epa-rtp facilities waste reduction assessment

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EPA-RTP FACILITIES WASTE REDUCTION ASSESSMENT
PURPOSE:
The WRRC conducted a Waste Stream Audit of EPA-RTP Activities on August 30 – September
2, 1999. The Audit was conducted pursuant to William Laxton’s Memorandum of August 24,
1999 to help develop a program for the new EPA facility in RTP. A walk through assessment of
waste generating activities at 10 facilities was conducted to accomplish the following:





Identify waste.
Quantify volumes generated.
Verify current waste recycling, reuse and disposal practices.
Identify additional waste streams not currently targeted for recycling, reuse,
energy generation, etc.
Identify waste reduction alternatives and optimized waste handling opportunities
for the new facility.
MINIMUM REQUIREMENTS:
EPA’s RTP facilities are expected to comply with the provisions of Executive Orders governing
federal facilities. Provisions of two Executive Orders address pollution prevention, waste
reduction, energy, and water conservation and other environmental issues. The following
paragraphs provide excerpts of two that address findings in this report and establish minimum
waste reduction goals and standards for future operations.
Executive Order 13101: Greening The Government Through Waste Prevention, Recycling
and Federal Acquisition dated September 14, 1998 (attached).

Establishes waste prevention and recycling goals for daily operations.

Establishes affirmative procurement goals to help create markets for recycled content
materials. Goals applicable to this audit’s findings include wording that each agency
shall establish minimum post consumer content of 30% for all categories of paper. If
price and performance dictate, 20% post consumer content paper may be purchased.
Effective January 1, 1999, the minimum standards established are applicable to all
purchases.

Contracts for services within Federal Facilities are to include a requirement to comply
with provisions of this order.
Executive Order 38561: Greening The Government Through Efficient Energy Management
dated June 3, 1999 (attached).
Although outside the scope of this audit, the main thrust of EPA – RTP’s energy management
practices should be at a minimum to insure that stipulated energy conservation goals, techniques,
and practices are met by the new facility and when possible, exceeded. These include:
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
Reduced energy consumption per gross square foot of 30% by 2005, and 35% by 2010
(Baseline 1985).

For lab facilities, reduce energy consumption by 20% by 2005 and 25 percent by 2010.
(Baseline 1990).

