Tribal Casino Pollution Prevention
BEST MANAGEMENT PRACTICES/P2 RESOURCE LIST I
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Introduction ^Pno^°
There are more than 400 gaming facilities in the U.S. and the number and collective size of
the industry has increased steadily in recent years. The hospitality and gaming industries are
resource-intensive operations and generate many waste streams from the multi-function
facilities. Consequently, tribal casinos often have a large "environmental footprint."
More Tribal Casinos and Revenue Each Year
2004 2005 2006 2007 20CJB 2009
National Indian Gaming Commission
httD://www.niQC.QOv/LinkClick.asDx?fileticket=lk4B6r6dr-U%3d&tabid=67
The large and growing tribal casino sector consume large amounts of resources and generate
many wastes - tribes increasingly are focusing effort on reducing their environmental
footprint and in the process operating more efficiently and cost-effectively. In the following
sections, the best management practices (BMPs) for tribal casinos are divided into four
categories: (1) solid waste, (2) water use/wastewater generation, (3) energy use, and (4)
hazardous materials/hazardous waste. The BMPs encompass operations and activities
associated with the casinos, lodging, and dining.
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BMPS/P2 RESOURCE LIST (continued)
Solid Waste
According to a California waste study, commercial industry collectively generates about half of
the state's disposed waste stream
Primary
Sources/Waste
Streams
Food preparation
Food packaging
Hospitality items
Office paper, newspapers, phone books and directories
Construction and demolition (C&D) waste
Beverage containers
Shipping/receiving material (cardboard, plastic, pallets, etc.)
Fluorescent Lamps
Waste
Characterization
Hotels/Lodging Waste Generation:
• 5,049 pounds of waste/employee/year with less than 25% diverted
• 97 lbs/cubic yard (CIWMB. 2006. Targeted Statewide Waste Study -
Large Hotels:
www. calrecvcle.ca.aov/Publications/default.asD?Dubid = 1184').
• 35 - 45% of municipal solid waste is from commercial sources
{EcoPurchasing Guide for Hotels and Motels, 1993, University of Fla.)
• Restaurants: 1 Ib/seat/day, 17 Ib/employee/day
Hotels: 2-4 Ibs/room/day of solid waste (various CA studies
www.ciwmb.ca.aov/WasteChar/WasteGenRates/Service.htm')
Solid Waste
Composition
Hotels/Lodging Waste Composition:
Component
CIWMB-20061
Mohegan -199722
Food/organics
45.3%
37.5%
Grease
1%
Cardboard
6.8%
7%
Glass bottles and
containers
5.3%
4.5%
("commingled
recyclables")
Metal
3.1%
Paper
33.2%
50%
("trash")
Plastic
7.8%
C&D (Const & Demo)
5.0%
Other
0.3%
—
100%
100%
CIWMB. 2006. Targeted Statewide Waste Study - Large Hotels
www.calrecvcle.ca.aov/Publications/default.asp?pubid = 11841.
2 EPA. April 2000. Waste Reduction Tips for Hotels/Casino in Indian Country.
www. epa.Qov/epaoswer/non-hw/tribal/pdftxt/casi notips.pdf
page 2
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BMPS/P2 RESOURCE LIST (continued)
BMPS/P2
Opportunities
General for Casinos - Solid Waste and Recycling:
U.S. Environmental Protection Agency. Waste Reduction Tips for Hotels
and Casinos in Indian Country.
www.eDa.aov/wastes/wvcd/tribal/Ddftxt/casinotiDS.Ddf
Food Waste:
As hospitality venues, casinos prepare and serve food in multiple locations
including restaurants, worker cafeterias, and hotel room service. Food
service is often the largest casino function after gaming, and typically
offer patrons food during most, if not all parts of the day and night. The
largest component of the waste stream from food service is organic
materials including food trimmings, post-consumer waste (e.g., plate
scrapings), and disposable paper containers, and napkins.
Restaurants generate about 1 pound/seat/day or 17
pounds/employee/day of solid waste of which 37% is food waste.
(CalRecycle, Estimated Solid Waste Generation Rates for Service
Establishments.
www.ciwmb.ca.aov/WasteChar/WasteGenRates/Service.htm
• EPA Food Waste Management Cost Calculator,
www.eDa.QOv/wastes/conserve/materials/oraanics/food/tools/index.ht
m: EPA developed this Microsoft Excel spreadsheet to help
organizations estimate and compare the costs of alternatives to food
waste disposal. The
spreadsheet allows
Total Savings of Alternative Scenario and Source Reduction
Compared to Baseline Scenario
the user to input data
specific to their
circumstances
including access to
composting and
kitchen grease
vendors, and waste
costs and calculates
savings over multiple
time periods (see
example at right).
