EPA-RTP FACILITIES WASTE REDUCTION ASSESSMENT

• Identify waste.
• Quantify volumes generated.
• Verify current waste recycling, reuse and disposal practices. recycling, reuse, energy generation, etc.
• Identify waste reduction alternatives and optimized waste handling opportunities for the new facility.

• 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).

• 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.

• 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 the sites outside RTP, were not aware of which wastes could be recycled through existing programs. Observations both general and specific will be discussed in succeeding sections.

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.

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. 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.

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 metal, 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.

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 on site activities and other Federal Agencies (Advertised on GSA List)
2. Made available to local schools at no charge
3. Publicly auctioned
4. Disposal

Waste		Fate
Pallets		Reused
		Pay $2/pallet to remove
		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 trash can 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 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, trash cans 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.

Waste		Fate
White Paper		Recycled. Most copies in individual recycling containers were single sided.
Toner Cartridges		Replaced in Xerox container and returned to vendor (no charge)
Plastic Bottles		Recycled (No obvious vending source of plastic bottles)
Aluminum Cans		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)		Trashed (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.

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 trash cans. 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 2 reams of unused paper were in recycle bin.
• Computer room had computer paper in trash can.

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)		Incinerated at Building R
Lab Solvents (Acetone, Toluene, Methanol, Methylene Chloride)		Waste is fuel blended for incineration. 6-7 55-gallon drums generated annually. No drum can contain >10% Methylene Chloride by volume.
Chloroform		7 drums/year to waste treatment.
White Paper		Recycled (Many desk top printers observed in office areas).
Shredded Paper		Recycled
Excess Chemicals		Placed on "chemical adoption lists". If no takers, disposed of as waste.
Batteries		NICAD recharged as long as possible then to hazardous waste stream. Lead/Acid to recycler.
Lab Glass		Contaminated and non-contaminated 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:

11th 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 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		Fate
Food		101 lbs/day composted
Bottles/cans/cardboard		Recycled
Grease		Combined with Annex Cafeteria's and sent to vendor.

Loading Dock:

Surplus materials, equipment and wastes from all activities is 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 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.
1st Floor Shops		Contractor areas had some recyclable waste in trash cans. 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.
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 these storage lockers be secured when not in use.

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:

• 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). An employee orientation and/or training in office/lab waste reduction practices is recommended.
• 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. Laboratories should standardize chemicals used to extent possible. 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 Poulenc 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.

Long Term:

• 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 putrescent garbage, yard clippings, and other compostable waste conversion alternatives including a joint project with NIEHS.
• Practice what we preach.