Establishing water conservation practices and procedures compatible with GSA
principles for the siting, design and construction of new facilities.
If appropriate, the LEED Green Building Rating System ™ 1.0 standard issued by the Green
Building Council dated January 1999 could be used as an evaluation tool for systems, materials,
and practices being installed and implemented in the new building (attached).
APPROACH: John Calcagni and Bob Carter of the Waste Reduction Resource Center
accompanied by appropriate staff environmental members, conducted a waste audit of targeted
EPA-RTP activities in the following order:
August 30
Emissions Monitoring Lab
Grand Slam Racquet Club
Catawba Building
NHEERL
August 31
Annex
Administration Building
Building 4201
NHEERL
Sept. 1
N. C. Mutual
Human Studies
Sept. 2
Environmental Research Center
The Audit was conducted in a manner to minimally interfere with on-going activities. Most
personnel were aware of the scheduled audit. All encountered were very cooperative and
expressed interest in handling and reducing waste properly at their location.
Waste generating and handling practices were observed at each location. Many personnel at
individual sites were not aware of the ultimate fate of wastes collected at their site. Many,
particularly at Chapel Hill and N. C. Mutual sites, were not aware of which wastes could be
recycled through existing programs. Observations both general and specific will be discussed in
succeeding sections.
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GENERAL DISCUSSION:
The Environmental Protection Agency must set the example in complying with environmental
standards established for Federal Agencies. To do otherwise would compromise the Agency’s
capability to enforce the environmental standards, rules and regulations it is charged with
enforcing.
EPA-RTP has an opportunity to set the example for environmental stewardship in this area.
Every effort should be made to instill an environmental protection ethic in all offices, labs, and
other activities in the new facility. Efforts to generate this ethic should begin now in existing
operations.
This assessment found significant variability in current waste reduction, waste avoidance and
recycling practices at different locations. In most cases, all personnel contacted were interested
in participating in the existing recycling program as they understood it to be. Knowledge of
current opportunities varied. A re-education of all employees on the current recycling program
would set the stage for program review and modification.
A significant effort needs to be initiated to reduce the large magnitude of files, records, excess
materials, equipment, furniture, etc., as soon as possible. Guidelines need to be issued on the
proper retention and disposal of records and documents dating from the 70’s and 80’s.
Cataloging and broadcasting of excess materials and equipment for possible internal use and
marketing or disposal should begin ASAP.
The ORD Health, Safety, and Environmental Management Office now manages future
acquisition of hazardous chemicals. However, large quantities of chemicals and other hazardous
materials were observed throughout the various labs and shops; many of which were dated as
purchased in the 80’s. Expanded control of the purchase, storage and issue of chemicals and
other hazardous materials is recommended to insure these materials are minimized. If feasible, a
central order issuing and lifecycle monitoring and control using a bar coding system should be
planned for the new facility. This computer based control and tracking process would provide
the necessary tools to minimize this waste stream.
To maximize the effectiveness of the program and eliminate the need to “grandfather” old
chemicals it should be started before moving to the new facility. Existing inventory should be
bar-coded as a condition of transfer. It is recognized that laboratory chemicals, standards and
cleaning agents are varied and generally issued in small volumes. However, there appears to be
reluctance to share chemicals among labs. The existing adoption programs for chemicals and
glassware needs to be expanded, given greater prominence and “sold” to the staff. Efforts should
be made to reduce quantities of chemicals stored in labs by such means as having the contractor
custom formulate solutions when using chemicals used in low volume or have the contractor
retain possession of the purchased reagent and limit what is dispensed to that necessary to
complete the task. Any effort to standardize, reduce quantities used and insure life cycle control
would be worthwhile.
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Executive Order 13101 encourages agencies, to the extent permitted by law, to retain funds from
recycling materials. Presently, arrangements for transferring the recyclable materials to a
wholesaler are designed to minimize the administrative burden rather than to realize any
potential economic return. The recyclable materials are transferred to a recycler through an
informal arrangement, which either party can cancel. The recycler agrees to haul, at no cost, all
agreed upon recyclables sorted by the Agency. The advantages of this arrangement are the
administrative simplicity of not having to bid and negotiate a formal contract, the elimination of
the need to track or keep records on quantities transferred and the elimination of the need to
transfer funds between parties. This approach minimizes the burden on the Agency and achieves
its primary interest of assuring that these materials are recycled rather than discarded. The limits
of this approach are that it does little to encourage expansion to other materials (e.g. scrap
metals, excessed laboratory glass, electronic components, etc.) or to recover any profits from the
recycling of materials.
While most offices pay a premium to cover the costs of collecting recycling materials, for larger
programs the proceeds from the sale of white paper, aluminum, cardboard, and scrap metal are
often sufficient to more than offset the costs of collection of the less profitable materials such as
mixed paper, plastic, and glass. Military installations often use proceeds from their recycling
programs to supplement “local morale and welfare funds.” From the limited available records,
we could not determine whether the quantity and mix of recyclable materials to be collected at
the new building would be sufficient to support a profitable recycling program. However, we