$25,000
$20,000
$15,000
$10,000
$0
I
• Green Seal GS-46, Standard for Restaurant and Foodservice
Operations,
www.areenseal.orQ/certification/standards/as46 restaurantfoodsvcs.cf
m: Green Seal established GS-46 to delineate environmental
standards for restaurants and food service operations for a variety of
"key impact areas" including food waste. GS-46 identifies levels of
environmental performance with specific goals and best practices.
Particularly useful are the tools associated with the standard including
a Waste Reduction and Management Plan to log food waste
accomplishments in each standard requirement.
• CalRecycle, www.calrecvcle.ca.aov/Publications/default.asp?cat=20:
California's guide to minimizing food waste from restaurants provides
an overview and tips for each point of food waste generation from
purchasing, handling and storage, preparation, and serving.
page 3
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BMPS/P2 RESOURCE LIST (continued)
Recyclables:
• Formalize a Recycling Program with staff training, data tracking, and
auditing (EPA provides an overview of implementation steps.
www.eDa.aov/osw/conserve/rrr/recvcle.htm
• Where available, maximize use of municipal or commercial recycling
programs; many offer free containers and pickup of recyclables and
some allow commingling of recyclables. Diverting recyclables and
compostables can reduce costs associated with landfill disposal of solid
waste disposed.
• WasteWise: Consider joining this free, voluntary EPA program through
which organizations eliminate costly municipal solid waste, benefiting
their bottom line and the environment.
www.eDa.aov/eDawaste/DartnershiDs/wastewise/about.htm
• Recycle paper products, cardboard, glass, plastic, and metals.
Commonly recyclable materials:
www.eDa.aov/osw/nonhaz/municiDal/Dubs/bus-auid/aDD-e.Ddf
• Identify special waste streams that can be recycled, such as batteries,
electronics, and fluorescent lamps. WasteWise electronics reuse and
recvclina: www.eDa.aov/eDawaste/inforesources/Dubs/infocus/rif-
c&d.Ddf
• Set up a paper recycling program:
www.eDa.aov/waste/conserve/materials/DaDer/settina/schoolwork.ht
m# offices
C&D - Carpeting:
• Environmentally preferable purchasing of carpet (U.S. EPA. 2006.
Carpet Resources.
www.eDa.aov/oDDtintr/eDD/Dubs/Droducts/carDets.htm"). Green Seal
offers a list of recommended carpet brands that manufacture and sell
environmentally responsible consumer carpets.
• Carpet reclamation (U.S. Environmental Protection Agency. 2006.
Carpet Resources.
www.eDa.aov/oDDtintr/eDD/Dubs/Droducts/carDets.htm
Greenhouse Gas
Reductions
Solid waste generation, disposal, and breakdown have large implications
on greenhouse gas (GHG) emissions. Tribal casinos can calculate the
GHG effect of their solid waste reduction and diversion efforts using
various methodologies.
EPA created the Waste Reduction Model (WARM,
httD://eDa.aov/climatechanae/wvcd/waste/calculators/Warm home.html")
to help solid waste planners and organizations track and voluntarily report
GHG emissions reductions from several different waste management
practices. WARM calculates and totals GHG emissions of baseline and
alternative waste management practices - source reduction, recycling,
combustion, composting, and landfilling. The model calculates emissions
in metric tons of carbon equivalent (MTCE), metric tons of carbon dioxide
equivalent (MTC02E), and energy units (million BTU) across a wide range
of material types commonly found in municipal solid waste.
page 4
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BMPS/P2 RESOURCE LIST (continued)
Hazardous Material/Hazardous Waste
Primary
Sources/Waste
Streams
• Janitorial chemicals
• Building maintenance chemicals
• Construction/Demolition wastes (asbestos and lead)
• Vehicle maintenance (hazardous chemicals, fuels, used oil, etc.)
• Fertilizers and pesticides
Waste
Characterization
• Janitorial - 1/3 of cleaning chemicals used today have harmful
ingredients (Western Regional Pollution Prevention Network. Janitorial
Products - Pollution Prevention Project.
www.westD2net.ora/Janitorial/workshoD.cfm
• Building Maintenance - metal cleaners, glass cleaners, aerosol
solvents, etc.
