the corporate
level
Make pollution prevention awareness program a part of new
employee orientation

Provide advanced training

Retrain supervisors and employees
Encourage two-way communication between employees and
management

Solicit employees' pollution prevention suggestions

Follow-up on suggestions
Cite accomplishment in performance reviews

Recognize individual and group contributions

Grant material  rewards

Consider pollution prevention a job responsibility subject to
review
Submit process releases on innovations to local media and
to industry journals read by prospective clients

Arrange for employees to speak publicly about pollution
prevention measures in schools and civic organizations.
Source: Facility Pollution Prevention Guide (EPA May 1992)
                                               18

-------
Additional Options

        The following options were considered but were not evaluated further due to poor economics,
technical limitations, or ongoing research within the USPS. A brief discussion of each follows.

               Recycle vehicle wash water

               Fuel and oil additives or treatments such as synthetic oil

               Long life oil filters

               Recyclable air filters

               Alternative fuels (solar, natural gas, electric)

               Alternative vehicle body materials


        The option of recycling wash water from the power washer was not evaluated further given the high
capital cost and long payback period. The long payback period is due to the very low water and sewer fees
paid  by the  USPS.   The cost feasibility calculations for  a washwater  recycling system are shown in
Appendix E.

        The USPS Engineering and Development Center is researching and testing engine performance
enhancing materials, long.life oil filters, and recyclable air filters.  Additionally, Fleet Management Bulletin
No. V-08-87 prohibits the testing of fuel and oil additives and treatments or other energy saving devices and
additives at the local level without prior approval of the USPS Office of Fleet Management. The USPS is
actively researching alternative fuels. Ongoing USPS research and the national implications of these options
make it more appropriate that they be researched at higher USPS levels.

        Painting operations are a major source of hazardous waste at the VMF. A possible option to
reducing or eliminating painting might be alternative vehicle body materials such as fiberglass or other non-
metal materials that are impregnated with pigment.  As the vehicle ages the material would wear down
exposing a new layer of paint. This may eliminate the need to routinely repaint vehicles.  Issues such as
choosing and testing alternative vehicle body materials are more appropriately researched at higher levels
of the USPS given the highly technical nature of material science and the  USPS wide implication of this
option.

Options Ranking

        Table 3 is a qualitative ranking of selected pollution prevention options discussed in the feasibility
section.  Each  option is judged against a set of criteria.  These criteria take into account environmental,
economic,  and  implementation considerations identified from the site visit, interviews with USPS employees
and information taken from the worksheets. The ranking system in Table 3 is based on the assumption that
each  option will have either a positive (more efficient, more cost effective, reduce toxicity), neutral, or
negative (more  labor intensive, more expensive, incompatible) effect on current operations.  Using a system
of one through  five, with three as a neutral point, each option was ranked. Options with the highest scores
have the highest potential  to eliminate or reduce wastes and/or waste management costs.  Some options
were  not ranked because  they have very low capital costs, the option's benefits are not easily quantified,
or the option does not lend itself to the ranking criteria.   These include training painters in better  spray
techniques, improved inventory control and  housekeeping, purchase paint in  bulk,  recycle  paint  cans,
improved parts  cleaning procedures, improved waste management cost tracking, and employee incentives.

                                                19

-------
                                            Table 3. Qualitative Ranking of Selected Options
Painting Operation Maintenance and Repair Operations
Criteria
Reduction in occupational hazard
Reduction of a RCRA regulated waste
Reduction of 33/50 Program chemical
Reduction of disposal costs
Capital cost

Implementation
Reduction of Environmental Impact
TOTAL
Water
Borne
Coating
5
5
5
5
4
i
2
4
34
HVLP
Spray
Gun
5
5
4
5
4

3
4
35
Paint Mixer
4
4
4
4
4

4
4
32
Gun Washer
Station
5
4
4
4
3

3
4
32
Aqueous
Parts Washer
4
4
3
4
4

2
4
29
Antifreeze
Recycling Unit
3
4
3
2
2

2
4
21
On-Site
Solvent
Recycler
3
4
4
5
2

2
4
28
5 = Very Positive
4 = Positive
3 = Neutral
2 = Negative
1 = Very Negative

-------
These options are included in the implementation plan found in the Implementation Plan section of this
document.  The criteria used in the table are defined as follows:

               Reduction in occupational hazard:  the options are ranked on the basis of whether they
               would reduce worker exposure to hazardous substances. The antifreeze recycling unit is,
               neutral since workers will still have to handle ethylene glycol.

               Reduction of a RCRA regulated waste:  whether the option would eliminate or reduce the
               generation of a RCRA regulated  hazardous waste.

               Reduction of a 33/50 Program chemical:  whether the option would eliminate or reduce
               emissions of one or more of the 17 toxic chemicals targeted by the U.S.  EPA though its
               33/50 Program.  The options were ranked as follows:

               5 = elimination of a 33/50 chemical; 4 = reduction in emission of a 33/50
               chemical; 3  = no 33/50 chemical used; 2 = slight increase in a 33/50
               chemical emission; 1 = significant increase in a 33/50 chemical emission

               Reduction of disposal costs: whether the option would eliminate or reduce
               disposal costs.

               Capital cost: the initial impact of capital expenditure necessary for implementing the option.


               The options are ranked as follows:

               5 = zero ; 4 = $0 <->  $1,000;  3 = $1,000  <~> $3,500; 2 = $3,500 <-> $10,000; 1  =
               > $10,000

               Total  annual cost savings:  The payback period.  Cost savings include operation and
               maintenance costs and impact on raw material costs.  Potential cost savings or avoidance
               from  reduced  environmental  liability and/or worker health and safety  claims  are not
               included.

               The options are ranked as follows:

               5 =  > immediate payback;  4  =  ,3 year payback;  1 = no payback

               Implementation:  Factors include barriers (policy, technical, economic),  time needed  to
               implement the option including training, and ease of implementation.

               Reduction of environmental impact:  net effect of the option on the environment.

       5 = elimination of waste  and/or emission, very positive environmental impact
       4 = reduction in volume  of waste and toxicity, positive environmental impact
       3 = no change in environmental impact                            •
       2 = increase  in waste  volume and/or toxicity
       1 = large increase in waste volume and/or toxicity.
                                              21

-------
FEASIBILITY ANALYSIS

       This section presents a limited technical and economic feasibility assessment for each of the major
source reduction and recycling options selected by the assessment team: low VOC paints (water borne
coatings); high volume low pressure (HVLP) paint application system;  a paint gun washer station; an
aqueous chemicals parts washer; an onsite solvent distillation unit; and an onsite antifreeze recycling unit.
The discussion includes an overview of each option's current state of technology (i.e. is the technology
widely accepted), the capital, operation, and maintenance costs associated with equipment/material change,
operational differences (i.e. differences  in operating the equipment as compared to the status quo),
wastes/emissions  reduced/eliminated,  new  wastes generated and implementation barriers.  Figure 3,
presented earlier, portrays the estimated annual solid and hazardous waste management costs  for the
Buffalo VMF. This figure was derived from assessment worksheets, waste manifests, and interviews with
USPS employees.  A feasibility discussion of each of the  major options described above follows.

Low VOC Paints, (Water Borne Coatings)

        Replacing solvent  borne paints with water borne paint will eliminate hazardous waste solvent paint
thinner,  and solvent  paint.  VOC emissions will  be significantly reduced.   Low VOC  coatings  are
commercially available and have been widely used in some industries.  Improvements in the quality and
performance of water borne coatings are advancing quickly. Coating manufacturers are engaged in close
competition to be the first to produce coatings  that help facilities comply with strengthened air pollution
regulations. While the technology is improving,  water borne coatings do not deliver the high sheen finish
demanded by automotive  companies and customers. This should not be a limitation to the use of water
borne coatings for the Postal Service.   The USPS requirements are based more on performance than
appearance.  Water borne paints reportedly provide equal corrosion resistance and durability to solvent
based paints.

        Many coatings are used in  refinishing and choosing a compatible system of products is complex.
Technicians select coatings  on the basis of their compatibility  with  one another  and also  for their
compatibility with stripping products and body filler materials. As a result, automotive refinishers are often
reluctant to change their systems.  Potential barriers to switching to water based paints depend on the type
of coatings applied to the vehicle in the factory as well as limitations involved in the application and drying
processes (i.e. temperature requirements).

        Water borne coatings cost about the same as the  solvent based paints currently used at the  Buffalo
GMF. Water borne paints  can be applied with the same equipment used for solvent borne paints.  Longer
drying times are  a consideration.   Water borne paints are reportedly available in  an air-dry version.
Depending on the specific  paint and production schedule a drying oven may be required. Acme Automotive
finishes has a complete line of low VOC products on the market. The  products air dry in 30 minutes -16
hours and emit 1.1 - 4.4 Ibs/gal of  VOCs. Acme Automotive product information is found  in Appendix F.
Contact information for other companies offering water borne coatings are found in Appendix G. Table 4
provides some specifications for a  water borne non-electrostatic coatings.

        Water borne paint waste is typically nonhazardous. The major new waste stream will be wash water
from paint equipment clean up and excess  paint.  The wash water can  be discharged to the sewer after
appropriate pretreatment, typically removal of paint solids. If toxic pigments are used in the paints the solids
will have to be disposed of as a hazardous waste.  Contact the local  sewer authority to determine what
washwater or paint treatment is required.
                                               22

-------
                        TABLE 4. WATER BORNE NON-ELECTROCOATING
 Application:           Dip or spray applied

 Resins:               Acrylic latex, halogenated copolymer latex, aqueous urethane, alkyds,
                       modified alkyds, epoxies, polyesters

 Bake Temperature:     Air-dry quickly or baked, force dried

 Advantages:           Low VOCs, smooth film, corrosion resistance, good adhesion, easy
                       application, clean up, low-cost equipment, non-flammable, fast drying, low
                       toxicity.

 Disadvantages:        Need to monitor painting conditions more closely than with solvents, drying
                       time affected by humidity and temperature because water-borne dry more
                       slowly.  May also blister when placed in ovens with insufficient flash-off time.

 VOCs:                0.5 -3.5 Ibs/gal
High Volume Low Pressure (HVLP) Paint Application System

        Depending on operator technique, conventional air spray guns may have a transfer efficiency rate
of only 25 to 30 percent.  For every ten gallons of paint sprayed, up to three to four gallons of paint may
be wasted. By comparison, the transfer efficiency of HVLP guns is 65 - 90 percent, so as little as 0.1 - 0.35
gallon may be lost for every gallon applied. One automotive refinisher in the San Diego area reported paint
use reductions of over one third with a finish quality of good to excellent.  The firm did not experience any
operational problems  with the equipment, and reported  overall  operating  costs were  comparable to
conventional air atomized spray systems.   Another firm reported  that HVLP  spray guns achieve a
comparable finish when using standard automotive paints,  but may leave a "halo" effect when metal flake
paints are used.  This is not expected to be a problem for Post Office applications since metal flake paints
will not  be used.  Disincentives to switching to HVLP systems include operator training and time to get
accustomed to the new spraying technique.

        Table 5 demonstrates how coating usage, solid waste, VOC  emissions and overspray vary as a
function of the transfer efficiency of the spraying equipment.   The table was prepared  based on VMF
purchase records of 600 gallons of paint per year.  The formulas for making the calculations are found in
Appendix  H.  Assuming that the VMF's existing gun  system achieves a 40 percent transfer efficiency, a
relatively high transfer efficiency for this type of equipment, the table illustrates that by switching to the HVLP
system  with a transfer efficiency of 80 percent, coating  usage decreases  by 50  percent, solid waste
decreases by 30 percent and VOC emissions decrease by 50 percent.  Because overspray is reduced from
115.2 gallons per year to 19.2 gallons per year, paint filter usage will decrease by approximately 50 to 80
percent.
                                               23

-------
                    TABLE 5. COATING USAGE, SOLID WASTE GENERATION
                AND VOC EMISSIONS AS A FUNCTION OF TRANSFER EFFICIENCY
  Item
20%
   Percent Transfer Effiri

40%      60%
                                                                    100%
Coating Usage

Coating solids applied
(gai/yr)

Coating usage (gal/yr)
assuming 32% by volume
solids

Solid Waste Generation

Coating solids overspray
Solid waste generated
(gai/yr)
VOC Emissions (gal/yr)

VOC Emissions (tons/yr)*
                           76.8


                           1200
          76.8      76.8      76 8
          600
307.2


1689.5


816

3
408

1.5
          400
                              300
                                                                    76.8


                                                                    240
          115.2     51.2
          1267.2    844.8
                    272

                    1
                                                          19.2


                                                          422.4


                                                          204

                                                          .75
                                                                  163

                                                                  .6
Source:        Duletsky, Barbara W., David L Newton.  'The Use of Process Modifications in Reducing
               Industrial Wastes  from Spray Coating Operations."   1985  Triangle Conference on
               Environmental Technology, Raleigh, NC.


Assumptions

       •       Paint solids content of 32 percent.

       •       Coating  usage is the total amount of paint sprayed at the work piece.  Coating solids
               applied is the amount of solids that are actually transferred to the work piece.  Coating
               usage equals the sum of  coating solids applied + coating  solids oversprayed + VOC
               emissions.

               Performance of the VMF's existing spray gun  system is estimated to be 40  percent,  a
               relatively high efficiency rate. A high estimate of HVLP performance is 80 percent.

               Assumes 5 Ib VOC/gal of coating; 1 gal VOCs  = 7.5 Ibs

       HVLP paint application systems can be considered a  mature technology.   HVLP  equipment  is
available from several manufacturers. Vendor information is found in Appendix G. One manufacturer, Binks,
produces a line  of guns that is suitable for most automotive refinishing.  This line of spray guns meets the
stringent VOC emissions standards of the California South Coast Air Quality Management District.  HVLP
guns are designed to  handle a wide variety of paints including water borne and high-solids paint.

       In  general, the only equipment modification required is the replacement of the gun head.  Some
HVLP spray guns may need more equipment modifications than others (e.g., turbine air compressor or new
paint cups). HVLP systems include a high-volume air source, a material supply system and  special HVLP
guns. The. major cost is the spray gun head and associated accessories. A representative Binks gun costs
                                              24

-------
 $385 while a conventional air atomized spray gun costs $200. The VMF's existing air source and material
 supply system may be compatible with a HVLP gun.

        The primary operational difference is the increased transfer efficiency. All other parameters of the
 painting/refinishing process will remain the same.  To ensure proper operation HVLP spray guns must be
 cleaned and maintained more frequently than airless or air-assisted spray guns. The primary advantage of
 using an HVLP system is a reduction of VOC emissions. A secondary advantage is a 30 percent reduction
 in paint overspray. Decreased overspray reduces raw material costs since less paint is needed to cover the
 same area.  In addition there is a mass reduction in paint overspray that is collected by paint filters. Thus,
 the number of paint filters will be reduced.  The amount of overspray depositing on the ground to be swept
 up or washed down the drain with water will also be reduced. No new wastes are generated.

        Table 6 presents a cost/benefit analysis for an HVLP paint application system.  Note that many of
 the cost figures and waste quantities are estimates and, thus, the results of the analysis may vary from actual
 values.

             TABLE 6. COST/BENEFIT ANALYSIS:  HVLP PAINT APPLICATION SYSTEM


  Capital Costs	

  Binks  Mach 1                                                         $ 385

  Installation (labor @ $25/hr)                                           $  25

                Total Capital Expenditure                               $ 410

  Operating and Maintenance Costs

         Paint purchase cost 40% (300 gallons/yr)($20.49/gal)             $2,458
         Misc. replacement parts                                        $ 100
         Energy requirement (approximately equivalent to existing           none
         levels)                                                         none
         Labor (approximately equivalent to existing levels)                $ 500
         Training (20 hours implementation/start-up cost @ $25.00/hr)
                Total Annual Operating and Maintenance Costs
 Avoided Costs
         Purchase cost (less paint is required $12,304.32 - $2,458.80)
         Paint Filters (half as many filters are needed $2,348 - $1,174)
         Disposal cost reduction (30% less waste paint is generated)

                Total Annual Avoided Costs

                Net Annual Benefit (NAB) = Avoided Costs - O&M

                Pay Back Period = Capital Costs/NAB
 $3,058


 $9,845
 $1,174
 $ 177

$11,196

 $8,138

 immediate
Assumptions
               Total current paint purchase cost is $12,304 per year for 600.5 gallons of paint.

               Total paint waste and thinner currently generated is 277.3 gallons and costs $592 per year
               for disposal.
                                               25

-------
               Paint applied using the existing gun system is approximately 300 gallons with the other 50
               percent being lost to overspray and VOC emissions.

               The HVLP system will lose 15 percent as overspray.

               Disposal costs will be approximately 30 percent less due to decreased paint waste.

               20 hours of training and break-in time is factored in. No formal training is required.

               Avoided potential  liability from reduced  hazardous waste  generation,
               transport and storage was not quantified but is an additional benefit.


Paint Gun Washer Station

        Paint gun washer stations provide a more efficient means of cleaning spray guns and associated
painting equipment. HVLP guns require better cleaning than conventional guns and gun washers can make
a difference in maintaining their high performance.  Several manufacturers have gun washer systems on the
market  (see Appendix G).  Graco,  for example,  produces three models.  The stainless steel version is
suitable for aqueous cleaning chemicals, the others are only designed for solvents. The Graco Mini Flo PRO
Wash gun washer costs $995. The main advantage offered by the gun washer system over manual washing
in an open solvent sink is that the gun washer operates automatically with the lid closed.  Other advantages
include:

               The parts washer recycles the cleaning medium (solvent or aqueous).

               VOC emissions are reduced as much as 75-90 percent compared to a solvent sink.

        •       The washing cycle  (and, therefore, labor cost) decreases  to 30-60 seconds versus 5-20
               minutes for manual cleaning.

        •       The gun washer uses less solvent both because it reduces solvent loss from evaporation
               and because of the shorter cleaning cycle.

               The spray guns are cleaned more effectively with the gun washer.

        •       Worker exposure to toxic substances decreases.


        Spent solvent can be recycled on-site in a recycling unit or sent off site. Disincentives include costs
associated with maintaining the system, purchasing the solvent and contracting with a licensed hazardous
waste hauler to manage the spent solvent and the small amount of sludge  generated from the system.

        Table 7 presents a cost/benefit analysis for purchasing a gun washer station.  Note that many of
the cost figures and waste quantities are estimates and, thus, the results of the analysis may be slightly
inaccurate. It is possible that gun washers can be leased. The VMF manager should contact the contractor
servicing the existing solvent sink to inquire whether they offer a gun washer system.  The economics of
contracted service are  often  favorable,  considering  the current on-site labor costs for equipment
maintenance and off-site disposal.  Often the cost associated with using a solvent service company is less
than the combined cost of solvent purchase, tank maintenance, labor, and  waste disposal.
                                               26

-------
                  TABLE 7. COST/BENEFIT ANALYSIS: GUN WASHER STATION
  Capital Costs
   Graco Mini PRO Wash                                             $ 995

   Transportation                                                    $ 100

   Miscellaneous parts                                               $ 100
   Total Capital Expenditure                                          $1,195
 ': 'Operating and Maintenance Costs ."...,.::;.'  *: ;;j • :>.*£•: ? f %•;:;: ^ *:1:P# ^fl^l^lllPR^ilSi
   Operating costs:

    Misc. replacement parts                                         $  100
         Labor ($25/hr)(32.5 hours = 75% less labor needed)           $  812

         Clean solvent (gal/yr) (solvent can be reused twice before       $ 1,400
         disposal or recycling) (new solvent $8.00 per gallon)

    Disposal costs:

    (270 gallons) ($12.35/gal) (assumes 25% lost to evaporation)          $ 3,335
               Total Annual Operating and Maintenance Costs         $ 5,647
 Avoided Costs
   Purchase cost

         Solvent (360 gal/yr @  $8.00/gal  assuming 50% loss due to     $ 2,880
         evaporation)

         Labor cost ($25) (130 hours assuming 30 min a day spent on    $ 3,250
         cleaning)

   Disposal cost (202 gal)($12.35/gal) (actual)                          $ 2,495
               Total Annual Avoided Costs                          $ 8,625
               Net Annual Benefit (NAB) = Avoided Costs - O&M      $ 2,978
               Pay Back Period = Capital Costs/NAB                immediate
Assumptions
              Actual raw material usage figures are unknown.  It was assumed, based on VMF manifests,
              that 7.7 gallons of solvents are disposed  of every two weeks and that total VMF tank
              capacity is 15 gallons with 50 percent loss due to evaporation.

              Virgin solvents costs $8.00 per gallon.

              30 minutes a day is spent cleaning the paint gun and equipment after three color changes.
                                             27

-------
               Disposal cost for the gun washer system is higher than disposal cost for manual cleaning
               because less solvent has evaporated; assumes 25 percent is loss from the gun washer
               system, 50 percent from manual cleaning.

               Assumes the contents of the gun washer tank (30 gal) can be used twice before disposal.


Aqueous Chemicals and Parts Washers

        A number of equipment manufacturers specialize in designing and distributing cleaning systems
utilizing biodegradable aqueous and semi-aqueous cleaners. (See Appendix G.) These units are intended
to replace systems using hazardous solvent cleaning materials. Commercially available aqueous cleaning
units range from small, single-station dip tanks to completely automated-transfer, multi-stage systems.
Spray, agitating, immersion, ultrasonic immersion, or a combination of these processes can be selected to
address the VMF's specific applications.


        Some companies offer a leasing service for aqueous parts cleaners. These arrangements include
equipment leasing and periodic general maintenance service, replacement of spent cleaning solution with
fresh cleaning solution and make-up water.  The economics of a contracted service are often favorable to
purchasing and maintaining a parts washer considering the current on-site labor costs  for equipment
maintenance and off-site disposal. Often the cost associated with using a service company is less than the
combined cost of cleaner solution purchase, tank maintenance, labor, and waste disposal.  The purchase
price for aqueous cleaning units ranges from $650 to $1,000.  Aqueous cleaning chemicals cost around
$0.85 per gallon.

        The disadvantage to aqueous parts cleaners is that parts are wet after cleaning,  increasing the
possibility that carbon steel parts will rust. Thus, following rinsing to remove any residual cleaner residue,
the parts need to be thoroughly dried.  Two additional steps (i.e.,  rinsing and drying) may be required to
clean a part using an aqueous cleaning unit compared to a solvent sink. This corresponds to increased
space requirements for additional equipment, longer cleaning times, and potentially higher initial capital
costs. A corrosion-preventing  inhibitor may also need to be applied during the rinse cycle, or just prior to
dry-off, adding expense to the process.