doubt the present recycler would continue the present arrangement if it was incurring a
continuing loss. With the increased centralization of EPA facilities and possibility of
consolidating recycled materials with NIEHS, there will likely be an increase in volume at the
new site and the likelihood of profitability is greater.
We understand that in Washington, D.C., the Agency has an arrangement with the EPA
Recreation Association where the association takes responsibility for the recyclables, serving as
an intermediary between the Agency and the wholesaler rather than having the Agency deal
directly with the wholesaler. Assuming interest by the RTP-EPA Recreation Association or
another local EPA/NIEHS employee-based group, a similar arrangement at the new facility
could result in tangible benefits to employees from recycling which could possibly encourage
increased participation. It would also provide a focal point for exploring expanding the program
into new areas without increasing the administrative burden on the Agency.
Subsequent to completion of the assessment, the Waste Assessment Team visited the NIEHS
Building and reviewed their recycling program. Their program appears to be well conceived and
functioning. While an in-depth review of their program is beyond the scope of this report, the
potential for beneficial cooperation is real. For example, NIEHS is receiving revenue for
recycling two waste streams that EPA-RTP is currently trashing (Pyrex and Tyvek). The
potential for establishing a central Material Recycling Facility to receive, market, and dispose of
excess and waste materials should be studied. Such a facility could serve both EPA-RTP and
NIEHS. Joint marketing of these materials would provide greater revenue than two separate
programs.
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SITE SPECIFIC OBSERVATIONS:
Emissions Monitoring Lab
Waste
Fate
Printer Copies Paper
Excess Recycled
Virgin Xerox Paper in use.
Aluminum Cans
Recycled by Vendor
Toner Cartridges
Unknown
Note: The store room of this facility contained old records, publications, spill kits for
acid/flammable/mercury/caustic materials clean up, etc. A continuing need for this material
could not be determined.
Excess Property Warehouse: Both Government owned and contractor property is stored in this
warehouse. Government owned property has been surplused by the original using activity.
Excess property is disposed of in the following priority:
1. Made available to local EPA onsite activities and other Federal Agencies.
(Advertised on GSA List)
2. Made available to local schools at no charge.
3. Publically auctioned.
4. Disposal
Waste Streams
Fate
- Pallets
1. Reused
2. Pay $2/pallet to remove
3. Non recoverable trashed
- Scrap Metal
Unknown
- Solid Waste
Disposed of under contract (dumpster contained
recyclable materials cardboard, pallets, metal,
computer monitors, white paper, carpets, etc. Inside
trashcan contained aluminum cans, white paper,
plastic, etc).
- Toner Cartridges
Accumulated from various activities and sold by
pallet via sealed bid.
Grand Slam Warehouse: The major activity in this building is the administrative supply storage
and issuing activity. The old central printing shop is no longer in use. While most paper in
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storage had 20 – 30 % post consumer content, special use paper was virgin material (colored,
covers, files, legal size three hole paper, etc.). According to the storeroom clerk, Xerox virgin
copier paper observed in use at various locations is not stocked or purchased. While basically a
storage and issuing activity, trashcans in the warehouse contained white paper, old permit forms,
etc.
Catawba Building: This is a leased office complex. As with all office areas observed, collection
sites for white paper and aluminum cans were provided. While several copier areas were
observed, the major user was the Central Printing Room which uses 15 to 50 cases of paper per
month depending on user requests. Some Xerox virgin paper was present.
Wastes
- White Paper
- Toner Cartridges
- Plastic Bottles &
aluminum cans
Fate
Recycled. Most copies in individual recycling containers
were single sided.
Replaced in Xerox container and returned to vendor (no
charge).
Recycled (No obvious vending source of plastic bottles
but bin was overflowing).
Annex: The Annex contains labs, test facilities, storage areas, offices and a cafeteria. The
loading dock for this facility serves as the collection and sorting area for recycled materials.
Materials and equipment were stored in every “nook and cranny” of this building. While the
loading dock is used by the contractor to sort recyclable materials, the dumpster contained white
paper, cardboard, loose fluorescent light bulbs, etc.
Waste
Fate
- Aerosol Spray Cans (Electronic Lab)
Placed in solid waste trash receptacles after use.
(This problem waste has been eliminated since the
assessment).
- Excess Equipment/Materials
To Excess Property Warehouse.
- Glass/plastic/aluminum
Recycled
- White Paper
Recycled
Note: Multiple copiers were observed in this building. Much of the work observed was single
sided. Two on 4th floor used purchased virgin paper from Office Depot (Purchased 5/27/99 and
7/26/99) with note to not use recycled paper.
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Annex Cafeteria
Waste
Fate
Grease
Sent to ERC Cafeteria
Glass, Plastic, Aluminum, Cardboard
Recycled
Steel Cans/Excess Food
Trashed
Administration Building:
This office building contained large quantities of paper document files. Significant quantities
of single sided white paper were in recycling containers. A large portion were headers from
printing jobs. Mixed paper was observed in multiple trashcans. Virtually all “junk mail” is
trashed.
Building 4201:
The same observations made of other administrative areas apply to this building with the
following additions:
- 3rd Floor copier had virgin paper stock. Approximately ½ ream of unused paper was in
recycle bin.
- Computer room had computer paper in trashcan.
NHEERL: This facility conducts toxicity studies using chemical analysis and test animals
(rodents, rabbits, snakes, etc). Animal care is provided by a contractor.
Waste
Fate
- Animal bedding (30K lbs./month)
(Includes bedding from ERC)
Incinerated at Building R
- Lab Solvents (Acetone, Toluene,
Methanol, Methylene Chloride)
Waste is fuel blended for incineration. 6-7 55-gallon