• Vehicle Maintenance - brake cleaners, solvent parts washers, used oil,
cleaners, used oil filters, etc.
BMPS/P2
Opportunities
Janitorial products P2:
Using green cleaning products in janitorial services offers better
environmental performance and improved worker health and safety, while
retaining the same sanitation quality as traditional, more chemical-
intensive methods.
• EPA has outlined various approaches and tools for "Greening Your
Purchase of Cleaning Products for Federal agencies casinos can use for
their operations including various tools, resources, and purchasing
auides. www.eDa.aov/eDD/Dubs/cleanina.htm#Dts
• EPA has defined environmental attributes for cleaners:
www.eDa.aov/eDD/Dubs/Droducts/cleanattribut.htm
• Green Seal has developed standards for various cleaning products
including general-purpose, restroom, glass, and carpet cleaners, for
routine cleaning of commercial, office, and industrial facilities:
www.areenseal.ora/certification/cleanina Droducts.cfm
• Case Study - Greening the Chumash Casino Resort:
www.eDa.aov/reaion09/waste/tribal/Ddf/Greenina-Tribal-Casino-
ODerations-SantaYnez.Ddf
Vehicle maintenance P2:
• EPA Region 9 conducted a comprehensive review of chemical products
used in vehicle maintenance facilities and prepared numerous
factsheets, case studies, and videos outlining P2 techniques and
technoloaies. www.eDa.aov/reaion09/waste/D2/autofleet/index.html
• Many vehicle maintenance fluids can be recycled, including used oil,
transmission and brake fluid, and antifreeze.
Integrated Pest Management (IPM):
• IPM reduce the use of pesticides, an approach that relies primarily on
non-chemical means such as controlling climate, food sources, and
building entry points to prevent and manage pest infestation.
www.eDa.aov/osw/wvcd/tribal/Ddftxt/casinotiDS.Ddf
• Landscape with indigenous plants adapted to the local climate and rain
patterns to reduce the need for additional chemical application.
page 5
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BMPS/P2 RESOURCE LIST (continued)
• GreenScapes: www.eDa.gov/QreenscaDes
• Large scale landscaping:
www.eDa.aov/eDawaste/conserve/rrr/areenscaDes/lrQscl.htm
• The Sustainable Sites Initiative: www.sustainablesites.org/
• Landscaping with Native Plants: www.eDa.gov/qreenacres/
• Integrated Pest Management Plan - Factsheet:
www.epa.gov/oppQ0001/factsheets/ipm.htm
Hazardous Waste:
• Batteries: www.epa.gov/osw/conserve/materials/batterv.htm
• Hazardous Waste Recycling:
www.epa.gov/osw/hazard/recvcling/index.htm
• Universal Waste: Steps to Managing your Universal Waste Lamps in
an Environmentally-Safe Manner:
www.epa.gov/osw/hazard/wastetvpes/universal/lamps/recvcle.htm
page 6
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BMPS/P2 RESOURCE LIST (continued)
Water Use/Wastewater Generation
Primary
•
Landscaping
Sources/Waste
•
Bathroom fixtures
Streams
•
Food Service
•
Building Operation/Physical Plant
Water Use
•
The average water usage per occupied room per day is 218 gallons
(University of Florida, Cooperative Extension Service and Energy
Extension Service. EcoPurchasing Guide for Hotels and Motels.
www.D2Davs.ora/ref/02/01784.Ddn
• Water consumption in the hospitality industry (Hagler BaiMy Services,
Inc., Bill Meade and Patricio Gonzalez-Morel. Improving Water Use
Efficiency in Hotels and Resorts Through the Implementation of
Environmental Management Systems.
www.ucowr.siu.edu/uDdates/Ddf/V115 A6.pdO
Water efficiency benchmarks
(International Hotels Environmental Initiative)
Property
size
Water use rating (figures are in US
gallons/guest night)
Good
Fair
Poor
Very poor
<50
roo ms
< 116
116- 134
134- 154
> 154
50- 150
roo ms
< 154
154-178
178-213
>213
> 150
roo ms
< 176
176-226
226 - 259
> 259
Water Use Distribution in Hotels:
Water Use Area
Hagler Bailly
Guest Rooms
33%
Kithcens/Coldrooms
18%
Landscaping
15%
Public Bathrooms
15%
Laundry
11%
Building Operation
5%
Pool
3%
100%
page 7
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BMPS/P2 RESOURCE LIST (continued)
BMPS/P2
Opportunities
WaterSense, www.eDa.gov/watersense is a voluntary partnership
program operated by EPA that promotes water efficiency and supports
implementation of product and practices that conserve water including at
commercial facilities such as casinos. By adopting and promoting water-
efficient products, services, and practices, water users can greatly reduce
annual water and energy costs, as well as help reduce the stress on
natural resources. www.eDa.aov/WaterSense/sDaces/ci.html
Bathroom Fixtures:
• Water saving bathrooms (faucets, toilets, urinals, showers, etc.) use
only a fraction of the water required by older, less efficient fixtures.