        Petroleum naphtha and brake cleaner solvent are hazardous materials and are managed as RiCRA
hazardous waste.  Replacement of solvents with non-toxic aqueous chemicals will eliminate the use of these
hazardous solvents.  Aqueous cleaners generate three main types of waste: waste water, oily waste, and
sludge.  Washwater are typically circulated through a filtration system and reused.  Additional water and
aqueous cleaner are added to the wash water as needed. Periodically the wash water bath is changed.
Depending on the aqueous cleaner used, the spent solutions may be flushed down a sanitary sewer leading
to a biological treatment facility. The USPS must contact the local sewer authority before disposing of spent
aqueous cleaning solutions down the drain.  Oily waste is typically managed by separating it from the wash
water. The sludge that accumulates in the bottom of the cleaning unit and oil are periodically collected and
disposed of as a hazardous waste.  Oil, grease,  and heavy metals removed from the cleaned parts can
concentrate in the sludge requiring the sludge to be managed  as a hazardous waste.

Onsite Solvent Distillation and  Recycling of Solvents

        Onsite solvent distillation units are available on the market and widely used in industry. An article
on choosing the correct distillation unit is  included in Appendix I.  Many companies are marketing solvent
recycling equipment (see Appendix I). The average cost runs about $3,500 for a small unit designed for five


                                               28

-------
to 15 gallons per batch .  Other associated costs include the cost of disposing of the small amount of
hazardous waste sludge the equipment produces.

       Operating an onsite distillation unit may require additional hazardous waste management paper
work.  Additional labor time will be required for operating and maintaining the unit.  Fire and safety
considerations must  be taken into account when choosing the location of a distillation unit.  Onsite
distillation units are regulated by New York state law, see 6 NYCRR Part 370.

       Table 8 presents a cost/benefit analysis for an on-site solvent recycling unit.  Note that many of the
cost figures and waste quantities are  estimates and,  thus, the results of the analysis may  be slightly
inaccurate. Given the long payback period of 4.5 years, this option is not recommended. If the cost of raw
materials or waste disposal increase significantly, this option may be feasible.


          TABLE 8.  COSTS/BENEFIT ANALYSIS: SOLVENT/THINNER DISTILLATION UNIT


 Capital Costs
   LSgR unit (GSA Schedule)                                        $3,700                   ~

   Transportation                                                    $  100

   Installation (labor @ $25/hr, piping and electrical)                     $  200
        Total Capital Expenditure                                     $4,000
   Operating and Maintenance Costs
   Operating costs:

        Heating ($0.10/gal)                                          $ 130
        LS-JR still bags ($19.38/doz)(22 doz/yr)                       $ 430
        Misc. replacement parts                                      $ 100
        Labor ($25/hr)(260 hrs)                                      $6,500
        Thinner (660 gal)(0.2)($6.36/gal)                               $ 839

   Disposal costs:
                                                                    $3,574
    (1787 gallons) (.20) ($10.00/gallon)
                Total Annual Operating and Maintenance Costs          $12,694
 Avoided Costs
   Purchase solvent, service units, waste disposal
        Engine Parts Cleaning Solvent                                 $3,744
        Brake Parts Cleaning Solvent                                  $2^262
        Paint Equipment Cleaning  Solvent                             $2,496
        Waste paint/thinner                                          $  592
                Total Annual Avoided Costs                            $12,452
                Net Annual Benefit (NAB) = Avoided Costs - O&M       $  879
 Pay Back Period = Capital Costs/NAB                               4.5 years
                                              29

-------
Assumptions

               Total volume of paint waste/thinner estimated at 277 gallons per year according to manifest
               records.

               Recycled thinner will replace virgin product by 80 percent.  20 percent virgin thinner will
               need to be purchased.

               Distillation  unit reclaims  80 percent  of material, 20 percent of the total waste must be
               disposed of as hazardous at $10.00 per gallon.

               Actual purchase amounts and costs of the gun cleaner and solvents are not available from
               the VMF. This assumes  conservatively that no material was lost through VOC emissions
               and uses the amount disposed of as the initial raw material amount.

               Total combined waste disposal of the paint wastes, thlnners, gun cleaner and solvents is
               1,787 gallons a year according to VMF records.


               For purposes of this analysis, the table assumes that paint wastes, thinners, gun cleaner
               and solvents from degreasing will all be processed in the recycling unit. In actual practice,
               however, the waste streams  will be recycled separately  in the  unit rather than in
               combination.
Onsite Antifreeze Recycling

        An onsite antifreeze recycling unit would reduce the amount of hazardous waste (spent antifreeze)
generated by the VMF.  This would reduce the potential environmental liability of managing these wastes.
Concerns about manufacturers invalidating warranties if recycled antifreeze is used have declined.  Major
U.S. auto makers have begun testing and approving recycling/distillation equipment.  In addition, many in
the automotive maintenance industry point out that once a vehicle's warranty expires, the warranty issue
is moot.

        Antifreeze recycling technology has improved over the past few years. There are two types of
recycling technologies; filtration systems and distillation systems.  Filtration systems rely on a series of fine
mesh filters to remove suspended matter from  the coolant. The pH is adjusted and new inhibitor (e.g.,
corrosion prevention) is added to restore the properties of fresh coolant.  It may still  be necessary to mix
in some fresh coolant with the recycled product. The recycling unit  generates spent filters which may be
a hazardous waste due to metals content. Distillation systems reportedly attain higher levels of cleanliness
than filtration systems because distillation removes more  of the contaminants particularly the metals. The
distillation unit does not generate any additional wastes.

        The VMF management annually purchases 300 gallons of antifreeze for use at the Buffalo VMF at
a cost of $600 dollars. The waste hauler does not charge  the Buffalo VMF for disposal of waste antifreeze.
Under these conditions a distillation system  is  not economically feasible. Although the  Buffalo VMF is
currently not charged for antifreeze disposal it is conceivable that they will have to pay in the future, making
the economics more favorable. Table 9 presents a cost/benefit analysis for an antifreeze distillation unit.
Note that many of the cost figures and waste quantities are estimates and, thus, the results of the analysis
may be slightly inaccurate.
                                                30

-------
           TABLE 9.  COST/BENEFIT ANALYSIS: SMALL ANTIFREEZE RECYCLING UNIT


 Capital Costs	

         Finish Thompson Inc. Bad Ethyl Coolant Reclaimer              $3,500

         Transportation                                               $  100

         Installation                                                  none

                Total Capital Expenditure                             $3,600

                Operating and Maintenance Costs

         Purchase cost ($2.00/gal)(30 gal assuming 10% fresh           $  60
         antifreeze is added)

         Treatment cost ($1.87/gal)(300 gal)                            $  561

         Disposal cost (.10)(300 gal)(1 drum/50 gal)($150/drum)         $  90

                Total Annual Operating and Maintenance Costs          $  711

 Avoided Costs

         Purchase cost ($2.00/gal)(300 gal)                            $  600

         Disposal cost                                               none

                Total Annual Avoided Costs                           $  600

                Net Annual Benefit (NAB) = Avoided Costs - O&M       $ -111

 Pay Back Period = Capital Costs/NAB
Assumptions
               This analysis compares the costs associated with an antifreeze recycling unit to the cost
               of the Postal Service's current purchase and disposal contract with Safety Kleen.

               The recycling unit operating cost of $1.87/gallon for running the antifreeze unit is provided
               by the manufacturer, Finish Thompson Incorporated and includes electricity, water, and
               chemical costs for operating a 15 gallon run of 50/50 used coolant.
Potential Barriers

       This section outlines potential technical, economic, or institutional barriers to identified options.
Table 10 includes a summary of the barriers to implementation.  Overall the implementation barriers are
relatively modest: there are no major institutional barriers and  the  capital costs associated with new
equipment purchases is relatively low. The major barriers are that some options such as the water borne
coatings and aqueous parts washer require further research and testing.  In particular the USPS needs to
                                               31

-------
                                     TABLE 10.  POTENTIAL BARRIERS TO POLLUTION PREVENTION OPTIONS
Waste Generating Activity
        Waste
           Pollution Prevention Option
        Potential Barriers to Implementation
Painting
Paint waste
                                        VOC emissions


                                        Booth filters
                                        Paint cans
Use water borne paints

Rigid inventory control to reduce thinner use
Better housekeeping to reduce spills and leaks

Use high transfer efficiency equipment

Provide painter training to improve spray technique
Recycle solvent onsite
                       Gun washer station to reduce solvents use in gun
                       cleaning
                       Paint mixer
                       Use high transfer efficiency equipment
                       Use water borne coatings
                       Use high transfer efficiency equipment
                       Purchase paint in reusable bulk containers
                                                               Recycle used paint cans
 Maintenance and Repair Parts Cleaning   Solvent/VOC Emissions  Switch to aqueous cleaners
                                                               Recycle spent solvent onsite
 Vehicle/Large Parts Washing

 VMF Wide
 Antifreeze
 Waste water

 All wastes
Better cleaning techniques
Antifreeze recycling unit
Install a wash water recycling system

Improved Waste Management Cost Tracking
Requires further research and testing
Employee attitude and lack of employee training

Employee attitude and lack of employee training
Capital cost, lack of operator training, adjustment
period
Employee attitude and lack of employee training

Capital cost, operation and maintenance, requires
further research,and a long payback period (4.5
years)

Capital cost

Capital cost
Operator training, adjustment period
Requires further research and testing
Operator training, adjustment period
None
Locate recycling market
Further research and testing required, capital cost
Further research required, capital cost, operation and
maintenance
Employee training
Poor economics (at the present time)
High capital cost, long or no payback, installation
may be difficult
Employee attitude and lack of employee training

-------
test the alternative coatings compatibility with existing paints and painting equipment; and its performance
under a wide range of operating conditions.  Prior to replacing solvent parts washers with aqueous washers
USPS staff should evaluate its compatibility with existing procedures, waste water treatment issues, and
ability to clean parts adequately.


IMPLEMENTATION PLAN

        A number of source reduction and recycling options were described.   Most of the options
complement each other.   However, switching to water borne coatings and aqueous parts cleaners will
eliminate the need for an onsite solvent distillation unit.  Options are grouped based  on their ease  of
implementation and are shown in Table 11.
                               TABLE 11. IMPLEMENTATION PLAN
 Ease of Implementation
Options
 Immediate Implementation/Low Barriers        Inventory control and better housekeeping practices

                                             Contact paint vendor about purchasing paint in
                                             reusable bulk containers

                                             Contact metal recycling firm about feasibility of
                                             recycling metal paint cans and aerosol cans

                                             Painter training to Improve spray technique

                                             Employee training/involvement in pollution prevention

                                             Improved waste management cost tracking

                                             Good operating practices for parts cleaning
 Intermediate Implementation/Medium Barriers   Water borne paint

                                             HVLP paint gun

                                             Paint gun washer
 Long-Term Implementation/High Barriers
Paint mixer
Antifreeze recycling unit

Recycle solvents onsite
       Before purchasing any new equipment, the Postal Service should consult with several suppliers and
discuss costs based on a long range assessment of VMF waste generation (i.e., waste records for the last
two years should be compiled). New equipment must be tested under a full range of conditions prior to full
scale implementation.  Suppliers are usually very willing to demonstrate their products at the purchaser's
facility.
                                               33

-------
CONCLUSION

        VMF employees have enacted a number of activities to reduce or recycle automotive maintenance
and paint operation wastes.  These activities included:


               Good operating practices to minimize equipment cleanup wastes during
               painting operations.

               Excess paint is saved in one gallon containers and reused on the next appropriate job.

               Washing engine and brake parts and painting equipment takes place in solvent sinks. The
               sink recirculates "dirty" solvent to give the paint spray gun an initial rinse prior to a final
               rinse with clean solvent.  The spent cleaning solvent is recycled offsite by a  commercial
               waste management firm.
                                                         f
               Purchasing re-refined engine oil for use in all vehicles.

               Sending  used tires to a tire recycler and purchasing retread tires for trucks.

               Sending  repairable parts such as generators offsite to be rebuilt.

               Eliminating methylene chloride in brake cleaner solutions and chlorinated solvents in parts
               cleaners.

        •       Using recirculating solvent sinks to reduce solvent use during automotive maintenance and
               repair.

               Recycling spent brake cleaning solvent and parts cleaning solvent offsite.

               Collecting used oil (brake fluid, transmission fluid, engine oil) for offsite recovery (re-refining
               or incineration for energy recovery).

               Recycling batteries through an outside contractor who recovers the lead.

               Recycling metal parts, such as wheel rims, by sending them to a smelter.


Based on preliminary assessment findings and recommendations VMF staff  reevaluated  the number of
engine and brake parts cleaning solvent sinks required and determined they can reduce the number by three
or four units. Eliminating three or four solvent sinks will reduce the amount of hazardous waste generated
by 3,575 to 5,010 pounds and save from $2,626 to $3,562 in operating costs  annually (assuming the
servicing frequency of the remaining sinks is unchanged).

        The USPS has a number of additional opportunities to reduce or eliminate VMF wastes as outlined
in this report. Wastes from painting operations and solvent parts washers are the largest hazardous waste
source  for which  source reduction options exist.  Source reduction alternatives for the other major
hazardous wastes generated at the VMF; engine oil, antifreeze, and lead acid batteries, are not advanced
enough to make them viable options at  this time.  These materials  are  integral to gasoline powered
automobile  engineering and  design.   The shift to alternative fuels  ushered in by the  Clean  Air Act
amendments will have a long term impact  on the type of vehicles the USPS must maintain and the types
                                               34

-------
of wastes generated. In the near term, however, the DSPS should focus on eliminating hazardous waste
from painting and parts cleaning operations.

        Water borne coatings and high transfer efficiency paint delivery systems will eliminate or significantly
reduce hazardous wastes and VOC emissions from painting operations. Replacing organic cleaning solvents
with aqueous parts washers will eliminate hazardous solvent wastes from engine and brake parts washing
operations.  Enacting these options can potentially reduce hazardous wastes by 5,954 pounds. Table 12
summarizes potential hazardous waste reduction and cost savings for selected options. Implementing these
options will assist the Buffalo GMF staff meet the USPS goal to reduce 1992 waste levels by 25 percent by
1993 and an additional 25 percent by 1995. Further, eliminating solvent borne paints will significantly reduce
emissions of four EPA 33/50 target chemicals and assist the USPS in meeting its goal of reducing emissions
of 33/50 target chemicals by 1995.


     TABLE 12. POTENTIAL WASTE REDUCTION AND COST SAVINGS FOR SELECTED OPTIONS
                    (REDUCTIONS ARE COMPARED TO CURRENT PRACTICES)
  Option
Annual Waste Reduction
Potential
Annual Cost Saving Potential
  Water Borne Paints


  Aqueous Parts Washer



  HVLP Paint Application System


  Gun Washer Station
2,782 Ibs of hazardous waste
paint/solvent/thinner

3,163 Ibs of hazardous engine
and brake parts cleaning
solvent

50% less VOC emissions
30% less paint solid waste

75-90% less VOC emissions
$3,088 in reduced waste
disposal

Undetermined
$8,138 in reduced raw material
and waste disposal

$2,978 in reduced raw materials
and waste disposal
        Implementing options identified in this report will not only reduce hazardous wastes, but will also
 reduce GMF operating costs by decreasing disposal costs. Additionally, there are unqualified benefits such
 as reduced liability, paper work, spills and spill control/disposal costs, and future regulatory requirements.
 Reducing hazardous materials/wastes avoids costs associated with cleanups caused by spills of hazardous
 solvents. Substantial sums of money have been spent at VMFs across the nation to handle accidental spills
 and  releases to the environment.  These accidents also involve considerable staff time for completing
 notices, meeting with regulatory agencies and managing cleanup operations.  Postal  Service employees
 reported that the VMF was scheduled to purchase a paint booth, to comply with New  York state VOC
 emission requirements.  Prior to purchasing a paint booth the Postal Service  should seriously consider
 replacing solvent borne paints with water borne paint and/or switching to  a  HVLP paint  delivery system.
 These options together will significantly reduce VOC emissions and eliminate the need for the paint booth.
 The HVLP system alone has the potential to significantly reduce VOC emission.

       There are no major barriers to implementing many of the pollution prevention options. As with all
 new products the water borne paints and aqueous parts washers will have  to researched and tested prior
to switching.  Recycling antifreeze onsite and operating an onsite solvent distillation unit are not feasible at
the Buffalo VMF at present due to the poor economics and long payback periods.
                                              35

-------
       The Buffalo VMF has several characteristics that favor a successful pollution prevention program.

              A core of enthusiastic and committed USPS staff

              Top level  commitment to pollution prevention  as shown  in  pollution
              prevention policies and waste reduction goals

              Buffalo GMF management commitment as shown by their participation in this project

              Adequate quantities of recyclable materials to interest recycling vendors


Applicability to Other VMFs

       The USPS operates the largest  U.S. civilian vehicle fleet.  This has two implications.  First, a
significant amount of hazardous waste is  generated  at  Postal Service VMFs nationally.  The waste
management costs and potential environmental liabilities are substantial. The options recommended in this
report are directly applicable to the Postal Service's 350 other vehicle maintenance facilities in the United
States. Net annual benefits and paybacks should be applicable also.

       Secondly, operating and maintaining such a  large fleet empowers the USPS with very strong
purchasing power.  The USPS could specify a preference for purchasing vehicles painted with water borne
paints or other low or no VOC technologies.  More immediately, the USPS could begin using water borne
paints at their vehicle maintenance facilities nationwide. A Postal Service commitment to eliminating solvent
based coatings on USPS vehicles will have a significant impact on the Nations coating industries and would
provide the incentive for industry to perfect this technology. The Postal Service could work directly with a
major coating manufacture to design a water borne coating system to meet USPS requirements.  The low
number of paint colors used by the USPS should make standardizing coatings simpler.

       The USPS should set a minimum transfer efficiency for paint application systems. Given the present
state of the industry a transfer efficiency of 75 percent would be reasonable. This level should be reviewed
periodically as equipment improves.  By specifying a transfer efficiency rather than a specific  piece of
equipment, such as a HVLP system, the USPS can take advantage of improved technology. Presently the
HVLP system is  best suited for the type of vehicle painting operations  performed at VMFs.  However,
advancements in other high transfer efficiency delivery systems such as electrostatic, and powder coating,
could make these viable technologies for Postal Service use.

       Switching to aqueous cleaners can eliminate the use of hazardous solvents and hazardous wastes
from cleaning  engine and  brake parts.  However,  some aqueous  cleaning systems generate RCRA
hazardous wastes.  Selection of a nonhazardous aqueous cleaning system will require additional research
and testing.  The USPS could work with  industry to test aqueous cleaning systems. Once a system that
meets USPS specifications is identified the USPS could  set minimum performance standards, or prescribe
a certain  brand to be used at all VMFs.
                                               36

-------
 APPENDIX A



WORKSHEETS

-------
Firm USPS
Site Buffalo. NY - VMF
                                  Waste Minimization
                                Assessment Worksheets
Prepared By_
Checked By_
Sheet	of
                               WASTE SOURCES
         v>EPA
Shop Clean-Up
Obsolete raw materials
Spills and leaks (liquids and powders)
Dirty rags and sawdust
Area wash water
Clarifier sludges
Container disposal
Pipeline/tank drainage
Evaporative losses
Significance at Shop
Low

/


/
/
/
/
Medium
^

S
/




High


,





Note: For a discussion of waste minimization options for reduction of shop clean-up wastes, see the EPA
pollution prevention guide for the automotive repair industry.
Body Repair
Left over filler
Sanding dust
Painting
Left over paint
Dirty wash thinner Mineral spirits
Empty containers
VOC air emissions
Particulate emissions
Dirty booth filters 	 	 	

/


/

/
/
/
--





/
/
/










-------
Firm USPS
Site Buffalo. NY - VMF
Date March 1992
Waste Minimization
Assessment Worksheets
Project Number
Prepared By
Checked By
Sheet of
— 	

Page of
        Worksheet
            2a
WASTE MINIMIZATION:
       Material Handling	
vvEPA
 A.  DRUMS, CONTAINERS, AND PACKAGES
 Are drums, packages, and containers inspected for damage before being accepted?           \*f  Yes  D No
 Are employees trained in ways to safely handle the types of drums and packages received?    Sf  Yes  D No
 Are they properly trained in handling spilled raw materials?                                 D  Yes tf No
 Is there a formal personnel training program on raw material handling, spill prevention, proper
storage techniques, and waste handling procedures?
Describe handling procedures for damaged items:  Return to vendor.
                                                  D  Yes Hf No
How often is training given and by whom?   Train new employees first couple of weeks bv shoo foreman and
senior maintenance employees.	
Is obsolete raw material returned to the supplier? Batteries oil recycle                        D  Yes D No
Is inventory used in first-in first-out order?                                               Q^  Yes D No
Is the inventory system computerized?                                                  H^  Yes D No
Does the current inventory control system adequately prevent waste generation?             H^  Yes 0 No
What information does the system track?  How much we purchase, what we use on each job (work order}.
and what we dispose of.	___^__	
Are stored items protected from damage, contamination, or exposure to rain, snow, sun,
and heat?                                                                           \jf Yes D  No
Is the dispensing of raw materials supervised and controlled?                              \af Yes D  No
Are users required to return empty containers before being  issued new supplies?             H^ Yes D  No
Do you maintain and enforce a clear policy of using raw materials only for their intended use? tf Yes D  No

-------
Firm USPS
Site Buffalo. NY - VMF
Date March 1992
	 - 	 — -••• 	 	 — -=---^-. — —
Worksheet
2b

	 	 	 • 	
WrlStf* MinimtTatinn
Assessment Worksheets
I Project Number
WASTE MINIMIZATION:
Material Handling

~
Prepared Bv
Checked Bv
Sheet of Page of
&EPA

B. BULK LIQUIDS HANDLING
What safeguards are in place to prevent spills and avoid ground contamination during the filling of storaae
tanks? *
High level shutdown/alarms D Secondary containment of Paint room with dike
Flow totalizers with cutoff D Other of
Describe the SVStem: Manually filled by private vendor. Bulk oil. bulk antifreeze. Solvents are 55-oallnn
drums and 5-aallon oails.