drums generated annually. Drums containing
>10% Methylene Chloride by volume are handled
separately.
- Chloroform (dilute)
waste stream is apparently generated by ERC)
- White Paper
Recycled (Many desk top printers observed in
office areas).
- Shredded paper
Recycled.
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- Excess Chemicals
Placed on “chemical adoption lists.” If no takers,
disposed of as waste.
- Batteries
NICAD recharged as long as possible then to off
site disposal as universal waste. Lead/Acid to
recycler.
- Lab Glass
Excess contaminated and non-contaminated glass
not claimed through adoption process goes to lined
landfill (1 cube yard/quarter).
- Solid Waste
Disposed. (Dumpsters contained cardboard, wood,
white paper, plastic, and pine shavings in addition
to trash).
Radioactive Waste
Depending on type decayed on site and incinerated,
sent to Florida facility for disposal or stored on site.
N. C. Mutual Building:
11 Floor Copier
Mixed paper in box (No recycle bin by copier)
9th Floor Copier Room.
Toner/ink cartridges in trash. Not aware of program to
collect and sell 10-15 boxes of paper consumed every two
weeks. Virgin copy paper “delivered by warehouse.”
Cardboard
trashed.
General Observations:
No one was aware of any toner ink cartridge recycling opportunity.
Human Studies Laboratory: This multipurpose building on UNC Campus is not scheduled for
movement.
Waste
Fate
Lab Glass/plastic
To trash. Plastic was being returned
to vendor but was stopped due to shipping
costs.
Hazardous Chemicals
To UNC for disposal (cost unknown).
White paper
Recycled. Picked up at building and sent to
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Annex. Significant quantity of headers.
Newspapers, mixed paper, glass, plastic
Taken by various employees to County
Recycling Centers. (Did not know mixed
paper and newspaper could be included with
white paper for sorting).
Toner Cartridges
Believed trashed. Possibly sent to MD-36
for recycling.
Personnel interviewed at this facility were unaware of any EPA sponsored recycling except for
white paper.
ERC:
Cafeteria
Waste
Food
Bottles/cans/cardboard
Grease
Fate
10 lbs/day composted
Recycled
Combined with Annex Cafeteria’s and sent to vendor.
Loading Dock:
Surplus materials, equipment and wastes from all activities are collected
and processed on the loading dock.
Waste
Fate
Pallets
To accumulation site, Contractor paid $2/pallet to pick up.
Chemicals
To Building R for processing for off site disposal or
incineration.
Surplus Equipment
Placed in temporary holding area for pick-up and use by
other labs. If no takers, sent to surplus warehouse.
Trash
Dumpster contained metals, cardboard, white paper, etc.,
that could have been recycled.
Ist Floor Shops
Contractor areas had some recyclable waste in trashcans.
Waste chemicals sent to Building R. NHEERL metal shop
operator “dumpster dives” to recover reusable metals.
A162 Computer Center:
Virgin paper in use specified by EPA HQ. Toner cartridges
trashed.
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Administrative Areas
Similar practices as observed at other sites. Substantial
quantities of equipment and paper stored throughout
facility similar to Annex.
Note: Chemical lockers (High Bay area) contained hazardous chemicals for test burn. While
appropriately marked, recommend OSHA rules for handling and security be reviewed to insure
compliance.
Accumulation Site: This fenced-in site contained many trailers, vans, etc., of unknown use. A
dumpster outside of the gate contained metals, cardboard, wood and other recyclable materials.
RECOMMENDATIONS:
Interim:
-
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Establish control over purchase of computer/copier/printer paper purchase and usage.
Ensure requirements of Executive Order 13101 for recycled content are met.
Adopt appropriate waste reduction suggestions contained in the “Waste Reduction Tip
Sheet” for offices (attached). Annual update and refresher training in the office/lab waste
reduction practices is recommended.
Identify office/floor recycling coordinators to improve communication of programs
among office staff and to serve as “watchdog” to ensure proper procedures are followed.
Insure all personnel are aware of proper handling of used toner cartridges. Consider
purchasing recycled toner cartridges.
Begin preliminary discussions with NIEHS on a joint recycling program. Identify
sources used by NIEHS for recycling Pyrex glass, Tyvek, etc., and establish similar
relationship with vendor if appropriate. (Dick Sloane, 541-2947 )
Laboratories should standardize chemicals used to extent possible. Efforts should be
made to reduce the acquisition of lower volume chemicals through improved sharing
among labs or seeking vendors who will dispense lesser quantities or custom formulate
necessary reagents.
If not planned, a central glass /implement cleaning facility should be considered similar
to that at NIEHS.
Begin a coordinated removal and marketing of excess materials, equipment, records, etc.,
from all activities.
NIEHS currently ships all Styrofoam (peanuts, packing materials, etc.,) to Rhone
Poulence for transshipment to a recycling company in Butner where it is converted into
plastic utensils. EPA should explore this alternative after reuse opportunities have been
exhausted.
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Long Term:
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-
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Begin study of the practicality of establishing a central Material Recycling Facility jointly
with NIEHS. Secure assistance of N. C. Office of Waste Reduction and N. C. Recycling
Association in the planning process.
Establish a central hazmat control and tracking system for all hazardous materials used
in the new facility. All hazardous materials to be transferred from existing materials
should be inventoried, bar coded, and placed under central inventory control.
Review energy and water conservation measures incorporated into the design of the new
facility to insure compliance with Executive Order 38561.
Establish an administrative procedure SOP to insure waste reduction and recycling are
inherent in daily operations at the new facility.
Evaluate and select the best putrescible garbage, yard clippings, and other compostable
waste conversion alternatives including a joint project with NIEHS.
Practice what we preach.
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