Casinos bathrooms often experience heavy customer usage and can
operate 24 hours a day, 7 days a week. EPA provide WaterSense
labeling based on third-party testing to meet EPA's specifications for
water efficiency and performance. A list of qualified products is
available at www.eDa.aov/WaterSense/Droducts/index.html.
Landscaping:
• Landscape with indigenous plants adapted to the local climate and soil
conditions to reduce the need for superfluous water application.
• Use recycled water for landscaping.
• Use composted mulch to retain soil moisture, control weeds, and
reduce water use. Mulching is placing organic matter over the root
zone of plants and trees and conserves water by reducing moisture
evaporation from the soil and weed populations. (U.S. Environmental
Protection Agency. Environmentally Beneficial Landscaping - Learning
to Balance Our Needs with Those of Future.
www.eDa.aov/reaion02/ff/ebl.Ddn
Food Service:
• Water efficient dishwashers
• Sink aerators
• Others
Building Operation/Physical Plant:
• Condensate reuse on steam boilers
page 8
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BMPS/P2 RESOURCE LIST (continued)
Energy Use
Heating/Ventilation/Air Conditioning (HVAC)
Kitchens
Lighting (casino)
Lighting (hotel and restaurants)
Building Operation (elevators, security systems, AV equipment, etc.)
Energy Use • Casinos can use 5+ times as much energy per square foot (1,200,000
Btu/sq.ft./year) as the average large hospital (EnergyServices. March
2006. Casino Energy Management Fact Sheet, www.wapa.aov
• Breakdown of energy consumption in the hospitality and lodging industry
(Energy and Environment Benchmark for Hotel Industry. 2006.
Engineering).
Space heating
31%
Water heating
17%
Cooling
15%
Lighting
20%
Kitchen
10%
Elevators
3%
Other
4%
Total
100%
• Laundering within the hospitality industry consumes around 2 - 5% of the
total hotel electricity (Energy and Environment Benchmark for Hotel
Industry. 2006. Laundry).
BMPs/P2 Lighting:
Opportunities # Use most effjCjent lighting systems for application (occupancy sensors,
energy efficient lamps/ballasts, etc.); Energy Star, lighting products:
www.eneravstar.aov/index.cfm?c=lighting.pr lighting
• Institute policy of using compact fluorescents (CFL) throughout facility
(casino, dining, meeting space, and lodging) instead of incandescent
except for special cases.
Slot Machines:
• Replace existing fluorescent lamps with longer lasting and more efficient
LED lamps, which can be a 50% savings rather than standard light bulbs.
LED lamp retrofit kits are available, which are direct replacements of the
fluorescent lamps and eliminate the fluorescent ballast.
Heating, Ventilation, and Air Conditioning:
• Maintain HVAC efficiency through monitoring and maintenance (The
Pollution Prevention Resource Exchange. 2006. Hospitality: Operations.
www.p2rx.org/topichubs/subsection.cfm?hub=14&subsec=28(.nav=2
• Install onsite energy generation or purchase green power electricity (U.S.
Primary
Sources/Waste
Streams
page 9
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BMPS/P2 RESOURCE LIST (continued)
Environmental Protection Agency. 2006. Green Power Partnership. Buy
Green Power. www.eDa.aov/areenDower/buvQD/index.htm
Hot Water Heaters/Boilers:
• Insulate all hot water pipes to maximize efficiency (Wisconsin Focus on
Energy. 2006. Controlling Energy Costs in Lodging Business - Fact Sheet.
www.focusonenerav.com/business/commercial-business/hotels/
• Set hot water heaters used for domestic use no higher than 120 °F.
• Typically the hot water used for washing linens must be hotter than the
water routed to individual lodging rooms, in order for the detergents and
bleaches to be effective. Separate the hot water heaters that service the
laundry washing machines from the lodging rooms, so that they can be
set at different temperatures.