Are air emissions from solvent storage tanks controlled by means of:
Conservation vents D Absorber/condenser D
Nitrogen blanketing D Other vapor loss D
control system
Describe the system:


Are all storage tanks routinely monitored for leaks?
If yes, describe the procedure and monitoring frequency for above-ground/
walk around tanks.
If yes, describe the procedure and monitoring frequency for underground ti
fuel leak detection system.
How are the liquids in these tanks dispensed to the users (i.e., in small cor
containers, hand pumps; some are oumoed throuah roll-uo hose.
What measures are employed to prevent the spillage of liquids being dispe
and alert when filling, containers or vehicles. 	 _
When a spill of liquid oc
discuss the way in whicl
and Safety K/een removt


H' Yes D No
'vaulted tanks: Visual inspection.

anks: Gasoline, diesel

itainers or hard piped)? Small

nsed? Train employees to be safe

curs in the facility, what cleanup methods are employed (e.g., wet or dry)? also
hth«» rp«!iiltinn wastes are handled: Dry - we use around corn
's the filled drum of contaminated corn for $119.00 a drum.



-------
Firm USPS
Site Buffalo. NY - VMF
Date March 1992
Waste Minimization
Assessment Worksheets
Project Number
Prepared By
Checked Bv
Sheet of Page of :
       Worksheet
           3
OPTION GENERATION:
   Material Handling
vvEPA
Meeting format (e.g., brainstorming, nominal group technique)   Normal meeting group.

Meeting Coordinator

Meeting Participants
Suggested Waste Minimization Options
A. Drums, Containers, and Packages
Raw Material Inspection
Proper Storage/Handling
Return Obsolete Material to Supplier
Minimize Inventory
Computerize Inventory
Formal Training
Waste Segregation
B. Bulk Liquids Handling
High Level Shutdown/Alarm
Flow Totalizers with Cutoff
Secondary Containment
Air Emission Control
Leak Monitoring
Currently
Done? Y/N

Y
Y
N/A
Y
Y?
Y
Y

N
N
Y
N
Y
Rationale/Remarks on Option



Look at vendor for removal







Paint room

Underground

-------
Firm USPS
Site Buffalo. NY - VMF
Date.
                                         Waste Minimization
                                       Assessment Worksheets
 Project Number
Prepared By_

Checked By_

Sheet
                                                                                            of
       Worksheet
           4a
WASTE MINIMIZATION:
Body Repair and Paint Application
           &EPA
A. BODY REPAIR


Do you generate large quantities of waste filler?


Are your workers supervised/trained so they do not mix more filler than required?


Do you currently employ rigid inventory controls to minimize product use?


Do you discourage the use of hoses to flush filler dust to the sewer or clarifier?


Are sweep brooms or vacuum units available for your workers to use?
                                                 D Yes G/ No


                                                 G/ Yes D No


                                                ~& Yes D No


                                                 G/ Yes D No


                                                 G/ Yes D No
Explain how you minimize waste from auto body repair:   We purchase baas of filler and the employees use

the rinoer to squeeze out lust what they need. No cans to throw away.	
B. PAINT APPLICATION


Do you generate large quantities of waste paint or thinner?  20-gallon drums/month?


Do you currently employ rigid inventory controls to minimize material use?


Do you use more than 1/2 gallon of thinner per car?
                                                 D Yes G/ No


                                                 D Yes D/ No


                                                 G/ Yes D No
If yes, discuss how implementing more rigid controls could be accomplished in you shop:   Thinner used
mostly in paint to sorav.
Is the volume of paint mixed based on the surface area to be painted?                      D/"  Yes D  No


Does the design of your mixing equipment prevent you from mixing smaller batches of paint?  D Yes G/ No


Do you provide customers with leftover paint (enamel or lacquer only) for touch-up use?      D Yes G/ No


Are operators trained to use their equipment properly so as to minimize overspray?           G/  Yes D  No


Are they periodically retrained?                                                        ^  Yes D  No

What measures have you taken to reduce the generation of waste paint:   Mix what we need and recap.	

-------
Firm US PS
Site Buffalo. NY - VMF
Date March 1992
Waste Minimization
Assessment Worksheets
Project Number
Prepared Bv ,
Checked By
Sheet of
Page /of
Worksheet
4b

WASTE MINIMIZATION:
Body Repair and Paint Application
                                                                                 wEPA
 B.  PAINT APPLICATION (Continued)
 Who provides this training and how often is it given?   Shoo foreman and local paint distributors: 1 or 2
 Do your operators use large amounts of solvent to clean equipment? Recycle by Safety Kleen D Yes G/ No
 Do they scrape out paint cups before rinsing?                                             G/ Yes D  No
 Have you tried using or do you use an enclosed cleaning system?  Gun cleaning              Or' Yes D  No
 What was the effect?	

 Do you contract with an offsite thinner supplier/recycler?                                  G/ Yes D  No
 Do you decant dirty thinner and use it as an initial wash thinner? Safety Kleen recycles       D Yes sf No
 Do you paint more than 50 cars per month?  50 jobs partial and whole                       D Yes Q/ No
 If yes,  have you looked at onsite recycling systems?                                       G/" Yes 0  No
 Have you tried to  list your waste with a certified waste exchange?                           G/ Yes D  No
 Please discuss any measures you have taken to recycle paint/thinner waste: 	
Have you investigated the use of low VOC paints?
Have you investigated the use of high transfer efficiency spray equipment?
If yes, did it reduce the amount of paint sprayed?  1/3 of paint
Did it affect finish quality/customer satisfaction?
Have you investigated the use of styrofoam booth filters?
Discuss your success/failure with these options:  Investigate paint booth.
G/ Yes  D No
G/ Yes  D No
G/ Yes  D • No
O/ Yes  D No
D Yes  [/ No

-------
 Firm USPS
 Site Buffalo. NY - VMF
                                      Waste Minimization
                                    Assessment Worksheets
                            Prepared By_
                            Checked By_
                            Sheet   of
       Worksheet
           5
OPTION GENERATION:
Body Repair & Paint Application
wEPA
Meeting format (e.g., brainstorming, nominal group technique)
Meeting Coordinator 	___^___	
Meeting Participants	
Suggested Waste Minimization Options
A. Body Repair
Mix filter according to need
Employ rigid inventory control
Sweep up or vacuum dust
B. Paint Application
Employ rigid inventory controls
Mix paint according to need
Give customer touch-up paint
Train operators to minimize overspray
Scrape out paint cups before rinsing
Use an enclosed cleaning system
Contract with a thinner supplier/recycler
Install onsite recycling equipment
List waste with waste exchange
Use low VOC coatings
Use high transfer efficiency equipment
Use cleanable styrofoam filters
Currently
Done? Y/N

Y
Y


Y
Y
N
Y
Y
Y
Y
N
Y
Y
N
N
Rationale/Remarks on Option



Vacuum sanding system








:



-

-------
Firm USPS
Site Buffalo. NY - VMF
Date March 1992
Waste Minimization
Assessment Worksheets
Project Number
Prepared By
Checked Bv
Sheet of
Page of
Worksheet
  6a
WASTE MINIMIZATION:
      Shop Clean-Up
vvEPA
In addition to automotive refinishing, do you perform automotive repairs? (If yes, please refer
to the EPA pollution prevention guide for automotive repair shops.) D/ Yes D
Are drip pans placed under leaking cars to reduce the need for floor cleaning? \sf Yes D
Are dirty parts removed and placed on a drip pan instead of directly on the shop floor? tf Yes D
Are all work bays kept clean and neat? \*f Yes D
Do your workers wipe up small spills of fluids as soon as they occur? H^ Yes D
Do you have an award program for workers who keep their work bays clean (i.e., prevent
leaks and spills)? D Yes [/
How are spilled fluids recovered and disposed of? Dry system - with ground com soread over soill and
absorbed. Safety Kleen picks up drum of contaminated corn for $119.00.
Do you use a laundry service to clean your rags and uniforms? tf
If not, how are they handled?

Yes D
No
No
No
No
No
No

No

Do you use a biodegradable detergent for cleaning shop floors? ^ D
Have you tried using a steam cleaner in place of chemical cleaners? 5^
We use hot water (120°)
Do you discharge area washdown wastewater to a POTW or industrial sewer instead of
to the storm drain? Q
If not, how is this wastewater handled?
Yes D
Yes D
Yes I/
No
No
No



-------
Firm USPS
Site Buffalo. NY - VMF
Date March 1<
                                          Waste Minimization
                                       Assessment Worksheets
                                    Project Number
                                                         Prepared By	
                                                         Checked By	
                                                         Sheet	of	    Page
                                                                                             of
                                      WASTE SOURCES
                                                                    &EPA
                      Shop Clean-Up
                                                                     Significance at Shop
                                                                Low
                                                                 Medium
                                                                                          High
Obsolete raw materials
Spills and leaks (liquids and oowders)
Dirtv raas and sawdust
Area wash water
Clarifier sludges
 Container disposal
 Pipeline/tank drainage
 Evaporative losses
                      Parts Cleaning
 Spent solvent cleaner Recycled Safety Kleen
 Spent carburetor and brake cleaner  Recycled Safety Kleen
 Evaporative losses  Recycled Safety Kleen
 Leaks and soills (solvents)
 Spent alkaline cleaner
 Leaks and spills (alkali)
 Rinse water discharge
 Sludges and filter wastes
                  Maintenance and Repair
 Motor oil Recycled
 Oil filters Safety Kleen •- 60 filters per drum
 Gear and lube oil
Transmission fluid
Brake fluid
Radiate
slant  Safety Kle
                                                                N/A

-------
Firm USPS
Site Buffalo. NY - VMF
Date March 1992
Waste Minimization
Assessment Worksheets
Project Number
Prepared By
Checked By
Sheet of
	 —

Page of
        Worksheet
            6c
WASTE MINIMIZATION:
       Material Handling	
v°/EPA
 A.  DRUMS, CONTAINERS, AND PACKAGES
 Are drums, packages, and containers inspected for damage before being accepted?          tf Yes  D No
 Are employees trained in ways to safely handle the types of drums and packages received?    D/ Yes  D No
 Are they properly trained in handling spilled raw materials?                                D Yes G/ No
 Is there a formal personnel training program on raw material handling, spill prevention, proper
 storage techniques, and waste handling procedures?
 Describe handling procedures for damaged items:  Return to vendor.
                                                  D  Yes  Of No
 How often is training given and by whom?   Train employees first couple of weeks by shoo foreman and
 senior maintenance employees.	
 Is obsolete raw material returned to the supplier?                                          D  Yes  D No
 Is inventory used in first-in first-out order?                                               H^  Yes  D No
 Is the inventory system computerized?                                                  a''  Yes  D No
 Does the current inventory control system adequately prevent waste generation?             G/  Yes  D No
 What information does the system track?  How much we purchase, what we use on each job (work order).
 and what we dispose of.	^	
Are stored items protected from damage, contamination, or exposure to rain, snow, sun,
and heat?                                                                           Q/ Yes  D No
Is the dispensing of raw materials supervised and controlled?                              H^ Yes  D No
Are users required to return empty containers before being issued new supplies?             G/ Yes  D No
Do you maintain and enforce a clear policy of using raw materials only for their intended use? tf Yes  D No

-------
Firm USPS
Site Buffalo. NY - VMF
                                          Waste Minimization
                                        Assessment Worksheets
                                                            Prepared By_

                                                            Checked By_

                                                            Sheet    of
        Worksheet
           6d
                           WASTE  MINIMIZATION:
                          	Material Handling
               vvEPA
B. BULK LIQUIDS HANDLING

What safeguards are in place to prevent spills and avoid ground contamination during the filling of storage
tanks?                                                                              *       "
       High level shutdown/alarms  D
       Flow totalizers with cutoff    D
                                 Secondary containment
                                 Other
Describe the system:  Manually filled bv private vendor.  Bulk oil, bulk antifreeze.
Are air emissions from solvent storage tanks controlled by means of:
       Conservation vents
       Nitrogen blanketing
Describe the system:
                           D     Absorber/condenser
                           D     Other vapor loss
                                 control system
D
D
Are all storage tanks routinely monitored for leaks?                                       H^ Yes  D  No

If yes, describe the procedure and monitoring frequency for above-ground/vaulted tanks:   Visual inspection.

walk around tanks.	

If yes, describe the procedure and monitoring frequency for underground tanks:   Tank #01 - gasoline: tank

tt02 diesel fuel; leak detection system.		—_—;	
How are the liquids in these tanks dispensed to the users (i.e., in small containers or hard piped)?  Small

Containers: hand puma: some are pumped through roll uo hose.	
What measures are employed to prevent the spillage of liquids being dispensed?   Train employees to be

safe and alert when filling, containers or vehicles.	—.	___	
When a spill of liquid occurs in the facility, what cleanup methods are employed (e.g., wet or dry)?  also
discuss the way In which the resulting wastes are handled:   Dry - we use ground com and Safety Kleen
rer,
the filled rfr,
                          itaminated corn.

-------
Firm USPS
Site
Buffalo. NY - VMF
Date March 1992


Worksheet
6e

Waste Minimization
Assessment Worksheets
Project Number
Prepar
Check
Sheet

WASTE MINIMIZATION:
Parts Cleaning
___________ — _ 	 ^
•ed Bv
ed Bv
of Page of
&EPA
 A. SOLVENTS
 Do you use parts cleaning solvent for uses other than cleaning parts?                       O Yes tf No
 Have you established guidelines as to when parts should be cleaned with solvents?           D Yes \*f No
 By vehicle maintenance analysis
 Do you use solvent sinks instead of pails or dunk buckets?                                 tff Yes D  No
 Are solvent sinks and/or buckets located near service bays?                                G/ Yes D  No
 Do you allow cleaned parts to drain inside the sink for a few minutes to minimize dripping
 of residual solvent onto the shop floor?                                                  sf Yes D  No
 Are you careful when immersing and removing parts from the solvent bath so as not to
 create splashes?                                                                      tf Yes D  No
 Do you keep all solvent sinks/buckets covered when not in use?                            \af Yes D  No
 Do you lease your solvent sinks?                                                        tf Yes O  No
 If yes, does your lease include solvent supply and spent solvent waste handling?             of Yes D  No
 If you own your solvent sinks, does a registered waste hauler collect your dirty solvent for
 recycling or treatment? N/A                                                              D Yes D  No
 Do you own onsite solvent recovery equipment such as a  distillation unit?                   D Yes [/ No
 If yes,  how are the treatment  residues handled?
 What other methods are you using to reduce solvent use/waste?
B.  AQUEOUS CLEANERS
Do you use dry pre-cleaning methods such as baking and/or wire brushing to reduce loading
on the aqueous cleaner?                                                                gf yes D  No
Have you switched from caustic-based cleaning solutions to detergent-based cleaners?       tf Yes D  No
Do you use drip trays on hot tanks to minimize the amount of cleaner driobed on the floor?    D Yes D  No
N/A; No hot tanks                                                  ^^

-------
Firm  USPS
Site Buffalo. NY . VMF
                                         Waste Minimization
                                       Assessment Worksheets
                                 Prepared By_
                                 Checked By_
                                 Sheet	of
       Worksheet
           6f
 WASTE MINIMIZATION:
	Parts Cleaning
v-xEPA
B. AQUEOUS CLEANERS (Continued)
Are the hot tanks/jet spray washers located near the service bays?
N/A
Do you pre-rinse dirty engine parts in a tank of dirty cleaning solution so as to reduce loading
on the clean tank?
Do you routinely monitor solution composition and make adjustments accordingly?
Do you routinely remove sludge and solids from the tank?
Done by Safety Kleen
Are sludge and solids screened out before they reach the waste sump?
Waste sludge managed by Safety Kleen
Have you installed still rinses or converted free running rinses to still rinses?  This water
can be used as make-up to your cleaner bath.
Do you use demineralized water for your cleaning bath make-up?
Is your cleaning tank agitated?
Do you lease your hot tank(s)/jet spray washer(s)?
N/A
If yes, do you  use mechanical agitation instead of air agitation?
Do you own your hot tanks/jet spray washer(s)?
N/A
Do you own onsite aqueous waste treatment equipment?
Does a hazardous waste hauler collect aqueous waste for recycling or treatment?
If not, how is your waste handled and disposed of?  	_	.—_
                                                  D  Yes D No

                                                 Sf  Yes D No
                                                 D Yes  Of No
                                                 H'  Yes O No
                                                  D  Yes D No

                                                 D Yes  D/ No
                                                 D Yes  Of No
                                                 tf  Yes D No
                                                  D  Yes D No
                                                  D  Yes D No
                                                  D  Yes D No

                                                 D Yes  & No
                                                 D Yes  G/ No

-------
Firm USPS
Site Buffalo. NY - VMF
Date March 1992
Waste Minimization
Assessment Worksheets
Project Number
Prepared Bv
Checked Bv
Sheet of Page of
        Worksheet
            6g
WASTE MINIMIZATION:
        Waste Handling	
&EPA
 A. AUTOMOTIVE FLUIDS

 For facilities servicing fleet vehicles, do you test fluid quality to determine when automotive
 fluids should be changed?  Time bases                                                   D  Yes {/ No

 When fluids must be drained to service a part, are they stored in a clean container so they
 may be used to refill the vehicle?                                                        tf Yes  D No

 Have you had experience using any longer lasting synthetic motor oils?                      D  Yes sf No

 If yes, please discuss:  __ _ _ __
 Are all waste fluids kept segregated?                                                     B^  Yes  D No

 If not, have you notified your waste hauler or recycler?                                      D  Yes  D No

 Have you ever had a load of waste fluid rejected by a hauler or recycler because of cross
 contamination?                                                                         D  Yes  D No

 Please describe how you store and dispose of waste fluids (motor  and lube oils, greases, transmission fluids,
 and spent anti-freezes):  Waste oil tank, waste antifreeze tank, transmission fluid goes in waste oil tank.

 2 1500-gallonl new oil tanks above around; 1 (450-gallon) waste oil tank underground; 225 ATF fluid _

 above ground.                       _             _
 B.  OTHER WASTES

 Are removed oil filters drained before disposal?


 Do you dispose of filters in the trash?

 If yes, have you contacted your waste oil hauler about alternative means of disposal?
                                                   Of Yes  D No

                                                   D Yes \sf No

                                                    D  Yes  D No
If yes, what was the response?
Does a battery collector remove your used batteries?  Eldon batteries


Do you take used batteries to a storage or recycling facility?
Eldon batteries


When replacing brakes, do you contain loose asbestos waste that may be released?
Nilfisk vacuum
                                                   G/ Yes D  No


                                                   G/ Yes D  No



                                                   [/ Yes D  No

-------
Firm USPS
Site  Buffalo. NY - VMF
Date March 1992
                                   Waste Minimization
                                 Assessment Worksheets
 .Project Number
                            Prepared By_

                            Checked By_
                                                         Sheet   of       Page
                                                  of
      Worksheet
         6h
 WASTE MINIMIZATION:
	Waste Handling
&EPA
B. OTHER WASTES (Continued)
Do you use a collection/recycling system to service air conditioning units?
Contracted - Al Parker, Harium Rd.
Do you sell or give worn parts to a re-manufacturer?
Scrap iron; starter rebuilt - B&K; component rebuilt here at VMF.
Do you have any suggestions for reducing other wastes? Radiators rebuilt bv Moxie

C. SHOP CLEAN-UP
Are drip pans placed under leaking cars to reduce the need for floor cleaning?
Are dirty parts removed and placed on a drip pan instead of directly on the shop floor?
Are all work bays kept clean and neat?
Do your workers wipe up small spills of fluids as soon as they occur?
Do you have an award program for workers who keep their work bays clean (i.e., prevent
leaks and spills)?
Do you use a laundry service to clean your rags and uniforms?
Do you use a biodegradable detergent for cleaning shop floors?
Have you tried using a steam cleaner in place of chemical cleaners?
We use hot water (120°)
Do you discharge area washdown wastewater to a POTW or industrial sewer instead of to
the storm drain?
If not, how is this waste handled? 	 	 	 	 — 	


D Yes D No
D Yes D/ No



O/ Yes D No
G/ Yes D No
D/ Yes D No
G/ Yes D No

D Yes G/ No
&/ Yes D No
G/ Yes D No
&/ Yes D No
D Yes G/ No



-------
 Firm  USPS
 Site Buffalo. NY - VMF
      Waste Minimization
    Assessment Worksheets
        Worksheet
           7a
OPTION GENERATION:
    Shop  Clean-Up
Prepared By_
Checked By_
Sheet
          &EPA
Meeting format (e.g., brainstorming, nominal group technique).
Meeting Coordinator.
Meeting Participants.
Suggested Waste Minimization Options
Use Drip Pans
Wipe Up Spills (Cotton Rags)
Keep Bay Clean
Award Program
Use Laundry Service
Use Biodegradable Detergents
Use Steam Cleaners
Discharge to POTW/lndustrial Sewer
Currently
Done? Y/N
Y
Y
Y
N
Y



Rationale/Remarks on Option









-------
Firm USPS
Site  Buffalo. NY - VMF
Date March 1992
      Worksheet
         7b
                                  Waste Minimization
                                Assessment Worksheets
    Project Number
Prepared By_
Checked By_
Sheet   of
INPUT MATERIALS SUMMARY
                                                                      Page	of
          &EPA
Attribute
Name/ID
Source/Supplier
Component/ Attribute of Concern
Annual Consumption Rate
• Overall
• Component(s) of Concern
• Purchase Price, $ per 	
* Overall Annual Cost
Delivery Mode2
Shipping Container Size & Type3
Storage Mode4
Transfer Mode6
Empty Container Disposal/Management6
Shelf Life
Supplier Would
» Accept expired material (Y/N)
• Accept shipping containers (Y/N)
_• Revise expiration date fY/N) 	
Acceptable Substitute(s), if any
Alternative Supplier(s)
Description1 •
Solvent
Cleaner
Mineral Spirits
JP Industrial
Safety Kleen

2. 1 tons




Safety Kleen with
drums
55 gat. drums
In furnished
Safety Kleen pump
in
~N/A
N/A

Y
They furnish
N
N
N/A
Brake Cleaner
Safety Kleen
Castle Products
JP Industrial

60 gal, year




Safety Kleen
55 gal & 30 gal.
By Safety Kleen
only what used
Pump
N/A
N/A

Y
They furnish
N
N
N/A
Alkaline
Cleaner
Johnson
detergents
Johnson

1.500 gal. year




Tanker truck
500 gal. tank bulk
1 bulk tank, 165
gal.
Hand pump
N/A
N/A

•Y
N/A
N
Mild detergent
Y
Motor Oil
Bulk Noco quart
can recycled for
shipping to
A.O.
92% Safety
Kleen

12,558 quarts/
year Manifest
Mineral Spirits




Bulk tank &
quart
8,500 tanker
500 gal. tank &
quarts
Pump
Quarts trash
N/A

Y
N/A
N
N
Y
'Stream numbers, if applicable, should correspond to those used on process flow diagram.
'e.g., pipeline, tank care, 100 bbl. tank truck, truck, etc.
3e.g., 55 gal. drum, 100 Ib. paper bag, tank, etc.
'e.g., outdoor, warehouse, underground, aboveground, etc.
'e.g., pump, forklift, pneumatic transport, conveyor, etc.
_"e.g., crush and landfill, clean and recycle, return to supplier, etc. 	 	 	 1

-------
Firm USPS
Site Buffalo. NY - VMF
Date March 1992
Waste Minimization
Assessment Worksheets
Project Number
Prepared Bv
Checked Bv
Sheet of Page of
Worksheet
  7c
INPUT MATERIALS SUMMARY
v/EPA
Attribute
Name/ID
Source/Supplier
Component/ Attribute of Concern 	
Annual Consumption Rate
• Overall
• Component(s) of Concern
• Purchase Price, $ per 	
• Overall Annual Cost
Delivery Mode2
Shipping Container Size & Type3
Storage Mode'
Transfer Mode'
Empty Container Disposal/Management6
Shelf Life
Supplier Would
• Accept expired material (Y/N)
• Accept shippina containers (Y/M
• Revise expiration date fY/N)
Acceptable Substitute(s), if any
Alternative Supplier(s)
Description1
Oil Filters
Fram A/C
Hastings
Wholesale
Wheeler
Bros. Auto
Filters- 1,800



Approx.
$3,600
Truck
N/A
New-parts
room
Old-drum
New-
Old-drum
Safety Kleen
N/A

Y
Furnished
N/A
N
N
Gear &
Lube Oil
80/90
Southwest
Supply
14 ea,, 55 gal.



$1.540
Drum truck
55 gal.
In oil room
Pump
Feldman drum
& barrel
N/A

Y
N
N/A
N
N
Transmission
Fluid
ATF
Niagara Lube
v^*-^^BOi^Hb*IW^H^*aWB*^kWM«^^^^^M
1,200-1.400 gal.
year



$3,000
Tanker truck
N/A
250 gal. tank/oil
room
Pump
N/A
N/A

Y
N/A
N/A
N
N
Brake
Fluid
DOTS
Milfred
Product
Co.
^^^^^^^^^^HHHVHHHHB
80 gal.
year



$2,100
Truck
ff'l-
Stock
room
By hand
Plastic
trash
jugs
N/A

Y
N
N/A
N
N
Radiator
Coolant
Antifreeze
Niagara Lube
wholesale
-~^ ^— """"»«™
250 gtl./yr.



$1.500
Truck
Bulk & gal.
Bulk tank stock
room
Pump
Plastic trash
N/A

Y
N
N/A
N
N
'Stream numbers, if applicable, should correspond to those used on process flow diagram.
'e.g., pipeline, tank care, 100 bbl. tank truck, truck, etc.
3e.g., 55 gal. drum, 100 Ib. paper bag, tank, etc.
'e.g., outdoor, warehouse, underground, aboveground, etc.
'e.g., pump, forklift, pneumatic transport, conveyor, etc.
'e.g., crush and landfill, clean and recycle, return to supplier, etc -

-------
Firm USPS
Site Buffalo. NY - VMF
Date March 1<
      Worksheet
         7d
                                  Waste Minimization
                                 Assessment Worksheets
    Project Number
                              Prepared By_

                              Checked By_
INPUT MATERIALS SUMMARY
vvEPA
Attribute
Name/ID
Source/Supplier
Component/ Attribute of Concern
Annual Consumption Rate
• Overall
• Component(s) of Concern
• Purchase Price, $ per _
• Overall Annual Cost
Delivery Mode2
Shipping Container Size & Type3
Storage Mode4
Transfer Mode'
Empty Container Disposal/Management6
Shelf Life
Supplier Would
• Accept expired materiaJ (Y/N)
• Accept shiDPinq containers (Y/N)
' Revise expiration date (Y/N) 	
Acceptable Substitute(s), if any
Alternative Supplier(s)
Description1
Brakes
(asbestos)
Bee Cee Nu
Turp grizzly
Wheeler Bros.
Clutch
Wholesale
Auto

1200-1500
sets per year



$1.200-1.500
Truck
Boxes
stock room
hand
Buff Clutch
Wholesale
Auto Wheeler
Bros
N/A

N/A
N/A
N/A
N/A
N/A
Radiators
(lead)
Repair
Recycle
Monies

300 ea.



$5.400
Truck
Boxes
stock room
hand
Trash
N/A

Scrap Iron -
N/A
N/A
N/A
N/A
Batteries
(lead & acid)
Delco Dekt
Bdon

280 ea.



$14.000
Truck
Boxes
stock room
hand
Bdon: takes Old
Batteries
N/A

Y
N/A
N/A
N/A
N
Rinse
Water



















.
Rags &
Absorbent
Morgan Oil
PAAS
Country Com
3 m. -Morgn
Safety Kite

1500 rags 80
bundle year



?
Truck
Drum-corn
boxes-pads
stock room
hand
Corn-Safety
Kleen pad-
trash rag-
recycle-
laundry
N/A

N/A
N/A
N/A
N/A
N/A
'Stream numbers, if applicable, should correspond to those used on process flow diagram.
!e.g., pipeline, tank care, 100 bbl. tank truck, truck, etc.
'e.g., 55 gal. drum, 100 Ib. paper bag, tank, etc.
'e.g., outdoor, warehouse, underground, aboveground, etc.
'e.g., pump, forklift, pneumatic transport, conveyor, etc.
'e.g., crush and landfill, clean and recycle, return to supplier, etc. 	 _ — _ 	 1

-------
           APPENDIX B




ESTIMATED LIQUID AND SOLID WASTES

-------
                                                   Estimated Liquid and Solid Wastes Generated from
                                                              Vehicle Maintenance Operations
                                                              U.S. Postal Service Buffalo, NY
    Waste Type
   Annual Quantity
          Management Method
Annual Disposal Cost     Source of Data
           Assumptions
Oil Filters
Batteries
 Antifreeze
 Brakes
  1,374 Ibs per year    The filters are collected (uncrushed) in a 30
         or           gal. drum (approx. 60 per drum) and
approx. 1800 filters per recycled by Safety Kleen. The  metal from
         year          the casings is recovered and the filters are
                      burned  as fuel.

     280 per year      Used lead acid batteries are returned to a
                      local supplier (Eldon Batteries) who ships
                      them to a smelting plant which reclaims the
                      lead.

   300 gal. per year    Used antifreeze is stored and recycled by
                      Safety Kleen. Satellite branches, which
                      receive a significant amount of antifreeze
                      from the VMF (in one-gallon containers)
                      manage their waste separately.

 1200-1500 sets per year The brake pads for the larger vehicles
                      (trailers) are relined and the steel shell
                      recovered for scrap.  The brake pads from
                      smaller vehicles are only recovered for metal
                      value.
 Motor Oil

 Brake Fluid

 Transmission Ruid

 Solvent Engine Parts
 Cleaner
   2830 gal. per year
Combined and recovered via distillation
through Safety Kleen's Recycle Engine Oil
Program. The recovered oil is then returned
to USPS for reuse.
   5,746 Ibs per year    Collected by Safety Kleen.
                                                                                          $2564.90
                                                                                         No charge
                                              No charge
                                                             Waste manifests
                                                             Worksheet 7b - Input
                                                             Materials Summary.
                                                             Worksheet 7c - Input
                                                             Materials Summary
                    USPS
Average oil filter production weights
and disposal costs are based on
costs and production experienced
between the beginning of Jan. to the
end of March (1992).

A one to one relationship is
assumed relative to the number of
batteries bought to the number of
used batteries produced.

The number for annual waste
production is based on the most
recent manifested volume.  Pickup
occurs yearly.
                                            info requested     USPS
     No charge      Notes used to         The annual production is based on
                    determine annual      1987 data.
                    waste production for
                    the 1987 Hazardous
                    Waste Audit Report

   $3,744 per year    Waste manifests and   Average production volumes and
                    Safety Kleen purchase  disposal costs are based on costs
                    invoices.              and production experienced
                                         between the beginning of Jan. to the
                                         end of March (1992).

-------
Waste Type Annual Quantity Management Method
Solvent Brake Parts 2,106 Ibs per year Collected by Safety Kleen.
Cleaner
Annual Disposal Cost Source of Data
$2,262 Waste manifests and
Safety Kleen purchase
invoices
Assumptions
Average production volumes and
disposal costs are based on costs
and production experienced
between the beginning of Jan. to the
end of March (1992).
 Wastes Produced
 During Vehicle
 Washing, Large
 Parts Washing, and
 Floor Washing Using
 Alkaline Cleaners

  - Washwater
    Undetermined      The alkaline cleaner are used in the "floor
                       scrubber" and "pressure washer" to wash
                       down floors and cars. The washwater
                       produced passes through an oil and water
                       separator before proceeding to the
                       municipal wastewater treatment facility.
                                           Part of sewer fee   USPS
                    Virtually all the alkaline cleaner
                    purchased by the Postal Service is
                    used.
  - Oil/Grease
Sludge from
oil/water separator

Cracked Corn
Absorbent
 2,255 gal removed In
        1989
The oil/grease sludge was last collected by
Safety Kleen for incineration in 1989.
                                                                   Undetermined
USPS
1 - 2 30 gal. drums per Safety Kleen collects and fuel blends for
        year          incineration as a fuel.
                                             $590 per year     USPS
Oil Absorbent Pads        36 bundles       Municipal waste compactor
Soiled Rags
      8,515 rags       Morgan Linen Service for laundering.
       per year
                                          Not quantified. Part  USPS
                                          of overall compactor
                                                 fee.

                                             $596 per year     USPS
                                                                                                         None
                     Since the first drum of cracked com
                     waste was only half full, average
                     annual production was calculated by
                     determining the period  over which
                     this material had accumulated (from
                     March to June) and extrapolating
                     assuming a constant the rate of
                     waste production.
                     Average production volumes and
                     disposal costs are based on rag
                     usage over a 4 week period in
                     May/June of 1992.

-------
    Waste Type
   Annual Quantity
          Management Method
Annual Disposal Cost     Source of Data
                                 Assumptions
Paint Equipment      1118 Ibs (202 gal.) per These fluids are collected and recycled by
Cleaner (Spray Gun)           year          Safety Kleen.
Paint Thinner Waste  1664 Ibs (277.3 gal) per The waste paints and still sludges are
(excess paint,                year          collected and incinerated by Safety Kleen.
sludges collected
from the spray gun
still)
Paint Cans
  - non-aerosol
 Paint Cans
  - aerosol

 Paint Filters


 Radiators




 Used Tires
2,402 qt cans per year  Disposed of in municipal waste dumpster.
     Approx. 840
 2912 filters per year
Recycled as metal scrap.


Thrown in municipal trash dumpster. Wet
down if left in dumpster over 24 hours.
 280 radiators per year  Recycled for scrap iron content by BFC or
                      re-built by Moxie.
 1138-1200 small tires   Small tire casings are managed through Fox
                       Tire.  Reusable tires are re-capped and non-
                       reusable tires are disposed of.  The Buffalo
                       VMF does not use re-capped small tires.
    232 large tires      Larger traction tires are re-capped for reused
                       by the Post Office, while larger steering tires
                       are sold to the tire recycler and re-capped
                       for private sale.
                                                                   $2496 per year
                                                                  $591.5 per year
     No charge


  No extra charge


       $7000




       $1800
                                                              Waste manifests and
                                                              Safety Kleen's
                                                              invoices.
                                                              Waste manifests and
                                                              Safety Kleen's
                                                              invoices.
                                            No extra charge    USPS
USPS


Contractor note from
onsite visit.

Worksheet 7c - Input
Materials Summary
                                                              USPS
                                          Average production volumes and
                                          disposal costs are based on costs
                                          and production experienced
                                          between the beginning of Jan. to the
                                          end of March (1992).

                                          Average production volumes and
                                          disposal costs are based on costs
                                          and production experienced
                                          between the beginning of Jan. to the
                                          end of March (1992).

                                          A one to one  relationship is
                                          assumed relative to the number of
                                          cans of paint bought to the number
                                          of cans of paint disposed of.
2096.64
Interview with USPS personnel

A one to one  relationship is
assumed relative to the number of
radiators bought to the number of
cans of radiators disposed of.

This cost is expected to decrease.

-------
      APPENDIX C



Alternative Coatings Article

-------
Coatings  for
Compliance
Congress is scheduled to debate the Clean Air Act this
year, and VOC emission limits for liquid industrial
coatings are expected to be lowered. What's a finisher to
do? Comply . . .
By BEVERLY A. GRAVES
Associate Editor
      At  one lime  low-solkls/high-
      solvent coatings prevailed in
      the  finishing industry.  There
 was no need to worry about  things
 such as volatile organic compound
 (VOC) emissions or air toxics. Eas-
 ily applied finishes, with quick cure
 for swift turnaround were the order
 of the day. But the situation did not
 remain sunny and carefree. In fact,
 it  became fairly cloudy. And that's
 when the  government  decided  to
 clean the air.
    Believe  it  or  not,  the original
 Clean Air Act was passed in 19SS,
 according to Anthony J. Buonicore,
 vice president of Environmental Sci-
 ence & Engineering, Inc., Shelton,
  Conn., in his presentation at  Surface
  Coating '90  in Stnrbridge,  Massa-
  chusetts.  Most people tlo  nut  re-

  54  PRODUCTS FINISHING
member (his first  legislation but do
remember Rule 66 in California as
the first major air-pollution-control
regulation.
  Rule 66 restricted the amount of
photochemically  reactive  solvents
plants  could  discharge. Testing  on
photochemical solvent reactions per-
formed in smog chambers showed
that organic solvents in the air react
photochemically, leading  to ozone
formation and smog.  Rule 66 was
born as a result of these tests.
   The  original  Clean  Air Act  of
 1955 was amended in 1960, '63 and
 '65, before the Air  Quality Act of
 1967  replaced  it.  (Although  the
 name  changed,  the original name
 stuck.) In  1970  the Clean Air  Act
 Amendments were passed, establish-
 ing ambient  ;iir  limits for  various
                         JULY, I9»
pollutants.  EPA  was  also estab-
lished. The act placed the responsi-
bility for air pollution control with
the  states.  Each  state needed  to
submit plans for implementing regu-
lations that would meet the National
Ambient Air Quality Standards.
  Amendments followed  in  1977,
and Congress was  to review  the
Clean Air Act in 1981, but did not.
Congress  is  presently debating
amendments to the Clean Air Act.
Three bills have been introduced.
  One bill deals with air toxics: air
pollutants  that  pose a  potential
health risk. Each year in the U.S. 2.7
billion  Ibs of toxic  chemicals  are
emitted. The bill proposes reducing
this number by 75 pet. Many of the
nearly  190 hazardous  chemicals
listed in (his bill arc  covered under

JULY. 1990
GENERAL MOTORS' Buick, OMsmobilc,
Cadillac Hamlramck plant uses low-VOC,
two-component polyurethane clear coats
on its luxury vehicles.

SARA Title  III. Mr. Buonicore in
his address stated, "To comply, the
coatings industry will have to make
substantial investments  in process
changes, product substitutions, sys-
tems enclosures or emission capture
and control systems."
  So, what types of low-VOC coal-
ings  are  available?  They include
water-borne  electrocoalings and
non-electrocoatings;  high-solids,
both single-  and two-component;
chlorinated-solvent-thinned  coat-
ings;  powder coatings;   radiation
curable coatings; and a relatively
new technique that replaces solvent
with COf.
          PRODUCTS  FINISHING   J7

-------
 Lovv-VOC Paints
  Powder coalings arc proving to be
a viable option for many finishers
seeking compliance with VOC regu-
lations. The  technology has  been
enjoying double-digit annual growth
for a number of years. This growth
is forecast to continue for some time
into the future. However, the scope
of this article is to  look at liquid
coatings options for finishers  who,
for various  reasons, will  prefer to
stay with liquid finishing lines. For
that reason,  powder coatings  will
not be discussed in this report.
  Water-borne  coatings  generally
satisfy low-VOC regulation require-
ments.  After  water  evaporates,
water-borne  coatings have  charac-
teristics, both chemical and physi-
cal,  similar  to  solvent-borne  coat-
ings. Water-bornes can be  applied
by  electrocoating or spray, dip and
flow coating.
   High-solids coatings  offer  eco-
nomic as well as environmental ad-
vantages.  High-solids, both single-
and  two-component, usually meet
low-VOC  standards. Because solids
are  substituted  for  solvent,  more
surface can  be coated per  gal, but
they also  have their disadvantages,
individual to each  coating type.
   Another potential method for re-
 ducing  VOCs is  with  chlorinated-
 solvenl-thinned coatings. According
 to James A. Mertens of Dow Chemi-
 cal Company,  1,1,1-trichloroethane
 does  not cause increased ozone  in
 the lower atmosphere as do photo-
 chemically  reactive solvents.  1,1,1-
 trichlorocthnnc can be used in most

  It   PRODUCTS FINISHING
resin systems, including  polyesters,
acrylics, alkyds, epoxies, phcnolics,
nitroccllulosics and others.
  But all is not well and good with
chlorinated-solvent-thinned coat-
ings. A bill  has  been proposed  in
Congress that would list 1,1,1  and
methylcne  chloride,  among others,
as hazardous chemicals, and their
release would be strictly controlled.
  Radiation-curable coatings use ul-
traviolet or electron-beam energy to
cure 100-pct reactive liquid coatings.
Coating choices are limited. Sub-
strates are usually limited  to cylin-
drical and flat substrates, but coat-
ings have been  cured  on objects
having moderate complexity.
  Radiation curable coatings elimi-
nate the  risk of  solvent explosion
and pollution hazards, because they
emit no VOCs. They will  also cure
on  heat-sensitive  substrates.  One
disadvantage,  according   to  Carl
 Izzo of Westinghouse,  Pittsburgh,
 Pennsylvania,  is that the larger  the
 part, the more energy is needed to
 cure the  paint,  and consequently
 profit is not as great.
   CO  for Solvent. Recently a new
 system for reducing VOCs 30 to 70
 pet was unveiled  by Union Carbide.
 In the process paint  concentrate is
 mixed  with  a precise  amount of
 supercritical carbon  dioxide.  The
 mixture is drawn through tubing and
 atomized as it  is  released from a
 spray  gun. The CO,  spreads  out
 from the spray gun into the atmos-
 phere. Wet paint  film remains on the
 substrate  with  enough solvent to
                           JULY.' 1990
 give it the appearance the applicator
 wants.
   Specially designed  spray  equip-
 ment is required, but is easily retro-
 fitted to existing paint  and  finishing
 lines. It is adaptable to both manual
 and  automated  operations  and
 works in both electrostatic and non-
 electrostatic spray lines. Union Car-
 bide has licensed the technology to
 several paint manufacturers.
   Transfer Efficiency.  Does  trans-
 fer efficiency affect VOC emissions?
 According to Ron Joseph, president
 of Ron Joseph & Associates, Inc.,
 Saratoga, California, transfer effi-
 ciency is probably one of the most
 important parameters  in  reducing
 VOC emissions. The greatest bene-
 fits are derived when  transfer effi-
 ciency is low (five to 20 pet).
   As transfer efficiency increases,
 additional increments have a lesser
 effect on VOC emissions,  and the
 law of diminishing returns applies.
 A shift in transfer efficiency from
 80 to 90 pet will yield  a very
small  benefit in   terms  of  air
quality, whereas a shift from five to
 10 pet will halve VOC emissions.
   Although Mr.  Joseph does  not
have conclusive  data,  he  believes
that lower solids coatings will yield
lower transfer efficiencies than high-
solids coating, when tested  under
the same  conditions.  Therefore,
water-borne coatings,,  which  often
have a volume solids of 20 to 40 pet,
may  provide  lower transfer  effi-
ciency  than  high-solids,  solvent-
borne coatings.
JULY. 1990
 Waler-Bornc Eleclrocoaling
 Dr.  George E. F.  Brewer is princi-
 pally credited with  originating  (he
 electrocoating process  in  the late
 1950's. But Dr. Brewer states that it
 was  not a viable process until  1961.
 Originally  developed for the  auto-
 motive industry, electrocoating soon
 found its  way into the appliance,
 metal furniture and other industries.
  There are two types  of electro-
 coating processes, anodic  and
 cathoclic. In both methods parts  are
 immersed in an electrically charged
 coating. Anodic coatings deposit on
 a positively charged part, the anode,
 and  cathodic coatings deposit  on
 the  negatively charged part,  (he
 cathode.
  Cathodic coatings usually require
 better surface preparation than  an-
 odic  coatings, but  provide  better
 corrosion resistance. Anodic  coat-
 ings have lower  bake temperatures,
 some as low as  2SOF. An air-dry
 version has been developed, recently.
 Also, the resin for anodic  coatings
 generally costs  less.  Electrocoat
 resin  types include polyester, epoxy
 esters and acrylics.
  Recent improvements in cathodic
 electrocoatings include  higher film
 build,  improved  edge coverage and
 throwing power, reduced pinholing
 over zinc galvanized alloy,  reduced
 VOCs and  lower  curing tempera-
tures. Industry is demanding more
improvements, including better cor-
rosion  resistance,  shorter  baking
times and even lower temperatures
and VOCs.

           PRODUCTS FINISHING   J9

-------
 LowvOC Paints
  Anodic cleclrocoalings have their
own  advantages.  Coating  thick*
nesses as low as 0.4 mil will hide and
protect  the  substrate.  They  have
lower  bake  temperatures   than
cathodic, as mentioned previously.
  The  overall  basic  strength  of
water-borne electrocoatings, accord-
ing to several paint suppliers, is their
high  application efficiency.  Other
strengths  include even coverage,
VOC compliance, good appearance
and application efficiency.
  Weaknesses  include equipment
costs,  tank maintenance and  color
variety. Other disadvantages include
the  need  for  corrosion-resistant
pumps, pipes and tanks and sensitiv-
ity to surface cleanliness.
   VOC levels are becoming the most
important consideration  for finish-
ers.  VOC  levels  for  water-borne
electrocoatings range from less than
2 to 3.5 Ib/gal.  In addition to the
automotive industry,  industries
using electrocoatings include metal
and  wood  doors,  compressors,
tools,  blower  housings  and  fans,
electrical switch gear, office equip-
ment, computers, and appliances.
  The future for water-borne elec.-
trocoatings,  as envisioned  by paint
suppliers,  varies. Some see  an in-
crease in use while others feel  the
market is saturated. All believe (hat
electrocoating is  here to stay.