Swimming Pools/Hot Tubs:
• Only operate outdoor heated pools during the warm season and consider
complete shutdown during off-peak season (only operating pump to
circulate pool chemicals).
• Use an insulating pool cover after hours and during off season.
• Replace existing single-speed circulating pumps with variable-speed
pumps.
Vendor information: www.pentaircommercial.com/
Energy savings calculator:
www.pentaircommercial.com/selectionauide/index.html
Appliances:
• Replace existing equipment with Energy Star rated appliances and
machines.
• Maintain appliances and perform regular cleaning of cooling and heating
elements/coils.
• Conduct cost/benefit analysis of appliances more than 10 years old
including us of energy company rebates.
Energy Calculators:
EPA's Energy Star program provides energy calculators for numerous types of
equipment to help make informed decisions about energy costs,
www.eneravstar.aov/index.cfm?c=bulk purchasina.bus purchasing:
• Clothes Washers
• Food Service Equipment: dishwashers, fryers, griddles, hot food cabinets,
ice machines, ovens, refrigerators and freezers, steam cookers, and
vending machines.
• Heating and Cooling Products
• Construction Products
• Consumer Electronics
• Office Products
page 10
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BMPS/P2 RESOURCE LIST (continued)
Case Studies
Mohegan Sun Resort
(TribalP2 Project Resources. Mohegan Tribe and Mohegan Sun
Resort. 2004. Visionary Planning for the Seventh Generation.
www.tribalD2.ora/resourceauerv.DhD?arouD=Droiect tvDe&searc
hbv=resourcecateaorv id&id=4&label=casinos
www.D2Davs.ora/ref/37/36109.Ddn
• 3rd largest casino in the United States
• Focused P2 effort on energy use, transportation, and food
service
o Send more than 2,190 tons of food waste to a piggery
each year
• Model of saving money through energy and resource
conservation
o Fuel cell technology
o Photovoltaics
o Heat pumps
o Infrared sensors for heating and lighting
o Recycling
o More than 44% of the solid waste stream is recycled
Chumash Casino Resort
Santa Ynez, California
Greening the Chumash Casino Resort:
www.eDa.aov/reaion09/waste/tribal/Ddf/Greenina-Tribal-Casino-
ODerations-SantaYnez.Ddf
• Parking structure storm water collection
• Gray water reuse
• Low flow bathroom fixtures
• Variable frequency drives
• Energy efficient projects: air hand dryers, slot machine
LEDs, energy management software
• Green cleaning program: Green Seal certified cleaners,
microfiber mops
• Source separation and recycling
• Customer and employee biodiesel shuttle buses
Eastern Band of Cherokee
Indians of North Carolina, 1
casino and 3 restaurants
www.tribalD2.ora/resourceauerv.DhD?arouD=Droiect tvDe&searc
hbv=resourcecateaorv id&id=4&label=casinos
• Composting program for wastewater treatment sludge,
vegetative waste, and food waste
• Collects approximately 1,200 lbs. of food waste per day and
final product is distributed to landscapers, nurseries, and
individual homes
Philadelphia's Sheraton
Rittenhouse Square Hotel
Greene-e. July 2002. Philadelphia's Sheraton Rittenhouse Square
Hotel "Warms Up" to Green Power.
• Purchases 20,000 kilowatts a month of wind power, which
represent 8% of the hotel's total electricity consumption
• Replaced incandescent light fixtures with compact
fluorescents and saved 78% in energy costs (Building Design
and Construction. November 2006. Green Buildings and the
Bottom Line)
page 11
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BMPS/P2 RESOURCE LIST (continued)
Disney World, Florida
Hotel Online Special Report, Ishmael Mensah. May 2004.
Environmental Manaaement Practices in US Hotels, www.hotel-
online.com/News/PR2004 2nd/Mav04 EnvironmentalPractices.ht
ml)
• Recycles 4 million gallons per day of wastewater for irrigation
of landscaping and golf courses
Habitat Suites Hotel in
Austin, Texas
Practices in US Hotels. Hotel Online Special Report, Ishmael
Mensah. Mav 2004. Environmental Manaaement. www.hotel-
online. com/News/PR2004 2nd/Mav04 EnvironmentalPractices.ht
mi)
• Water conservation program using water saving fixtures
• Energy savings using fluorescent lamps and air conditioning
units saving 122,000 kilowatt-hour of energy per year
page 12
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