Water-Borne Non-Elcclrocoaling
  Water-borne coatings  (non-elec-
trocoat)  can be air-dried,  force-
  TABLE I—Comparison of Coating Technologies
f
Coaling Single-
Technology Component
Alkyds & Acrylics Yes
High-Solids
(Air-Dry)
Alkyds. Acrylics & Yes
Polyesters High-
Solids (Baking)
Epoxies— No
High-Solids
Poryurethanes ' No
High- Solids
Water-Borne Yes
Alkyds & Acrylics
(Air-Dry)
Water-Borne Yes
Alkyds & Acrylics
(Baking)
Powder Yes
Clurlrnrfunosillon YCS
Two-
Component
No

No

Yes
Yes
No,

No
No
No
' Drying Film Thickness
Tlme"> Control
Slow Fair

Medium to
C<«el flfab*\
rasi l Da KB j
Medium
Medium
Medium lo
C<**l
Fast
Medium to
Fast (Bake)
Medium lo
Fast (Bake)
Medium lo
*
Fair

Fair
Fair lo
Good
Good

.Good
Fair to
Good
Very Good
Hardness 1
Fair

Good I
|

Very Good
Very Good ;<|
Fair
I
Good •;• /3
#(:|
Very Good
I
• • '• 'iUJ
Very Good -|
1 Abrasion
1 Resistant
Fair
1
I . Good
1
Very
L Good
E; Very
i Good
[ Fair
1
w
\ Very
1 Good
•DTi' P»'
•ft^vfery
IE- 72.; Good
Resistance lo:
Chemicals Solvents
Fair Poor

Very
Good

Very
Good
Very
Good
Poor

Good-
Very Good
Very
Good
..Very..
• Rnnri

Very .
Good

Good
Very
Good
Poor

Good- ;••••
• Very Good..- •••;
• ••• ' •••.
Very
Good
........ Very .;...-. .:
• -•JCnnrf-'-.1
Special
Application
Sunlight Equipment
Fair No

Very
Good

Poor
Very
Good
Fair

Good
i . '•
Fair-
Good
Very
Ciwwt '

Nol"

No
No«'»
No

,•'..".-': •> No
\ • •
••'KI-.. .•;'.'.•
Yes
^Wv.:']**'- •'•
                                                                                                                                       Facility
                                                                                                                                      Equipment   Coating
                                                                                                                                        Cost      Cosl
                                          Fast (Bake)
    'l'i Drying Times! slow drying - 3-8 hours; medium - 1-3 hours; medium-last = 20-60 mln.
     i}> No data available, but expected lo be good.
     i]) Some situations require high-speed, turbine-powered bells or discs.
     l<> Some high-solids polyurelhanes must be spray-applied through plural-component spray equipment.'


    M   PRODUCTS FINISHING                                        JULY, 1990
                                                                                                                                        Low
                                                                                                                                        Low
                                                                                                                                       Lnw<«»
                                                                                                                                       Low
                                                                                                            low
                                                                                                                                      Medium    Medium
                                                                                                         Medium lo
                                                                                                           High
                                                                                                         Medium lo
                                                                                                           High
                                                                                                         Medium
                                           JULY. 1990
                                                                                                                                      Medium    Medium
                                                                                                                                     Medium lo   Medium
                                                                                                                                       High
                                                                                                                                       High     Medium
                                     (Source: Ron Joseph, Ron Joseph & Assoc.)


                                              PRODUCTS FINISHING   61

-------
luw-VOC Paints
dried or baked.  Forced drying al-
lows  coatings  to  develop  their
final properties  more quickly. Bak-
ing systems provide for denser paint
films and improved performance.
  Non-electrocoal water-borne resin
types include acrylic latex, haloge-
nated copolymer latex,  aqueous ure-
thanc,  alkyds,  modified  alkyd,
alkyd and acrylic melamines, acryl-
ics, phcnolics, acrylic  latexes,  vinyl
emulsions, epoxies and epoxy esters
and polyesters.
  Various suppliers point out  that
acrylic water-bornes air dry quickly,
can be dip or spray applied, show
good adhesion  and gloss. And, ac-
cording to Thomas N. Dietsch Jr. of
The Thermoclad Co., Erie, Pennsyl-
vania, acrylics  perform better  out-
doors than  alkyds.  Alkyds   have
excellent  application properties,
however.
   Ken Lawrence  of Progress  Paint
in  Louisville, Kentucky,  touted the
performance properties  of epoxy
esters, saying that they provide  ex-
cellent adhesion  on less-than-clean
surfaces. Chuck Cosner  of Maurer-
Schumaker in  Livonia,  Michigan,
 agrees that both epoxies  and epoxy
 esters provide  good  adhesion.  He
 also adds that they offer good corro-
 sion and chemical resistance,  hard-
 ness and flexibility.
    Phenolics  are  corrosion  and
 chemical resistant and  have  better
 performance in  outdoor  applica-
 tions than alkyds. Vinyls also pro-
  vide good corrosion resistance, as
  well as good adhesion.

  tt   PRODUCTS FINISHING
                                     The  VOC  levels  reported  for
                                   water-borne  non-electrocoatings
                                   range from less than one half to 3.5
                                   Ib/gal.
                                     Applications  for  water-borne
                                   non-electrocoatings  are  varied. In-
                                   dustries using these coatings include
                                   aerospace; transportation; automo-
                                   tive;  appliance;  steel  containers;
                                   rail-car accessories; air conditioning
                                   parts and housings; structural steel;
                                   metal furniture;  metal  and  wood
                                   doors;  shelving and storage  racks;
                                   truck engines; farm equipment; light
                                    fixtures; and many more.
                                      These coatings strengths include
                                    low VOCs, smooth film, corrosion
                                    resistance, good adhesion, easy ap-
                                    plication  and  clean  up, low-cost
                                    equipment outlay,  non-flammable,
                                    fast drying and low toxicity.
                                      Bud Pare of Strathmore Products
                                    in Syracuse, New  York, contends
                                    that  in  many  cases  water-borne
                                    products equal solvent-borne prod-
                                    ucts in performance,  particularly in
                                    areas such as gloss, color, corrosion
                                    resistance and a-'   sion. In fact, one
                                    such product  hu» been  developed
                                    that in tests surpasses solvent-bornes
                                    in corrosion resistance.
                                       Close control of paint application
                                     parameters is necessary when apply-
                                     ing water-borne coatings.  Drying
                                     time is  affected by humidity and
                                     temperature,  because water evapo-
                                     rates  more  slowly  than  solvent.
                                     Water-borne  paints also  tend to
                                     blister when placed in  baking ovens
                                     without sufficient flash-off time.
                                       Suppliers state that the increasing
                                                               JULY. 1990
 limitations on VOC emissions will
 increase the attractiveness and use
 of watcr-borncs.  Some suppliers see
 the need to boost user confidence
 in water-borne  finishes.  As  Tracy
 Garrett  Jr.  of  Deft  Inc.,  Irvine,
 California, sees it, "A  lol of users
 remember (he old consumer latex
 (water-borne) paints that came out
 when  oil-based  paints  were out-
 lawed. Those old  paints didn't stick,
 and they generally were not good.
 Unfortunately this carried over into
 industrial situations."
   Catalyzed resin systems overcome
 some  of the problems  associated
 with water-bornes. The  systems are
 said to "trick" the chemicals in the
 paint into accepting water only as
 the  carrying  agent. Because the
 water  in the paint acts only as  a
 carrier, the paint  film is not subject
 to  moisture and  humidity to the
 extent  that other water-borne paints
 may be.  These coating systems are
 used  for construction  equipment,
 fighter aircraft and tanks.
  Suppliers see a continuing effort
 to lower  VOC content and enhance
 performance properties  of water-
 borne coatings.

 Two-Component High-Solids
  High-solids is now a fast-growing
 coatings technology. But, according
 to Sudhir Laddha and Raymond T.
 Chlodney  of Essex  Products,
 Clifton, New Jersey, the early high-
solids coatings had their problems.
These  included  heavy-film build,
 high bake  temperatures,  -greater

 JULY, 1990
 clean-up time, high-cost, high vis-
 cosity,  inferior gloss, limited  mois-
 ture resistance and solvent popping.
   Systems developed later had lower
 drying  times and  viscosities, and
 they could be applied with conven-
 tional equipment. Most recent devel-
 opments in  high-solids coatings
 have  further improved  on  these
 characteristics.
   Two-componcnl coalings arc gen-
 erally  used  when  good  hardness;
 abrasion, corrosion, chemical and
 solvent  resistance; and exterior du-
 rability  are required. They are also
 used  when bake ovens  cannot  be
 used because of heat-sensitive sub-
 strates.  High-solids, two-componcnl
 resins  include  acrylics, epoxies,
 polyesters  and  acrylic  urethanes,
 polyurethanes and polyester-based
 polyurethanes.
   Acrylic urethanes,  according to
 paint suppliers, offer excellent gloss
 and color retention as well as  excel-
 lent chemical resistance.
   Ken  Peter of  Perry  & Derrick,
 Cincinnati,  Ohio, extols the attrib-
 utes of epoxies  saying  they  offer
 excellent adhesion and toughness as
 well as  chemical, solvent and  water
 resistance.
   Polyester urethanes  offer  excel-
 lent gloss and color retention and
 good  chemical resistance. Polyure-
 thanes also offer high gloss, flexibil-
 ity, chemical and solvent resistance,
 in addition to durability, weathera-
 bility, abrasion resistance and easy
cleaning. Vic Scaricamazza of Mor-
ton International Specialty Chcmi-

           PRODUCTS FINISHING  43

-------
 Lotv-VOC Paints
cals Group. Chicago, Illinois, adds
(hat two-component urethanes also
offer excellent corrosion resistance,
  VOCs for  two-component, high-
solids coatings range from 2.7 to 3.5
Ib/gal. The transportation manufac-
turing industry appears to  be the
largest   user.  Cars,  car  carriers,
buses, heavy-duty  tractors,  trucks,
truck trailers, rail cars, marine com-
mercial  aircraft and high-precision
 fighter   aircraft manufacturers use
 two-component,  high-solids  coat-
 ings. Other industries also using the
 coalings include  manufacturers of
 ground-support  equipment for
 fighter aircraft,  aircraft  compo-
 nents,   composite containers, ma-
 chine tools and other miscellaneous
 items.   Two-component,  urethanes
 also are used extensively on products
  made  of plastics and other  heat-
  sensitive materials.
  But these coatings do have their
limitations. The major shortcoming,
according to most suppliers, is short
pot life (as little as four hours to as
much as 12 to 24 hours). Another
drawback is that  in some instances
the coatings arc  more difficult to
apply uniformly  and  have slower
drying  times.  As  Carl  Varga  of
Man-Gill Chemical Co.,  Cleveland,
Ohio, says, a particular weakness of
polyurethanes is concern over health
hazards of isocyanales. But he adds
that suppliers are working to remove
isocyanales  while  maintaining, a
quality coating.
   Two-component, high-solids coat-
 ings are also either air dried, force
 dried or baked.  According to  EPA
 regulation, air-dried or force-dried
 coatings are defined as  those dried
 below   194F.  Baked  coatings are
 cured  above  194F. They include
                 u Sri
                            o

 polyesters,  acrylics, epoxics  and
 alkyds.
   Air-dry coatings by nature con-
 sume less energy when curing. They
 are  ideal for large machines  and
 heat-sensitive substrates.
   Use of two-component, high-sol-
 ids  coalings should increase, ac-
 cording  to  finish  suppliers.  Espe-
 cially  for  finishers who need  to
 comply with regulation while pro-
 viding high-performance finishes.
  One company needing  to do just
 that was The Ford Motor  Company.
 In  1988, Ford  specified  that  two-
 component polyurethane  clear coat
 be used on its models. The coating is
 said  to  provide a  higher, gloss,
 smoother and more durable surface
 than conventional paints. The top-
coat also resists environmental "fall
out" such as acid rain.
  According to Dale  Bayer of

CAR  CARRIER is  first coaled wilh a
low-VOC high-solids primer followed by a
low-VOC high-solids urethane topcoat.
 Mobay,  suppliers of raw materials
 for polyurethane  coatings,  more
 than 90 pet of the automotive plastic
 market in Europe uses two-compo-
 nent urethanes. The coatings have a
 40 pet market share in Japan. In the
 U.S. I lie market slime is only 10 pel,
 but growing.
   General Motors also uses  two-
 component   polyurethane clear
 coals. They are applied to its luxury
 vehicles  manufactured at  G.  M.'s
 Hamtramck plant in Detroit, as well
 as its other assembly facilities.
  Sherwin-Williams is also finding a
 market  for its low-VOC  two-com-
 ponent polyurethane enamels. Mar-
 kets include  computer  housings.
 burial caskets, measuring and dental
 equipment,  sewing  machines  and
 snowmobiles.

 Single-Component High-Solids
  Resins  for  single-component,
high-solids coatings include alkyds,
alkyd melamines, alkyd ureas, acryl-
ics,  polyesters, polyester melamines,
  epoxies and  phenolics. Air-dry
     ^alkyds  and  acrylics  have
                     slow  drying
                                                                   1*33
                                                                                                                   f'/J
        PRODUCTS FINISHING
                                                               JULY. IWO  I  JULY. 1990
                                                                                                                        PRODUCTS FINISHING   65

-------
 LowVOC Paints
times  (three  to eight  hrs),  with
average hardness, abrasion chemical
and  sunlight  resistance.  Baked al-
kyds, acrylics and polyesters dry in
20 to 60 min. with some coatings air
drying in as little as 15 to 18 min.
  As mentioned,  air-dry  or  force-
dry  coatings  consume less  energy
than baked coatings. Force-dry sys-
tems, where some heat is used to
accelerate  drying,  cure at  120 to
I60F. Although these systems show
good corrosion resistance and physi-
cal attributes, they do require more
lime to attain adequate hardness.
 ^Baking-type high-solids coatings
require high  bake  temperatures,
sometimes up to 350F.  But coatings
being developed will permit reduced
bake  temperatures.  Baked  single-
component,  high-solids  coatings
have hard films and chemical  and
physical properties  comparable to
two-component coatings, according
to Mr. Joseph.
  Because of the high bake tempera-
tures,   single-component coatings
cannot be  applied to  plastics and
other   heat-sensitive  substrates.
Also, if not cured  above a minimum
temperature, they remain tacky in-
definitely, Mr. Joseph warns.
  VOC levels for single-component,
high-solids coatings range from 2.3
to 3.5 Ib/gal.
  According  to Chuck  Cosner of
Maurer-Schumaker,  single-compo-
nent coatings are best  for industries
where  ultimate corrosion protection
 and durability are required. Users of
 these  coatings include  steel door,

 66    PRODUCTS  FINISHING
new and reconditioned drums, metal
furniture, tool boxes, aluminum ex-
trusion,  window,  appliance,  bicy-
cles, tricycles,  exercise  equipment,
waste receptacles, light fixtures, bat-
tery chargers, auto parts and shelv-
ing manufacturers.
  Coating advantages, as compared
to two-component, include longer
pot life and no mixing mess. Other
attributes are less costly application
equipment,  variety of  application
methods, low VOCs, good appear-
ance and  protection,  quick  color
change capability,  good chemical
and  physical  resistance and  good
outdoor durability.
  Drawbacks  to using  single-com-
ponent,  high-solids  coatings  are
high curing temperatures, wet paint
tends to pick up dirt, more involved
clean-up and  booth maintenance,
over-bake and rccoating problems,
sensitivity to marginal surface prep-
aration and the temperature/viscos-
ity correlation. Occasionally paint
must  be heated  in order  to  be
sprayed,  but  urethanes are  heat
sensitive and  therefore cannot  al-
ways be heated.
   Other  problems  include  sludge
buildup in spray booth reservoirs.
Because of this, dry  niters, skim-
mers or cyclonic sludge-removal sys-
tems  should  be used.  High-solids
coatings obviously have more solids
 than  solvent-bornes,   hence more
 sludge is  generated in  the  booth
 unless  application  transfer effi-
 ciency is optimized.
   Many suppliers see a good future
                          JULY. 1990
  for  single-component,  high-solids
  coatings,  while others  see water-
  borncs replacing them.

  Chlorinated-Solvent-
  Thinned Coatings
   Solvents used in  chlorinated-sol-
  vent-thinned  (CST)  coatings  have
  been considered exempt  from many
 air-pollution  regulations  because
 they do not contribute to the forma-
 tion of ozone. Their exemption may
 soon be eradicated.
   The Bush administration has pro-
 posed legislation that would reduce
 toxic chemical emissions by 75 pel.
 Nearly 190 chemicals are  listed as
 hazardous, including  1,1,1-trichlo-
 roethane, a common solvent used to
 thin  paint.  The  problem  is  that
 chlorinated solvents are  believed to
 react similarly  to chlorofluorocar-
 bons,  thus contributing  to alleged
 global warming.
   Chlorinated-solvenl-thinned coat-
 ings use  resins such as  acrylics,
 alkyds,  phenolated alkyds, epoxies
 and polyesters. Acrylics are said to
 have  excellent  exterior  durability.
 Phenolated alkyds  have excellent
 corrosion  resistance, and when top
 coated with an acrylic,  withstand
 500  hrs  salt  spray.  Epoxy  resins
 provide excellent strength,  durabil-
 ity, adhesion,  chemical  resistance
 and electrical properties.
  Products finished  with  these
coatings  include  industrial  air
compressors, air conditioning units,
plastic shutters, steel posts and steel
containers.

JULY. 1990
    Chlorinated-solvent-thinned coat-
 ings are fast drying, have low VOCs
 and low viscosity. Vic Sanlamarin of
 Jamestown Paint and Varnish Co.,
 Jamestown, Pennsylvania,  believes
 they are essentially  equal  in per-
 formance  to conventional  solvent-
 borne coatings.
   One significant limitation of chlo-
 rinaled-solvent-lhinned coatings
 could be  their  inability  to  meet
 new air-pollution regulations. An-
 other shortcoming  is  their fast
 evaporation rate, which can  result in
 orange peel,  solvent popping and
 resin kickout.
   Most  suppliers  believe  chlorin-
 atcd-solvenl-lhinned  coatings will
 give way to water-bornes and high-
 solids coatings.  Mr. Santamaria
 even predicted thai chlorinated-sol-
 vent-thinned coatings will be extinct
 by the year 2000.
   For this  report, paint suppliers
 were asked how they viewed market
 penetration  for  various .low-VOC
 paints now and in 1995: The sample
 was small, and the predictions var-
 ied. For  certain categories  some
 suppliers predicted increases in coal-
 ings use, while olhers predicted de-
 creases.  The suppliers   responses
 were averaged. This will  provide a
 general idea of their predictions for
 low-VOC paints.  Remember, this  is
 not a representative sample.
  Market share for all water-borne
coalings is  predicted to increase 15
pet.  Single-component,  high-solids
coatings are expected to decrease in
market share by  16 pet.  Two-com-

           PRODUCTS FINISHING   67

-------
ponenc. high-solids coalings are ex-
pected  to increase market  share
dramatically, by 128 pet. The fore-
cast  for chlorinaied-solvcnt-thinned
is a 47 pet decrease.
  Howard Ellerhorst,  chairman  of
The Chemical  Consulting Group,
Cincinnati, Ohio,  a global consult-
ing firm that determines trends and
market shares for the products fin-
ishing industry, slated that in the
United Slates in 1990, 56 pet of all
paints  applied  (solvent-borne  and
two-component  high-solids,  water-
bornes, powder and radiation cure)
 involve low-VOC  formulations.  By
 1997,  low-VOC  systems are  ex-
 pected to have a 65-70 pet share.
    The forecast for both anodic and
 cathodic elect rocoat is seen as favor-
 able through 1997.
    The collective growth rate for all
  industrial  coatings  from 1990-1997
  is  forecast at a uniform  1.7  pet per
  year.  Low-VOC  growth rate is  cur-
  rently predicted as a steady 3.6 pet
  over the next  seven  years. But, Mr.
  Ellerhorst  cautions  that you never
  know  when  new  legislation  will
  cause a growth spurt or decline.
   What's on (he Horizon?
     Debates this year in Congress on
   the Clean Air Act Amendment will
   focus on three bills that concern air
   toxics, acid rain and  ozone/carbon
   monoxide  non-attainment. The air
   toxics and ozone/carbon monoxide
   non-attainment areas will affect fin-
   ishers the  most. Nearly  800 pollut-
   ants  arc already regulated. And 190

   (I    PRODUCTS FINISHING
more arc round on President Bush's
air toxics proposal, including 1,1,1-
trichloroethane.  methylcne chlo-
ride, methyl ethyl ketone and others.
  According to  Mr.  Buonicore, the
air  toxics  legislation requires that
EPA list categories and  subcatego-
ries of  major and area  sources of
these  hazardous. A major source is
one emitting, or with the potential to
emit, 10 metric tons/year of a single
listed hazardotis substance.
  The ozone/carbon monoxide non-
attainment legislation will  focus on
industries  in  non-attainment areas,
requiring them to lower their VOC
 emissions.  Industries targeted  will
 be polymer and  resins; auto body
 refinishing;  truck,  bus and heavy
 equipment  manufacturing and
 painting;  appliances, miscellaneous
 coated products;  automobile paint-
 ing; paint stripping; and  architec-
 tural coatings.
    Suppliers Help With Compliance.
  Paint  suppliers continue to develop
  lower-VOC  compliance  coatings.
  One way finishers  are  trying  to
  comply is through  improved trans-
  fer  efficiency, but  they cannot rely
  on  this  alone. The government is
  lowering the  limits.  Finishers are
  concerned. Several comments made
  by  finishers during Surface Coating
  '90 revealed that they are extremely
  concerned with the effects of air-
  pollution regulations. Many do not
   feel  paint  suppliers  are  providing
   the support,  in terms of low-VOC
   coalings, that  they  need  to  slay
   compliant.
   Isocyanalcs are round in polyure-
 thane coatings, and OSHA regulates
 their  emission.  Because  they  react
 with water, they pose a  significant
 health threat  to people and the
 environment. One dramatic example
 is Bhopal,  India, where  an  isocya-
 nate leak killed  more than 2,000
 people. Even limited amounts have
 an effect, including breathing diffi-
 culties, skin irritation and eye tissue
 damage.
   Several companies have  devel-
 oped and are developing isocyanate-
 free  paints. MagnaClad,  Inc.  in
 El Toro,  California, has  developed
 a  low-VOC water-borne polyure-
 thane  paint  that contains no  free-
 isocyanates.
   Chuck  Grewer  of MagnaClad
 feels that polyurethanes  never en-
 joyed  the popularity  they  should
 have because of factors such as
 smell, drying time, flammability and
 isocyanates.  The  new  isocyanale-
 free  products provide the character-
 istics  of  solvent-borne  polyure-
 thanes, as well as low VOCs.
  Clean Air Act Amendments are
 slated  for debate and potential ap-
 proval  this year. These amendments
 will  ensure  that  finishers comply
 with  lower  VOC emission  rates.
 Improved  transfer efficiency  helps,
 but it alone will not help finishers
comply. Being in  a non-attainment
 area  is not going to be beneficial.
And  although finishers may suffer
more headaches,   the  government
plans to  ensure  thai it won't be.
because of dirty air.           PF
                            JULY. I9W I   JULY. 1990
                                   For more data circle 504 on Postpaid Card
                                              PRODUCTS  FINISHING   69

-------
APPENDIX D



 Factsheet

-------



                         Vehicle
                         Maintenance
|  WHAT IS THE WASTE PROBLEM?
     Vehicle maintenance facilities use a number of
different hazardous materials and generate both hazardous
and nonhazardous wastes. Typical vehicle maintenance
activities and wastes generated include:
    • cleanup of the shop area (rags, solvents)
    • cleaning automotive pans (organic solvents, caustic
     waste waters and sludges)
    • replacement of automotive fluids (waste oil, oil filters,
     transmission and brake fluid, antifreeze)
    • replacement of non-repairable equipment (batteries,
     brakes, shocks, tires, mufflers, electrical components,
     water pumps)
    • repair of fixable equipment (brake calipers/rotors/
     drums, alternators, fuel pumps, carburetors, power
     train components)
    • light body work and touch-up painting (solvents, paint,
     paint thinner)
    • fueling vehicles (leaked or spilled petroleum during
     fueling and from underground storage tanks)
     HOW DOES THIS AFFECT YOU?

     Because of the similarity in operations at Vehicle
Maintenance Facilities (VMF), waste streams and waste
issues are comparable to those found at the Buffalo VMF;
therefore, the Buffalo facility is used as a case study to
exemplify waste problems and pollution prevention opportu-
nities.

     The U.S. Postal Service Buffalo District Vehicle
Maintenance Facility (VMF) maintains 1,200 vehicles each
year. The vehicles range from light delivery vehicles to
tractor trailer trucks. Operations at the Buffalo VMF include
vehicle washing, fueling, minor body repair and painting, and
engine maintenance and repair.

     The hazardous materials used for VMF operations can
be harmful to the workers exposed to these chemicals and
can cause environmental problems, such as polluting storm
water wilh oil, grease, fuel, and other contaminants. Han-
dling, tracking, treating and disposing of the wide range of
VMF operation wastes is time consuming and expensive. In
addition, the potential legal and financial liability of improp-
erly managed wastes or hazardous materials is also a concern.

     To address these waste management  issues, the Postal
Service is committed to source reduction and recycling as a
sound environmental practice. Source reduction is a multi-
media approach that minimizes or eliminates waste released
to land, air, and/or water without simply shifting pollutants
from one media to another. The Postal Service considers
source reduction to be the most preferred environmental
management technique for dealing with a waste generation
problem. For those wastes that cannot be reduced at the
source, the Postal Service recommends that generators
consider recycling as the next best option.

     In the Postal  Service Waste Reduction Guide (AS
552), the Postal Service set an overall goal to reduce waste by
25 percent from 1992 levels by December 1993 and an
additional 25 percent by December 1995. Additionally,
the Postal Service plans to reduce the use of
the 17 hazardous chemicals that have been
identified by EPA's 33/50 Program by 1995.
     WHAT CAN YOU DO?
UNITED STATES
POSTAL SERVICE
     Various waste reduction options have been identified
that can reduce or eliminate VMF wastes and help meet the
Postal Service's overall waste reduction goals.

     SOURCE REDUCTION
     Source reduction reduces the amount of waste or the
toxicity of the waste at the source, that is, before the waste is
generated. This can be accomplished by improved operating
and housekeeping practices, materials substitution, or process
and equipment modification.

     Improved operating and housekeeping practices»
Procedural changes that result in reduction of wastes. These
include:
   • Personnel practices - Management initiatives, em-
     ployee training, and employee incentives all help to
     promote pollution prevention and ensure proper use
     and handling of hazardous materials.
   • Procedural measures - Proper recordkeeping, material
     handling and storage, material tracking, inventory
     control, and scheduling can prevent materials from
     becoming wastes.
   • Loss prevention practices - Spill prevention, preventa-
     tive maintenance, and emergency preparedness are
     very effective at reducing the amount of waste gener-
     ated.

-------
       Materials substitution • Substitute hazardous sub-
 stances with nonhazaidous or less hazardous substances.
 Examples include:
     •  Alternatives to organic solvents include reformulated
       carburetor cleaner compounds, physical cleaning
       methods, and water-based cleaning systems.
     •  Use water-based paints in place of solvent-based
       paints. Water-based paints are formulated with
       considerably less solvent man solvent-based paint and
       cleanup with water.
     •  Substitute phosphate-free biodegradable detergent for
       standard detergents when washing vehicles.
       Process and equipment modifications • Change
 process steps or modify equipment to reduce waste. Ex-
 amples include:
     •  Determine how clean parts need to be prior to clean-
       ing.  Many parts require only enough cleaning for
       inspection.
     •  Use a pre-cleaning step. Cleaning efficiency can be
       increased by manual brushing or pre-rinsing parts
       before cleaning the part in a solvent or aqueous
       cleaner.
     •  Remove parts slowly from the solvent solution to
       reduce dragout and avoid spills. Cover the solvent
       sink when not in use to prevent solvent evaporation.
     •  Install or convert free running rinse to still rinses.
     •  Install vapor recovery nozzles on fuel pumps to
       recover fuel emissions.

       RECYCLING
       Recycling recovers a waste from one
 process and reuses it in the same or in another
 process in an environmentally safe manner.

      Many wastes from VMF operations
 have the potential to be recycled or reused.
 These  include engine oil, transmission fluids, solvents, parts
 washing solutions, vehicle washing wastewater, batteries,
 refrigerants such as CFC-12, and antifreeze solutions.
 Segregating wastes facilitates recycling and reuse of materi-
 als.  In particular, separate nonhazardous material from
 hazardous wastes, oil from solvent, and non-chlorinated
 solvent from chlorinated solvent Recycling alternatives
 range from contracting with an outside company to collect
 and recycle wastes, to installing and operating on-site
 recycling equipment

     Purchasing products made from or containing recov-
ered material or products that can be recycled  helps to create
and sustain recycling markets. Federal Procurement Guide-
lines urge Federal agencies to establish an affirmative
procurement program for recycled content products or
material. Recycled items that can be used at VMFs include
re-refined engine oil, antifreeze, recapped or retread tires, and
solvents for parts cleaning and painting.  In addition, many
paper, plastic, metal, and glass products are made with
recycled material or can be recycled.

      ENERGY CONSERVATION
      An energy audit can identify ways to conserve energy
and cut energy expenditures. Some methods of reducing
energy consumption include:
    •  Replacing old bulbs with energy efficient light bulbs
    »  Installing motion-sensitive lights
    *  Turning off lights and machines not in use
    •  Installing programmable thermostats


      REFERENCES

      The following is a list of references that provide
information on applicable pollution prevention techniques,
associated implementation costs, and potential source
reduction gains.
   1.    Waste Reduction Guide, USPS, (AS 552), Feb. 1992
   2.    Recycling Guide, USPS (AS 550), August 1991.
   3.    Hazardous Waste Guide, USPS (AS 553), May
        1992.
   4.    Guides to Pollution Prevention: The Automotive Re-
       pair Industry. USEPA, Risk Reduction Engineering
        Laboratory, Cincinnati, OH. 1991.
   5.    Guides to Pollution Prevention: Automotive Refin-
        ishing Industry. USEPA, Risk Reduction Engineer-
        ing Laboratory, Cincinnati, OH. 1991.
   6.    Waste Audit Study for Automotive Repair Shops.
        California Department of Health Services - Alterna-
        tive Technology Section. 1987.
   7.    Hazardous Waste Reduction Assessment Handbook
       for Automotive Repair Shops. California Department
        of Health Services - Alternative Technology Section
        1989.
   8.    Fact Sheet: Ultrafiltration. Minnesota Technical
        Assistance Program.
   9.    Pollution Prevention Tips: Waste Reduction Options
       for Radiator Service Firms. North Carolina Pollu-
        tion Prevention Pays Program.
  10.    Waste Reduction Information: Choosing a Still for
        On-site Solvent Recovery. Minnesota Technical
        Assistance Program.
  Funding provided by the United States Environmental
  Protection Agency and the United States Postal Service

-------
                   APPENDIX E




ECONOMIC FEASIBILITY OF WASHWATER RECYCLING SYSTEM

-------
                                          Appendix E
                        Economic Feasibility of Washwater Recycling System


       Prior to being repaired or serviced vehicles are washed using a Graco brand power washer. Large
engine or vehicle parts are also washed in the power washer. Currently wash water from vehicle and large
parts washing operations drain to the oil and water separator. A small capacity automatic car wash which
recirculates the washwater could reduce the amount of waste water.

       Several companies are marketing wash water recirculating systems including Landa and the Hotsy
Corporation. A wash water recycling system collects contaminated washwater, passes it through a series
of filters to remove contaminants and then recirculates the clean water for reuse. The  sludge waste is
collected for disposal. The system removes solids, oils and greases, and bacteria, it also adjusts the water's
PH.

       A  recirculating system would greatly reduce water consumption and sewer use since there is no
effluent from the system, the water is 100 percent reused. The amount of water used by the VMF's power
washer is  unknown since water use is monitored on a facility wide basis and not for specific operations.
USPS personnel should consider installing a water meter to gather accurate water consumption data.
Assuming that the power washer is used 4 hours a day at an average flow rate of 4 gallons per minutes, the
annual use is 249,600 gallons. Even if the  power washer is only used 1 hour a day the annual water use
is 83,200 gallons.

Table E-1  presents a cost/benefit analysis for a wash water recycling unit. The very low water and sewer
fees currently paid by the USPS make this an economically unattractive option at this time.

-------
          TABLE E-1. COST/BENEFIT ANALYSIS: WASH WATER RECYCLING SYSTEM
 CAPITAL COSTS
 Hotsy RC 1000
 Transportation
 Installation (labor @ $25/hr, piping and electrical)
 Total Capital Expenditure
 Operating and Maintenance Costs
 Operating costs:
    Maintenance (routine, plus cost of filters)
    Labor ($25/hr)(130 hrs/yr)
  Disposal costs:
         Sludge in sump pit
         Spent filter socks
         Cartridge filter
         Total estimate $150/month
  Total Annual Operating and Maintenance Costs
  Avoided Costs
  Disposal cost
        Waste water (249,600 gal/yr)(1,000 ft3/7,480 gal)($5.76/1,000
        ft3)
        Water consumption savings (249,600 gal) (1,000 ft3/7,480
        gal) ($3.82 gal)
  Total Annual Avoided Costs
  Net Annual Benefit (NAB) = Avoided Costs - O&M
$ 22,395
$   100
$ 4,000
$ 26,495
$  3,000
$  3,250
$  1,800
$  8,059
 $  192
 $  127


 $  319
 $ -7,739
Assumptions
              The VMF uses the pressure washer 4 hours a day; the average pressure water sprays at
              4 gai/min (240 gal/hr); total annual water consumption is 249,600 gal/yr.
              Water rates are $3.82 per 1,000 cubic foot and sewer fees are $5.76 per 1,000 cubic feet
              based on billing record for January to March 1991.
              1,000 cubic feet equals 7,481 gallons.

-------
       APPENDIX F




ACME PRODUCT INFORMATION

-------
                                                  TECHNICAL   DATA
 Automotive Finishes
 PRODUCT
 DESCRIPTION
                                                                                               TM
                                                      NE-Prime

                    Water   Borne   Primer-Surfacer
                                                                  Gray  585
NE-Prime™ 585 is a single-component, water borne primer-surfacer with a VOC as applied of 1 10
Ibs/gal designed to be used in VOC regulated regions. NE-Prime™ 585 is packaged ready to spray
and has excellent adhesion to steel, aluminum, fiberglass, and OEM surfaces.  NE-Prime™ 585
provides excellent filling, sanding, corrosion protection, and gloss holdout, ft is an ideal substitute
for lacquer primer-surfacers where fast dry and quality performance are required.
 TECHNICAL
 DATA
 SURFACE
 PREPARATION
 MIXING
APPLICATION
RECOATING
  Color
  Flash points
  Volume solids as applied
  VOC (Volatile Organic
  Content as applied)
  Viscosity #2 Zahn
  Lead/chromate free
  Air pressure
     Gray   • Recommended dry film        2.0-2.5 mils
>200°FTOC     thickness after sanding
    29.0%     Dry time before sanding @ 75°F  30-45 min.
 1.1 Ib./gal.     Sandability  Excellent-no clogging of paper
              Holdout                    Very good
   45 sec.     Humidity resistance (500 hours)*     Good
      Yes     Salt spray resistance (500 hours)*    Good
  40-45 psi       * After one week air dry
Bare Substrates: Steel, Galvanized Steel*, Aluminum, or Fiberglass
•Note:  With the inconsistencies of galvanized steel, consult your local Acme Representative for system
        recommendations and substrate testing.
1.  Solvent clean with KLIX® Solvent Cleaner 88 or AQUA-KLIX™ Low VOC Surface Cleaner 87 and
    wipe dry with a clean, dry cloth.
2.  Apply 2-3 medium coats of ETCH-LOG® Etching Filler 562 or 565f or one double coat of Vinyl
    Wash Primer 560.
Prepalnted  Substrates:
1.  Wash surfaces with a mild detergent in hot water. Rinse well and wipe dry with a dean, dry cloth.
2.  Solvent clean lacquer surfaces with KLIX-KRIL® Solvent Cleaner 6089. Solvent clean enamel
    surfaces with KLIX® Solvent Cleaner 88 or AQUA-KLIX™ Low VOC Surface Cleaner 87. Wipe
    dry with a clean, dry cloth.
3.  Grind repair area to remove paint and all rust as needed.  Fill as needed using an appropriate
    Acme body filler.  Albw body filler to tack up and shape as needed.
4.  Sand repair area and featheredge using 80,180, 280, and finish with 320 grit treated sandpaper
    on a random orbital sander.
5.  Apply 2-3 medium coats of ETCH-LOG® Etching Filler 562 or 565t to bare metal and body filler.
(For the above products refer to the appropriate product label or data page for complete information.)

1.  Stir or shake NE-Prime™ thoroughly before using.
2.  No reduction is required as NE-Prime™ 585 is packaged ready to spray. If additional reduction is
    required add up to 10% delonlzed water to achieve 35-45 seconds #2 Zahn.  Caution: Do
    not over reduce.
NOTE:  Store in full, air tight, lined containers to prevent rusting or mold growth.

1.  Adjust air pressure at the gun to 40-45 psi for siphon feed gun, 35-40 psi  for gravity feed gun,
    40-45 psi for pressure feed gun with 6-10 psi pot pressure or 8-9 psi for HVLP.
2.  Spray two or more medium wet  coats at  a gun distance of 8"-10" allowing each coat to
    become hand slick before the next coat. Use medium coats for filling instead of heavy, wet coats
    to minimize film shrinkage. Recommended dry film thickness is 2.0-2.5 mils.
3.  Clean spray gun with water or AQUA-KLIX™ 87 followed by lacquer thinner immediately after use.
NOTE: Do not use gun air to blow dry or cracking may occur.

1.  Allow NE-Prime™ to dry for a minimum of 30-45 minutes before sanding.  Cool temperatures or
    high film thickness will extend this time.
2   Finish sand with 320  grit or finer treated sandpaper.  Do not wet sand. Solvent clean with
    KLIX-KRIL® Solvent Cleaner 6089, or follow with damp rag to ensure surface is free of sanding
    residue.
3.  NE-Prime™ may be directly recoated after sanding with HYDRO-LOX™ Primer-Sealer 580/583t
    or any Acme topcoat.
tNew Product — To be announced

-------
                           PRODUCT  AT-A-GLANCE
 PRODUCT
  NE-Prime™ Water  Borne  Primer-Surfacer
                                         Gray  585
 USE               • A fast dry, water borne primer-surfacer with a VOC as applied of 1.1 Ibs/gal.
                    • Sands easily with no clogging of the sandpaper.
                    • Featheredges easily and fills 80-180 grit scratches.
 SUITABLE
 SUBSTRATES
> Steel
• Aluminum
• Fiberglass
• OEM lacquers
• OEM enamels
• Refinish lacquers
> Refinish enamels
• ETCH-LOC® Etching Filler
> Vinyl Wash Primer
 SURFACE
 PREPARATION
 MIXING
• Wash surfaces with a mild detergent in hot water. Rinse well and wipe dry with clean cloth.
• Solvent clean with an Acme solvent cleaner, and wipe dry with a clean cloth.
• Grind repair area to remove paint and all rust as needed.
• Apply an Acme body filler to clean bare metal as needed.
• Sand all areas to be refinished and featheredge all broken film areas.
• Treat bare metal with an appropriate Acme etching primer.


  None required —  use at package consistency*

* An  additional 10% of deionized  water may be added to adjust  viscosity to
  35-45 seconds #2 Zahn.  Caution: Over-reduction will dramatically lower viscosity and
  sacrifice application properties.
 APPLICATION
      Siphon  feed
  Apply 2 or more medium wet coats
                 Gravity feed
          Apply 2 or more medium wet coats
                       40-45 psi
                       (use 8-9 psi for HVLP)
        Time  to  Sand
          30-45 minutes
           (minimum)
            ©TOT
                                 35-40
 RECOAT
• HYDRO-LOX™ Primer-Sealerf
• LOX-SEAL™ Acrylic Sealer
• LOXON II® Urethane Sealer
• ProBase 10® Acrylic Urethane BC/CC
• ProSingle™ Acrylic Urethane
• PRO-KRIL® Acrylic Lacquer
• PRO-KRIL® Acrylic Lacquer BC/CC
                • HYDRO-LOX™ Primer-Sealert
                • KWIK-SLIK® Primer-Sealer
                • Acme Acrylic Enamel
                • ACME 100® Polyurethane Enamel
                • MIRALON® Acrylic Urethane
                • MIRALON® Acrylic Urethane BC/CC
                • FLEET-X® Enamel
 NOTES            • Clean equipment immediately with water or AQUA-KLIX™ 87 followed by lacquer thinner.
                    • Finish sand with 320 or finer grit treated sandpaper.
                    • Do not blow dry with gun air or cracking may occur.
                    • Remove sanding residue with KLIX-KRIL® 6089 or a damp rag before reooating.
                    • Recommended dry film thickness is 2.0-2.5 mils after sanding.
PAINT-SAFE™
  Read all label directions before use.
  Refer to MSDS for specific information.
  Wear a NIOSH approved organic vapor
  respirator PS-90000 or PS-90002 when
  mixing and applying.
                   Wear a NIOSH approved dust paniculate
                   mask PS-90015 when sanding.
                   Wear safety goggles PS-90017. coveralls
                   PS-90026, and latex gloves PS-90022
                   when using product.
fNew Product — To be announced
©1990 ACME Automotive Finishes
Cleveland, OH 44115
                                                               OOOA1496. 5/90

-------
Automotive Finishes
 PRODUCT  DESCRIPTION
                                  ProBase  10®
High Solids, Air Dry  Clearcoat 791
       Low  VOC (4.4  Pounds/Gallon)
 ProBase 10® High Solids, Air Dry Clearcoat 791 is a urethane Clearcoat designed for use in the open shop or in
 a spray booth. The fast dry times and excellent buffability make it ideal for all shop conditions.  Because 791 has
 higher solids, only two coats are required for 2.0 mils dry coverage. 791 delivers excellent gloss and DOI and if
 required, is easily polished to remove dirt or texture. 791 is low in VOC at only 4.4 pounds/spravable gallon
 TECHNICAL  DATA
 ProBase 10® High Solids, Air Dry Clearcoat 791
  Weight Solids @ the gun           44.6%
  Volume Solids @ the gun           37.8%
  VOC (sprayable)               4.4 Ibs/gal
  Mixing ratio by volume               3:1:1
  Clearcoat : Reducer: Hardener
  Viscosity (sprayable)  #4 Ford    13-15 sec.
                     #2Zahn   16-18 sec.
        • Air pressure @ gun
          Siphon feed                      50 psi
          HVLP/LVLP                    8-10 psi
        • Recommended Dry Film Thickness 2.0 - 2.5 mils
        > Gloss
          @  60°                      86 minimum
          @  20°                      82 minimum
        1 DOI                           80 minimum
 MIXING
 ProBase 10® High Solids, Air Dry Clearcoat 791
 • Clearcoat Reducer:  (Choose the Clearcoat Reducer that best fits the repair size and shop temperature.)
   Size  of repair         792/6792 Fast     794/6794 Medium      796/6796 Slow        797 Very Stow
   Small spot  repairs       50-85eF
   1- or 2-panel repair      50-70°F
   Multi-panel  repair       50-70°F
   Complete refinishing    50-60°F
   794/6794 Medium
     above 85°F
      70-90°F
      70 - 80°F
      60-70°F
796/6796 Slow

 above 90°F
  80-90°F
  70 - 85°F
above 90eF
above 85°F
    Mixing Clearcoat: Mix 3 parts Clearcoat 791 to 1 part Reducer, stir, then add 1 part Clearcoat Hardener
    798.
    Mixing Flexibilized Clearcoat: Mix 3 parts Clearcoat 791 to 1 part Clearcoat Reducer, stir, then add 1
    part Clearcoat Hardener 798 and 1 part MULTI-FLEX™ Flexible Additive 68
    Pot life of Clearcoat:  2 hours with or without MULTI-FLEX™	
 APPLICATION
 ProBase 10® High Solids,  Air Dry  Clearcoat 791:
 1.  Adjust air pressure at the gun to 50 psi for siphon feed or pressure feed (adjust pot pressure 5 to 10 psi).
     Use 8-10 psi for HVLP/LVLP with 5-6 psi at the cup.
 2.  Apply only 2 wet coats at a gun distance of 8-10 inches allowing each coat to become hand slick before
     applying the next coat. Apply second coat of Clearcoat within 45 minutes of the first to prevent possible
     recoat lift.
 3.  If extra flow is required, add up to 1 ounce of Universal Urethane Retarder 271 per sprayable quart.
 4.  To blend  Clearcoat edge, use  only 794/6794  Medium  Reducer using  25  psi  at  the  gun.
     IMPORTANT: Clean spray gun immediately after use with Gun and Equipment Cleaner 1301.	
DRYING SCHEDULE
Dry times are based on the recommended dry film thickness of 1.0-1.5 mils for basecoat color and 2.0-2.5 mils
for Clearcoat, thicker films will extend drying times.
• Air dry times:
j




• Force dry



• If buffing of
checking <
2. Buff by m
ultimate in


Dust free
To buff
To deliver
times:
Hf^F
120°F
2 hours after cool down
ProBase 10® Clearcoat 7£
requently with a rubber sqi
achine with polishing pad
70"F
792/6792
25 min.
8 hours
16 hours
792/6792
45 min.
30 min.
, 791 can
)1 Is need
791 Clearcoat
80°F
794/6794
30 min.
8 hours
16 hours
794/6794
45 min.
30 min.
be buffed.

90°F
796/6796
40 min.
8 hours
16 hours
796/6796/797
45 min.
30 min.

ed bv cross-sanding
lOO/T
zsz
40 min.
8 hours
16 hours




with 1500 grit
leegee to ensure Thafthe 1200 scratches are being removed.
using a quality microfinishing compound, follow with a microfmisning
appearance, hand glaze wflh a sofl
clean cloth.











sandpaper
glaze. For


-------
                             PRODUCT   AT-A-GLANCE
                     Basecoat  with  ProBase 10®  HS, Air  Dry Clearcoat 791
 •  ** ** •* » ^* '         »^»»^» ^^^^^^^»» •  »-»—--  ~^^^ ^•••^^^^^^^^,^^^^^_^
 USE               • An easy-to-apply, high-gloss Acrylic Urethane System with excellent durability.
                     • Matches OEM basecoat/clearcoat colors.
                     • Uses unique Basecoat Stabilizers (Fast 780 & Standard 782) that control color blending.
                     • Basecoat can be recoated in as little as 10 mins. when using 780 and 20 mins. with 782.
 SUITABLE
 SUBSTRATES
   OEM enamels           •  High-Build Epoxy Primer
   OEM lacquers           •  ETCH-LOC® Etching Filler
   Aged refinishes         •  HS KWIK-SLIK® Primer-Sealer
                           Hydro-LOX™ Primer
             LOXON II® Primer-Suriacer
             LOXON II® Sealer
             HS LOXON II® Sealer
 SURFACE
 PREPARATION
  Wash surfaces with a mild detergent in hot water.  Rinse well and wipe dry with clean cloth.
  Solvent clean with Acme solvent cleaner, and wipe dry with a clean cloth.
  Sand all repair areas to be refinished and featheredge broken film areas.  Finish with 320 grit.
  Treat bare metal areas with ETCH-LOG® Etching Filler.
  Surface with Hydro-LOX® Primer-Surfacer.
 MIXING
                 Basecoat
          Stir or shake color thoroughly
                               Basecoat
                                 Color
                      Use 760V or 782V for VOC regulated areas.
      High Solids, Air Dry Clearcoat
                  791
                                                                                       J
                                                               t
                                                            792/6792
                                                            794/6794
                                                            796/6796
                                                              797
 APPLICATION
                Basecoat
            Apply 2-3 medium coats.
           Allow each coat to flash until
           hand slick before next coat.
               Clearcoat
             Apply 2 wet coats.
         Allow each coat to flash until
         hand slick before next coal
                           45 psit      Pot life:  unlimited
                      Not»:  (/«• • 25 pal low praaaura mitt
                      coal to avan out metallic/mica colon  is  a
                      final coat altar hiding haa been achieved.

                      tUse 8-10 psi for HVLP/LVLP
                                           S0psifor791t
                  Pot life: 2 hours with or
                  without 68
RECOAT
PAINT-SAFE®

  (K)
  Recoat Basecoat color with 791.
  Recoat basecoat colors before 7 days or remove basecoat color.
NOTES            • Basecoat will appear flat when dry.
                     • Do not use fisheye killers in basecoat color as it will adversely affect the adhesion of the Clearcoat.
                     • If fisheyes are a problem in Clearcoat. add up to 1/2 ounce of URE-A-BAN Silicone Additive 71 per
                       sprayable quart of Clearcoat.
                     • Do not scuff, sand (wet or dry), or solvent clean basecoat colors.  (Small areas may be wet sanded
                       to remove dirt.)
                     ' Add up to 1 ounce of Universal Urethane Retarder 271 to improve flow or to prevent dry edges.
  Read all label directions before use.
• Refer to MSDS for specific information.
• Wear an air purifying respirator PS-90000/02
  when mixing and applying.
Wear a NIOSH approved dust paniculate mask
PS-90p15 when sanding.
Wear safety goggles PS-90017, coveralls
PS-90024/26, gloves PS-90022, shoe covers
PS-90028 and air supplied respirator
PS-90006/90012 when using product.	.
C1992 Acme Automovie Finishes
 Cleveland, OH 44115
                                                                           4/92
                                                                         A1SS8

-------
              i  i
Automotive Finishes
PRODUCT
DESCRIPTION
                              Uifiii,

                                 MIRALON   3.5

                  Low   VOC Acrylic   Urethane
»,«~ «, , ' .?'5iow VOC Acrylic Urethane « a high performance acrylic urethane that has a maximum
VOC (Volatile Organic Compounds) content of 3.5 pounds/gallon sprayable (420 grams/liter).
MIRALON® Low VOC is available as an intermix system with a wide color selection.
When MIRALON® 3.5 Low VOC is used with Hydro-LOX™ Waterborne Primer 580. Fleet and Original
Equipment Manufacturers have a VOC "system* to comply with regulations limiting coatings to a
maximum VOC of 3.5 pounds/gallon (420 grams/liter) of sprayable material.  Refer to your local, state.
or federal regulatory agendes for further details.
TECHNICAL
DATA
SURFACE
PREPARATION
MIXING
> Mixing ratio by volume
> VOC (maximum sprayable)
                                   3:1
                             3.5 Ibs/gal
                              420 g/liter
> Viscosity (sprayable)
 #4 Ford Cup                  20-25 sec.
 #2 Zahn Cup                  23-26 sec.
> Flash point (average) - Tag Open Cup     80°F
> Coverage @ 1 mil dry (white)   919 sq. fUgallon
> Recommended dry film thickness   2.0-2.5 mils
   (2 coats)
• Gloss   60°                         90
        20"                         80
> DOI (Average)                        80
> Pencil Hardness at 1 week dry         HB - H
> Dielectric strength        1800 volts/mil (dry)
   over steel (white)
Performance after one week air dry
- Impact resistance (80 in/lbs)
   direct                         Pass
   indirect                        Pass
• Flexibility (1/8* conical mandrel)        Pass
- Solvent resistance
   (MEK/Toluene/Gasoline/Oil)     No effect
-Chemical resistance (24 hr. contact)
   10% Hydrochloric acid          No effect
   10%Sulfuric acid             No effect
   10% Ammonium hydroxide       No effect
- Salt spray resistance -250 hrs       No effect
-Humidity resistance-100hrs       No effect
- QUV, accelerated weathering -      Excellent
   1,000 hrs(92% retention for white)
Bare Substrates: Steel, Galvanized Steel*, Aluminum, or Fiberglass
'Note: With the inconsistencies of galvanized steel, consult your local ACME Representative for
   system recommendations and substrate testing.
1.  Solvent clean with KLIX® Solvent Cleaner 88 or AQUA-KLIX™ Low VOC Surface Cleaner 87 and
   wipe dry with a dean, dry cloth.
2.  Treat bare steel areas with FERRO-PREP™ Steel Cleaner 2414 followed by CHEM-GRIP®
   Phosphate Conversion Coating 2415. Treat bare aluminum with Acme Metal Cleaner and Conditioner
   285. Or apply 2-3 medium coats o< ETCH-LOC® Etching Filler 562/565 or one double coat of Vinyl
   Etching Primer 560.
3  Follow with High Build Epoxy Primer 131/132, Hydro-LOX™ Waterborne Primer 580, LOXON II®
   Sealer 156/159, or KWIK-SLIK® Primer-Sealer 129/134/135.
Prepalnted  Substrates:
1.  Wash surfaces with a mild detergent in hot water. Rinse well and wipe dry with a dean cloth.
2.  Solvent clean lacquer surfaces with KLIX-KRIL® Solvent Cleaner 6089.  Solvent clean enamel
   surfaces with KLIX® Solvent Cleaner 88 or AQUA-KLIX™ Low VOC Surface Cleaner 87. Wipe dry
   with clean cloth.
3.  Grind off paint and remove all rust. Fill as needed using a ACME body filler. Allow body filler to tack
   up and shape as needed. Body filler must be cured before priming.
4.  Sand repair area and featheredge using 80, 180, 280, and finally 320 grit treated sandpaper on a
   random orbital sander.
5.  Apply 2-3 medium coats of ETCH-LOC® Etching Filler 562/565 to bare metal and featheredge area.
   Check local regulations to verify etching primers are VOC exempt.
6.  Follow with Hydro-LOX™ Waterborne Primer 580.
(For the above products refer to the appropriate product data page for complete information.)


1.  Stir or shake MIRALON® 3.5 Low VOC thoroughly before mixing.
2  Mix 3 parts MIRALON® 3.5 Low VOC Color with 1 part MIRALON® Low VOC Hardener 723. See
   your Acme representative about further reduction of MIRALON® Low VOC Color for specific
   applications.  Pot life: 2-3 hours @ 70°F.
3  Stir thoroughly and strain before use.
NOTE-If fisheyes are a problem, add up to 1/2 oz. of URE-A-BAN® Silicone Additive  71 to 1 quart of
     ' ready-to-spray MIRALON® Low VOC Color.
      Avoid use of MIRALON® Accelerator in MIRALON® Low VOC Color, it will significantly shorten
      pot life (as short as 1/2 hour @ 70'f).

-------
 APPLICATION   1 • For proper results use only the following equipment recommendations.  Conventional siphon lead
                       equipment may not yield proper appearance. Check equipment by applying MIRALON® 3.5 Low
                       VOC to a test panel before using.

                    •  Pressure Feed: Apply one medium crosscoat for nori-metallics. Metallic colors require two
                       medium coats with a 3-5 minute flash-off between coats, followed immediately by a light crosscoat to
                       even out metallic mottling.
DRYING
SCHEDULE
NOTES
                                Gun:
                                Fluid Tip:
                                Air Cap:
                        JGA502
                        FForFX
                        797
            Fluid Delivery:
            Atomizing air psi:
            Gun Distance:
              19-22 ounces/minute
              65-75 psi @ gun
              10-12 inches
                       Electrostatic:  Apply one  medium coat followed by a  second medium coat perpendicular to
                       direction of first coat.  The second coat may be applied immediately after the first coat.
                            Sinks Model 85B
                                                        Kremlin KMP Conventional
                                                                    Nordsen AN8 Conventional
                    Fluid Tip:
                    Needle:
                    Air Cap:
                    Atomizing air psi:
                    Fluid Delivery:
                    Kilo volts
                    Gun Distance:
                63B
                63AE
                PW
                35-45 psi® gun
                6 oz/min.
                60 KV
                10-12 inches
PluldTip:
Air Cap:
Atomizing air psi:
Fluid Pressure:
Kilovolts
Gun Distance:
#15 (.OSS')
33
65-75 psi @ gun
25-30 psi
75 KV
10-12 inches
Fluid Tip:
Air Cap:
Atomizing air psi:
Fluid Delivery:
Kilovolts
Gun Distance:
0.060"
987
65-75 psi @ gun
12-16 ozJmm.
60-75 KV
10-12 inches
2. Normally two coats of MIRALON® 3.5 Low VOC Acrylic Urethane are sufficient for complete hiding.
   If a third coat is required for hiding, allow second coat to flash 20-30 minutes, or until hand slick.
   Apply third coat wetter than the second coat.

Dry times are based on the recommended dry film thickness of 2.0 mils; thicker films will extend drying
times.

•  Air dry times (Using 722* MIRALON® Low VOC Mixing Clear only) @ 75°F and 50% R.H.:

                          - Dust free       40-60 min.
                          - Tack free       3-4 hours
                          - Tape free       4-6 hrs.
•Note:  Light cotors of MIRALON® 3.5 Low VOC using 722  Mixing Clear may be force dried at a
         maximum temperatures of 120°F.
         Dark colors of MIRALON® 3.5 Low VOC using 722 Mixing Clear may be force dried at a
         maximum temperature of 100°F.  Higher temperatures may cause hazing.

•  Force dry times (Using 724 MIRALON® Low VOC Mixing Clear only):
Note: See your heal ACME Representative for availability of 724.

                        Temperature          Tape free
                   Do not use below 140°F        —
                           140°F            1.5-2.5 hours
                           160CF             60 minutes
                           180°F             30 minutes
Note: After force drying, allow vehicle to cool down 10-15 minutes before removing from booth.

1. Recoating of MIRALON® 3.5 Low VOC Acrylic Urethane may take place at any time without a recoat
   lift problem. If film is allowed to dry for more than 48 hours, scuff sand with 320 grit or finer treated
   sandpaper before recoating.
2. Decals may be applied after 72 hours and before one week air drying at 75°F. Lower temperatures,
   heavy film thickness, poor air movement, thick decals, foil-based decals, etc., will extend the 72
   hour dry time before decal may be applied.  After one week, scuff sand for proper decal adhesion.
   Refer to your local ACME Representative for recommendations.
3. If force dry  equipment cannot achieve 140eF do not use 724.  Use 722, following the above air dry
   recommendations.

-------
                           PRODUCT   AT-A-GLANCE
PRODUCT       MIRALON®  3.5 Low  V6C Acrylic  Urethane
USE
SUITABLE
SUBSTRATES
• Complies with VOC regulations for a maximum VOC content of 3.5 Ibs^gallon (sprayable).
> A high performance, extremely durable, high-gloss acrylic urethane.
• Withstands harsh industrial environments and chemicals.
• Ideal as an OEM finish and refinish coating for fleets, trucks, and special vehicles.
• Hydro-LOX™ Waterborne Primer *
• ETCH-LOC® Etching Fillerf
• High Build Epoxy Primerf

•VOC Compliant @ 2.0 Ibs/gal. (240 grams/liter)
LOXON II® Primer-Surfacerf
LOXONII® Sealerf
KWIK-SLIK®f

        f Consult local regulations for VOC requirements
SURFACE      'Wasn surfaces with a mild detergent in hot water. Rinse well and wipe dry with clean cloth.
PREPARATION *Solvent clean witn f Acme solvent cleaner, and wipe dry with a clean cloth.
                   • Treat bare metal with a Acme conditioner or etching primer. Check local regulations to verify
                     etching primers are VOC exempt.
                   • Prime with High Build Epoxy Primer 131/132. Hydro-LOX™ Waterborne Primer 580, LOXON It®
                     Sealer 156/159, or KWIK-SLIK® Primer-Sealer 129/134/135.
MIXING
1 Stir or shake MIRALON® Low VOC Color thoroughly before mixing.
> Mix by volume 3 parts of MIRALON® Low VOC Color with 1 part 723 Hardener.
                                                     1
                                                    723
                   • Pot life: 2-3 hours
APPLICATION
RECOAT
NOTES
PAINT  SAFE®
          Pressure  feed*
  Apply 1 medium coat for solid colors, 2
  medium coats for metallic colors with a
           3-5 minute flash.
                      Electrostatic*
                    Apply 2 medium coats.
                   Flash off is not necessary.
                          Air pressure:
                          65 - 75 psi
                    Fluid delivery:
                    19-22 oz./min.
                       Binks Model 85B
                   Kremlin KMP Conventional
                   Nordson AN8 Conventional
*For complete equipment recommendation see APPLICATION on previous page.

• MIRALON® Low VOC can be recoated at any time.
• Decals may be applied after 72 hours and before 1 week. After 72 hours scuff sand for proper
  adhesion. Extend dry time in cool temperatures or if using large, thick, or foil backed decals.

• When MIRALON® Low VOC is to be force dried at 140 to 180eF use only 724 MIRALON® Low VOC
  Mixing Clear. Note: See your local ACME Representative for availability of 724.
• After force drying, allow vehicle to cool down 10-15 minutes before removing from booth.
• For air dry applications use 722 MIRALON® Low VOC Mixing Clear.
• If fisheyes are a problem, add up to 1/2 ounce of URE-A-BAN® Silicone Additive 71 per sprayable
  quart.
• Read all label directions before use.
• Refer to MSDS for specific information.
• Wear positive-air respirator PS-90006 or 90012
 when mixing and applying.
           • Wear a NIOSH approved dust paniculate
            mask PS-90015 when sanding.
           • Wear safety goggles'PS-90017. coveralls
            PS-90026, and latex gloves PS-90022 when
            using product.

-------
®1992  Acme Automotive Finishes                                                           A1329      Rev 3/92
c|eveland,OH 44115

-------
 Automotive Finishes
                                                                      Hydro-LOX™
                                        Low   VOC   Undercoat   System
                                                                  Base  Epoxy Primer  580
                                                           Primer-Sealer Activator   583
                                                        Primer-Surfacer Activator   584
PRODUCT
DESCRIPTION
 Hydro-LOX™ Undercoat System is composed of Hydro-LOX Base Epoxy Primer 580 that can be
 activated with Hydro-LOX Primer-Sealer Activator 583 to form Hydro-LOX Primer-Sealer or
 Hydro-LOX Primer-Surfacer Activator 584 to form Hydro-LOX Primer-Surfacer. Hydro-LOX is a two-
 component, water reducible, epoxy based undercoat system designed to provide excellent
 adhesion and corrosion protection without flash rusting, and with a VOC as applied of 2.0 Ibs/galton
 (maximum).
TECHNICAL
DATA
  Color   Light Gray    Base Epoxy Primer 580
         Med. Gray      Sealer Activator 583
         Dark Gray     Surfacer Activator 584
Flash points
Volume solids as applied
VOC as applied
Viscosity »2 Zahn
LeaoVchromate free
Coverage  1 mil dry
per sprayable gallon
Hydro-LOX
Primer-Surfacer
560/584
>230'F
37.1%
2.0 bs/gal.
31 sec.
Yes
GOO sq.ft.
Hydro-LOX
Primer-Sealer
580/583
>230-F
46.8%
2.0 t>s/gal.
32 sec.
Ves
750 K. tl.
                                                               Recommences dry
                                                               film thickness
                                                               Topcoat holdout
                                                               Humidity resistance* (96 hre)
                                                               Corrosion resistance*
                                                               (250 hrs.)
                                                               Impact resistance" • direct
                                                               Flexibility*
                                                               (1/4- conical mandrel)
                                                              Alter one week air dry
 Hydro-LOX
Primer-Surfacer
  5BQ/5B4
 2.0-2.5 mils

  Excellent
  Excellent
  Excellent

 160 in. t».

   Pass
 Hydro-LOX
Primer-Sealer
  SBO/SB3
 1.3-1.7 mik

 Excellent
 Excellent
 Excellent

 160 in. IDS.

  Pass
SURFACE
PREPARATION
Bare Substrates:  Steel, Galvanized Steel, Aluminum, or Fiberglass
Note:  With the inconsistencies of galvanized steel, consult your local Acme Representative for system
       recommendations and substrate testing.
1.  Solvent clean with KLIX® Solvent Cleaner 88 or AQUA-KLIX™ Low VOC Surface Cleaner 87 and
   wipe dry with a clean, dry cloth.
2.  Apply 2-3 medium coats of ETCH-LOC® Etching Filler 562 or 565*. or one double coat of Vinyl
   Wash Primer 560 for steel substrates.  For aluminum, remove oxidation by sanding with 280 grit
   on a random orbital sander. (Fiberglass does not require pro-treatment primer.)
   Note: Avoid using directly over shot/sand blasted steel without a pre-treatment primer.
Prepainted  Substrates:
1.  Wash surfaces with a mild detergent in hot water. Rinse well and wipe dry with a clean, dry cloth.
2.  Solvent clean lacquer surfaces with KLIX-KRIL® Solvent Cleaner 6089. Solvent clean enamel
   surfaces with KLIX Solvent Cleaner 88 or AQUA-KLIX Low VOC Surface Cleaner 87. Wipe dry
   with a clean, dry cloth.
3.  Grind repair area to remove paint and all rust as needed. Fill as needed using an appropriate
   Acme body filler. Allow body filler to tack up and shape as needed.
4.  Sand repair area and featheredge using 80,180, 280, and finish with 320 grit treated sandpaper
   on a random orbital sander.
5.  Apply 2-3 medium coats of ETCH-LOC® Etching Filler 562 or 565* to bare metal and body filler.
(For the above products refer to the appropriate product label or data page for complete
    information.).
                     New Product — to be announced.

-------
MIXING          1 • S('f Hydro-LOX thoroughly before using.

-------
                           PRODUCT  AT-A-GLANCE
PRODUCT   Hydro-LOX  Low VOC  Undercoat System
                                                      Base Epoxy  Primer  580
                                                 Primer-Sealer  Activator  583
                                               Prlmer-Surfacer  Activator  584
USE
• Low VOC water-borne primers with a VOC as applied of 2.0 Ibs/gal.
1 Sand Hydro-LOX Primer-Surfacer in 30 minutes at 75°F
• Recoat Hydro-LOX Primer-Sealer in 60 minutes at 140°F
SUITABLE
SUBSTRATES
• Steel
• Aluminum
• Fiberglass
• OEM lacquers
• OEM enamels
• Refinish lacquers
• Refinish enamels
• ETCH-LOC® Etching Filler
• Vinyl Wash Primer
SURFACE         -Wash surfaces with a mild detergent in hot water. Rinse well and wipe dry with clean cloth.
PREPARATION    • Solvent clean with an Acme solvent cleaner, and wipe dry with a clean cloth.
                    • Grind repair area to remove paint and all rust as needed.
                    • Apply an Acme body filler to clean bare metal as needed.
                    • Sand all areas to be refinished and featheredge all broken film areas.
                    • Treat bare metal with an appropriate Acme etching primer.

MIXING
                      An additional 10% of deionized water may be added Jor extra flow if needed. Caution: Over-
                      reduction will dramatically lower viscosity and sacrifice application properties.
APPLICATION
          Siphon  feed
    Apply 2 or more medium wet
      coats
       Time to Sand or Recoat
     Hydro-LOX  Primer-Surfacer — 30
     minutes to sand
                     40-45 psi for Hydro-LOX Primer-Surfacer
                        (8-9  psi for HVLP)
                     50-55 psi for Hydro-LOX Primer-Sealer
                        (9-10 psi for HVLP)
                                          Hydro-LOX Primer-Sealer — 60 minutes
                                          @ 140°F or 8 hours @ 70°F to recoat.
RECOAT
• ProBase 10® Acrylic Urethane BC/CC
• ProSingle™ Acrylic Urethane
• PRO-KRIL® Acrylic Lacquer
• PRO-KRIL® Acrylic Lacquer BC/CC
• Acme Acrylic Enamel
* ACME 100® Polyurethane Enamel
• MIRALON® Acrylic Urethane
• MIRALON® Acrylic Urethane BC/CC
• MIRALON® Low VOC
• FLEET-X® Enamel
NOTES            * Clean immediately with water followed by 1:1 alcohol and water solution, and finish with lacquer
                     thinner.
                    • Finish sand Hydro-LOX Primer-Surfacer with 320 or finer grit sandpaper.
                    • Remove sanding residue with KLIX-KRIL® 6089 or AQUA-KLIX™ 87 before recoating.
                    • Do not blow dry with gun air or cracking may occur.
                    • Recommended dry film thickness for primer-surfacer is 2.0-2.5 mils after sanding.
PAINT-SAFE™
  Read all label directions before use.
  Refer to MSDS for specific information.
  Wear a NIOSH approved organic vapor respirator
  PS-90000 or PS-90002 when mixing and
  applying.
      Wear a NIOSH approved dust paniculate"
      mask PS-90015 when sanding.
      Wear safety goggles PS-90017, coveralls
      PS-90026. and latex gloves PS-90022 when
      using product.

-------
TECHNICAL DATA
 ©1990 ACME Automotive Finishes
 Cleveland, OH 44115
A1505 5/90

-------

Automotive Finishes
                       u
s.tfAJI
                                                       CAL   DATA
                                                      AQUA-KLIX™
                                           Low VOC Surface Cleaner
                                                                          87
               AUQUA-KLIX™ Low VOC Surface Cleaner 87 is a water based emulsion
               that contains a surface active "detergent" and a special blend of solvents. It
               is  designed to  remove oil,  grease, wax, silicone, and other surface
               contaminants, as well as sanding  residue from bare metal  and plastic;
               OEM topcoats and primers; and refinish undercoats to prepare surface for
               painting.  When used on plastic substrates, AQUA-KLIX™ minimizes static
               build-up.
 TECHNICAL
 DATA
 SURFACE
 PREPARATION
 MIXING
 APPLICATION
 NOTES
• VOC-as packaged     1.40 IFS/gal (168 g/l)
     -as packaged     8.30 #"S/gal (996 g/l)
     less water & exempt
     compounds
• Mixing ratio  Use at package consistency
• Freeze hazard                  Yes
         1 Weight/gallon
         1 Solids by weight
         199°FTCC
1.  Wash surfaces to be painted and adjacent panels with a mild detergent
   and water solution to remove heavy deposits of dirt, oil, and grease.

None — use at package consistency.

1.  Saturate a clean cloth with AQUA-KLIX™ 87.
2.  Apply to  areas to be painted and adjacent panels.  Wipe surface
   thoroughly with AQUA-KLIX™ 87 and apply only to small areas at any
   one time.
3.  Wipe off with a second clean,  dry cloth before AQUA-KLIX™ 87 is
   allowed to dry. If drying occurs, repeat application.
Note:  In cooler temperatures and high humidity, step 3 may be needed to
   be repeated to remove AQUA-KLIX™ 87.  Or, after step 3, blow clean,
   dry air across the  surface to enhance the evaporation of AQUA-KLIX™
   87.
               1.
               2.

               3.

               4.
   On lacquer surfaces, avoid prolonged contact with AQUA-KLIX™ 87 or
   softening will occur. If this occurs, allow surface to dry thoroughly
   before next step.  (A light sanding may be needed if AQUA-KLIX™ 87
   has swelled the lacquer surface.)
   Best  results are obtained when temperatures are  maintained above
   70°F when using AQUA-KLIX™ 87.
   Avoid prolonged contact with bare metal and dry thoroughly to prevent
   flash rusting.                         .         u-    -        ..
   Protect  AQUA-KLIX™ 87  from freezing.   If this occurs, allow
   AQUA-KLIX™ 87 to warm slowly to room temperature before use.
   1992 Acme Automotive Finishes
   Cleveland, OH 44115
                                                                  A1473 Rev. 4/92

-------
    APPENDIX G




VENDOR INFORMATION

-------
                                         Appendix G
                                 Equipment Supplier Information
Disclaimer:  Mention of trade names or commercial products does not constitute endorsement  or
recommendation for use.
HVLP Paint Application Systems

Sinks Manufacturing Company
1 Chapin Rd.
Pine Brook, NJ  07058-9719
201-575-6660

Graco, Inc.
P.O. Box 1441
Minneapolis, MN 55440-1441
sales: 1-800-367-4023
technical assistance:
800-543-0339

Accuspray
26881 Cannon Road
P.O. Box 391525
Cleveland, OH 44139
800-321-5992

Low VOC, High  Solids Paints

Acme Automotive Finishes
101 Prospect Ave
Cleveland, OH 44115
216-566-3031

Gun Washer System

Graco, Inc.
P.O. Box 1441
Minneapolis, MN 55440-1441
sales: 1-800-367-4023
technical assistance:  800-543-0339

Aqueous Cleaners and Parts Washing Equipment*

Gary Hartline, General Sales Manager
OCS Manufacturing, Inc.
P.O. Box 370
429 Madera St.
San  Gabriel, CA 91778-0370
818-458-2471
C & H Chemical
222 Starkey St
St. Paul, Minn. 55107
612-227-4343

Mirachem
2113 East Fifth St
Tempe, AZ  85281-3034
602-966-3030

Weer-Flo*
15151 Technology Dr.
Eden Prairie, MN 55344
800-328-7942

* supplier of aqueous parts washing equipment

Solvent Recycling Unit

Finish Thompson Inc.
921 Greengarden Rd.
Erie, PA 16501-1591
814-455-4478

Binks Manufacturing Company
1 Chapin Rd.
Pine Brook, NJ  07058-9719
201-575-6660

PBR Industries
400 Farmingdale Rd.
West Babylon, NY  11704
516-422-0057

Fluids Testing Equipment

Northern Instruments Corp.
6680 N. Highway 49
Lino Lakes, MN 55014
612-784-1250

-------
Antifreeze

(Recycling)
Glyclean
Distributor:
FPPF Chemical Co., Inc.
117W.TupperSt.
Buffalo, NY  14201
800-735-3773

Kleer-Flo
15151 Technology Dr.
Eden Prairie, MN 55344
800-328-7942

(Distillation)
Finish Thompson Inc.
921 Greengarden Rd.
Erie, PA 16501-1591
814-455-4478

Wash Water Recycling System

Landa Inc.
13705 NE Airport Way
Portland, OR 97230
503-255-5980

Hotsy on the Hudson
145 Palisade St.
Dobbs Ferry, NY 10522
914-693-3997

-------
           APPENDIX H




ANALYSIS OF ALTERNATIVE COATINGS

-------
                                          Appendix H

                                 Analysis of Alternative Coatings


Additional information necessary for an in-depth analysis of switching to an alternative coating system is
provided below.                                                                           -

Calculating Coating Usage, Solid Waste and VOC Emissions from Coating Operation

Coating Usage:  assuming that the volume of coating solids must remain constant to maintain a certain
production level, coating usage can be calculated as follows:1

        CU =  SA/  PSxTE

where:  SA = coating solids applied
        PS = percent solids by volume at the gun
        TE = transfer efficiency of gun

assumes coating formulation of 32 percent solids, 5.0 Ibs of VOC released per gallons of coating.

Solid Waste: solid waste associated with the coating operation

        SW =  5.5 (CU) (PS) (1 - TE)

where:  CU = coating usage
        PS = percent solids by volume at gun
        TE = transfer efficiency

VOC Emissions:   VOCs emitted as a result of the coating operation; the amount of VOC emitted depends
                  on coating usage and percent VOC in the coating.

-------
                 APPENDIX 1



ONSITE DISTILLATION RECYCLING UNIT INFORMATION

-------
Waste Minimization Program
factsheet
                                          On-Site   Solvent
                                           Recovery   Stills
   Background on the Distillation

   Stills are equipment used in the distillation of chemical mixtures. Distillation is a separation process
   that requires that the components of a mixture possess unique boiling points. The two basic steps of
   distillation are vaporization and condensation.

   Vaporization involves heating the mixture to the boiling point of the solvent desired until the liquid
   becomes a gas. By controlling the temperature of vaporization it is possible to selectively recover one
   or more solvents from a mixture. For solvents that have a high  boiling point, the solvents are
   distilled at reduced pressures (sometimes near vacuum) to lower the temperature needed to boil the
   solvent. This process, vacuum distillation, requires additional equipment.

   During condensation, the vapor, known as the overhead product, is passed through a cooling system
   called a condenser where the vapor is condensed to a liquid product. The remaining material in the
   still, referred to as the still bottoms, must be disposed of as hazardous waste.

   Applications of Solvent Recovery St'^S

   Small quantity generators of solvent waste frequently use batch processing in 'kettle* type stills to
   recover their solvent waste. Batch process distillation involves feeding the waste to the still in a
   batch. No additional solvent waste  can be added to the system until the original batch is completed.

   Batch stills are frequently used for solvent recovery in the following settings:
                Autobody Repair:
                Automotive Repair:
                Dry cleaners:
to recover paint thinner
to recover parts cleaners
to recover drycleaning solvent
   Large quantity generators of solvent waste use continuous distillation systems as opposed to batch
   systems. Continuous systems are those which continuously are fed waste solvent and likewise
   continuously produce the recovered solvent. Continuous stills are able to recover large amounts of
   solvent faster than batch stills. However, continuous stills require that large amounts of solvent waste
   be fed to it in order to be cost effective.

   Continuous stills are frequently used in solvent recovery in these settings:
              • Chemical Manufacturing:
              - Paint Stripping:
              - Parts Degreasing:
to recover solvent by-products
to recover dirty paint strippers
to recover degreasing solvents
  Wisconsin Department of Natural Resources •  Hazardous Waste Minimization Program

-------
                       Purchasing Guidelines  for

                   On-Site Solvent Recovery  Stills


            THE FOLLOWING LIST OF EQUIPMENT PURCHASING CONSIDERATIONS WAS
            DEVELOPED BY THE WISCONSIN DEPARTMENT OF NATURAL RESOURCES TO
            HELP WISCONSIN BUSINESSES IDENTIFY AND EVALUATE CURRENT
            HAZARDOUS WASTE MINIMIZATION OPPORTUNITIES. ALTHOUGH IT IS NOT
            POSSIBLE TO COVER EVERY ASPECT OF EQUIPMENT SELECTION, THE LIST
            COVERS SOME OF THE MORE IMPORTANT POINTS AND PROVIDES
            CONSIDERATIONS FOR EVALUATING SOLVENT RECOVERY STILLS.
Is a still a feasible method for your company to recycle its solvent waste?

       1)     Is the solvent to be reclaimed a pure solvent or a solvent blend? [A blended solvent
              frequently yields a distillation product that differs in composition from the solvent fed
              to the still]

       2)     Are there components found in the distilled solvent that will make it unsuitable for
              use in its original capacity?

       3)     If the distilled product is not suitable for its original use, is there another use for the
              solvent in your facility?

       4)     Will  it be possible to implement a waste segregation policy in your facility?
              [Preventing the mixing of waste solvents is essential in developing an effective solvent
              recovery program,]

       5)     Does the solvent that you use contain Nitrocellulose? [Nitrocellulose is found in some
              inks and lacquers;it is explosive when it is dried,and should not be distilled!]
What type of still is best for you?

       1)     Is the capacity of the distillation unit adequate for your needs?

       2)     Is the boiling point of your solvent within the designed temperature range for the still
              or will you need to distill at reduced pressure?

       3)     Does the still operate on a batch or a continuous basis?

       4)     Will the waste solvent need to be treated to remove solids before it is fed to the still?
              [A high solids content may foul some types of equipment.]

       5)     Will the materials used in the construction of the still [e.g. stainless steel, teflon, etc.]
              resist deterioration from the solvent the still will process?

       6)     Are the still bottoms to be removed automatically or manually?
                                            -2-

-------
 What type of still is best for you? (continued)

        7)      Is the still heated by an electric element, hot oil, or steam?  [The best method of
                healing should be evaluated with respect to both safety and cost effectiveness.]

        8)      Is the solvent vapor cooled and condensed by chemical coolant, water, or forced air?
                [Some solvent vapors are cooled more efficiently by water and coolant as opposed to
                air.}

        9)      Will fractioning columns be necessary to separate components of the condensing
                vapor? [Fractioning columns help to separate components that have relatively dose
                baiting points.]

 Other considerations

        1)      Will the manufacturer demonstrate the efficiency of the still by distilling a sample of
                your waste?

        2)      Are the safety features of the still sufficient for the work environment at your
                facility?

                      Are the electrical switches and controls explosion proof?

                      Can the unit be secured to prevent it from being opened until it has cooled to
                      a safe temperature?

                      Is the unit designed to shut down safely if the maximum operating
                      temperature or pressure is exceeded?

                      Will the unit shut down safely if there is a failure in the water  or electrical
                      utility supply?

        3)     What is the anticipated volume of still bottoms that you expect to generate and what
               are the associated costs of disposal?  [Still bottoms are considered a hazardous
               waste.]

       4)     Will the still require a modification of the ventilation system at your facility? [Solvent
               recovery  hoods may be installed to collect fugitive emissions.]

       5)     Will the operation of the still affect your compliance with local, state, or federal
               environmental or health and safety regulations?

       6)     What are the energy requirements for the still?  Is it energy efficient?


Some of the purchasing guidelines have been adapted from a Minnesota  Technical Assistance
Program (MnTAP)fcct sheet on On-Site Solvent Recovery Stills. The DNR would like to thank
MnTAPfor its contribution.
                                               -3-

-------
                 On-Site  Solvent Recovery Stills
                Manufacturer and  Supplier List
August 1991
      THE WISCONSIN DEPARTMENT OF NATURAL RESOURCES (DNR), THROUGH THE
      WISCONSIN HAZARDOUS WASTE MINIMIZATION TECHNICAL ASSISTANCE PROGRAM,
      DEVELOPED THE FOLLOWING LIST OF MANUFACTURERS AND SUPPLIERS OF SOLVENT
      DISTILLATION EQUIPMENT. THE LIST SHOULD NOT BE CONSIDERED TO BE COMPLETE
      IN ITS LISTING OF MANUFACTURERS OR SUPPLIERS. THIS LIST IS NOT AN
      ENDORSEMENT OF ANY OF THE SPECIFIC MANUFACTURERS OR SUPPLIERS.
      HAZARDOUS WASTE GENERATORS ARE ADVISED TO THOROUGHLY EVALUATE THE
      SERVICES AND COMPLIANCE STATUS OF ANY COMPANY THAT THEY USE TO MANAGE
      THEIR HAZARDOUS WASTE. THE LIST WILL BE PERIODICALLY UPDATED. IF YOU
      HAVE  ANY ADDITIONS OR CORRECTIONS FOR THIS LIST, PLEASE CONTACT THE
      HAZARDOUS WASTE MINIMIZATION TECHNICAL ASSISTANCE PROGRAM AT
      (608) 267-3763.
      Manufacturer

      Acra Electric Corp.
      3801 N. 25th Avenue
      Schiller Park, II 60176
      Phone:  (708)678-8870
      Fax: (708)678-8889

      Artisan Products
      73 Pond Street
      Waltham,  MA 02254
      Phone:  (617) 893-6800
      Fax: (617)647-0143

      Baron-BIakesIee/Allied Signal
      2001 N. Janice Avenue
      Melrose Park, IL 60160
      Phone:  (708)450-3900
      Fax: (708)450-3884
      Atm: Bob Block

      B/R Instrument Corp.
      P.O. Box  7
      Pasadena,  MD 21121
      Phone: (612) 452-5695
            (800) 922-9206

      Branson Ultrasonic
      41 Egale Road
      Danbury,  CT 06813
      Phone:  (203)796-0400
Distributor/Sales Rep.

C&H Supply
400 S. 5th Street
Milwaukee, WI
White Cleaning Equipment
P.O. Box 1073
Waukesha, WI 53187
Phone:  (414)521-3152
Ann: DavePagor

Bob Block
Phone:  (708)450-3900
Ann Cole
12861 Hamlet Ave.
Apple Valley, MN 55124
Phone: (612)
 Schuette Ind. Sales
 P.O. Box 943
 Waukesha, WI 53187
 Attn:  Tom Riddle
 Phone: (414)549-0050

-------
 Manufacturer
Distributor/Sales Rep.
 Brighton Corporation
 11861 Mosteller Road
 Cincinnati, OH  45241
 Phone:  (513)771-2300
 Fax:  (513)772-2404
 Ann: Ken Lutz

 Crest Ultrasonics Corp.
 Scotch Road, Mercer County Airport
 Trenton, NJ  08628
 Phone:  (609)883-4000
 Fax:  (609) 883-6452

 DCI International
 1229 Country Club Road
 Indianapolis, IN 46234
 Phone:  (317)271-4001
 Fax:  (317)271-1044

 Detrex Corporation
 P.O. Box 5111
 Southfield, MI 48086
 Phone:  (313)358-5800
 Fax:  (313)358-5803

 Finish Engineering Co.
 921 Greengarden Road
 Erie, PA 16501-1591
 Phone:  (814)455-4478
Gardner Machinery Co.
P.O. Box 33818
Charlotte, NC  38233
Phone:  (704)372-3890
Fax:  (704)342-0758
Ann:  Pat Russell

Giant Distillation and Recovery
900 N. Westwood Avenue
Toledo,  OH  43606
Phone:  (414)531-4600

HofFman/CIarkson Ind.
P.O. Box 548
East Syracuse, NY 13057-0548
Phone:  (315)437-0311
Ann:  Earl Stone
Fred Hickey Corp.
9601 River Street
Schiller Park, IL  60176
Phone: (708)678-2777
David Arata
525 Westin Street
Hoffman Estates, IL 61094
Phone:  (708)843-2139
BobZopf
Phone: (317)271-4001
Dove Equipment Co.
4831 Colt Rd.
Rockford, IL 61109
Phone: (815)87-8900

Recovery Equipment Corp.
P.O. Box 75
Mequon, WI 53092
Phone: (414)242-9410

Pat Russell
Phone: (704)372-3890
Wisconsin Compressed Air
3056 W. Meinecke Avenue
Milwaukee, WI  53210
Phone: (414)442-0280

Earl Stone
Phone: (315)437-0311
                                    -5-

-------
 Manufacturer
                                                          P7T
 Hoyt Corporation
 251 Forge Road
 Westport, MA  02790
 Phone: (508)636-8811
 Fax: (508)636-2088

 Intend Corp.
 P.O. Box 4676
 Englewood, CO 80155
 Phone: (303)773-0753

 Kontes Scientific
 Glassware/Instruments
 P.O. Box 729
 Vineland, NJ 08360
 Phone:  (609)692-8500
 Fax:  (609)692-3242

 Lenan Corporation
 615 North Parker St.
 Janesville, WI 53545
 Phone:  (800)356-9424
 In Wi (608) 752-1601

 Luwa Corporation
 Process Division
 P.O. Box 16348
 Charlotte, NC 28297
 Phone:  (704)394-8341
 Fax:  (704)392-8507

 O-I/Schott Process Systems
 1640 Southwest Blvd.
 Vineland, NJ 08360
 Phone:  (609)692-4700
 Fax:  (609)692-5619
 Arm:  John Jaworski

 PBR Industries
 400 Fanningdale Road
 West Babylon, NY  11704
 Phone:  (516)422-0057

Phaudler Company
 100 West Avenue
Rochester, NY  14692
Phone:  (716)235-1000
Fax:  (716)423-9644
 Michael Merely
 Rt. #3, Box 217
 Slatington, PA 18080
 Phone: (215)767-7622
Cynthia Halstead
259 Mary Street
Winnetka, IL  60093
Phone: (708)835-3392
Energy Sales Products
515 St. Lawrence Avenue
Janesville, WI 53545
Phone: (608)752-0195
Ralph Scully
2407 Worthing Drive
Suite 101
Naperville, IL
Phone:  (708)305-8693
Liquiflow, Inc.
1201 National Ave.
Addison, IL  60101
Phone: (708)543-4080
Attn:  Mitch Brach
Quality Auto Body Supply
129 Vine Street
La Crosse, WI  54601
Phone: (608)782-4552

Mark Cody
Phone: (708)244-8363
    or
Todd Pollack
Phone: (313)739-4311

-------
Manufacturer
                                         Distributor/Sales Reo.
Progressive Recovery
1976 Congressinal Dr.
St. Louis, MO 63146
Phone: (314)567-7963
Arm:  Joe Miller

Renzmann, Inc.
Max DetweUer Corp.
13420 Reese St., West
Huntersville, NC 28078
Phone: (704) 875-1200

Siva Internationa)
Recyclene/Disti
405 Eccles Avenue
South San Francisco, CA 94080
Phone:  (415)589-9600

Unique Industries
P.O. Box C4530
Pacoima, CA 91333-4530
Phone:  (818)890-1133
Venus Products
1862 Ives Avenue
Kent, WA 98032
Phone:  (206)854-2660
Midwest Environmental
N88 W16751 Appleton Ave.
Menomonee Falls, WI 53051
Phone: (414)253-2299
Ann:  Mike Kleinhans

Arthur Collier
13420 Reese St. West
Huntersville, NC 28078
Phone: (416)433-0363
Waste-Tech, Inc.
1931 Industrial Drive
Libertyville, IL 60048
Phone:  (708)367-5150
Fax: (708)367-1787

Phoenix-Erin
487 Willsher Drive
Fond du Lac, WI 54935
Attn: Don White
Phone:  (414)922-2936

Northwest Fiberglass
3055 Columbia Ave. NE
Minneapolis, MN 55418
Phone:  (800)544-1388
                                            Hazardous Waste Minimization Program
                                          Wisconsin Department of Natural Resource:
                                                       P.O. Box 7921 (SW/3)
                                                        Madison, WI  53707
                                                         (608) 267-9523 or
                                                           (608) 267-3763
                                     Printed on R«cyd«d Paper
                            PUBL-SW-150 9
                                   -7-

-------