Environmental science

Designing a Low-Cost Pollution Prevention Plan to Pay Off at the University of Houston

Yurika Diaz Bialowas, Emmett C. Sullivan, and Robert D. Schneller Environmental Health and Risk Management Department, University of Houston, Houston, TX

ABSTRACT The University of Houston is located just south of down- town Houston, TX. Many different chemical substances are used in scientific research and teaching activities throughout the campus. These activities generate a signif- icant amount of waste materials that must be discarded as regulated hazardous waste per U.S. Environmental Protec- tion Agency (EPA) rules. The Texas Commission on Envi- ronmental Quality (TCEQ) is the state regulatory agency that has enforcement authority for EPA hazardous waste rules in Texas. Currently, the University is classified as a large quantity generator and generates �1000 kg per month of hazardous waste. In addition, the University has experienced a major surge in research activities during the past several years, and overall the quantity of the hazardous waste generated has increased. The TCEQ re- quires large quantity generators to prepare a 5-yr Pollu- tion Prevention (P2) Plan, which describes efforts to elim- inate or minimize the amount of hazardous waste generated. This paper addresses the design and develop- ment of a low-cost P2 plan with minimal implementation obstacles and strong payoff potentials for the University. The projects identified can be implemented with existing University staff resources. This benefits the University by enhancing its environmental compliance efforts, and the disposal cost savings can be used for other purposes. Other educational institutions may benefit by undertak- ing a similar process.

INTRODUCTION The University of Houston campus covers �550 acres and includes �100 buildings. Current enrollment is �35,000 students with �5000 faculty and staff.1 There are �400

laboratories on campus presently with more planned in 2006.

Colleges and universities typically generate a wide range of chemical waste and, because of their decentral- ized organizational structure face, challenges in comply- ing with applicable waste regulations.2,3 One of the criti- cal functions of the University’s Environmental Health and Risk Management Department (EHRM) is to manage chemical waste in accordance with the U.S. Environmen- tal Protection Agency (EPA) and Texas Commission on Environmental Quality (TCEQ) rules.4,5 This is a sizable undertaking for the EHRM staff and ties up many re- sources. There is no formal long-term investment in waste disposal costs for the University other than a demonstra- tion of regulatory compliance.6 Therefore, it is in the best interest of the University to minimize the quantity of chemical waste generated whenever possible so that funds could be spent on projects other than waste disposal.

In addition, the TCEQ has promulgated rules that require large-quantity hazardous waste generators, such as the University, to develop a written 5-yr Pollution Prevention (P2) Plan.7,8 In these plans, generators describe the actions planned to minimize or eliminate the gener- ation of hazardous waste at their facilities.7 Previous P2 plans submitted by the University, as required by the regulations, had limited success in reducing wastes. The implementation of a more effective plan maximizing the available staff resources was needed.

Previous P2 Plan The previous P2 Plan at the University of Houston was designed for the period of 2001–2005. This plan proposed goals to reduce or minimize hazardous waste by taking several steps.9 These steps included the following: (1) chemical substitution: replacing a nonhazardous or less- hazardous substance for a hazardous or regulated chemi- cal; (2) small-scale experimentation: scaling down the experimental techniques used in research or instructional laboratories; (3) chemical exchange program: instituting a CHEM-SWAP program for laboratories to trade their un- used or reusable chemicals with other laboratories on campus; and (4) procurement initiatives: the EHRM peti- tioned the Purchasing Department to adopt a no-pur- chase policy for mercury-containing equipment and lead- based paint; historically mercury waste has been generated at the campus along with lead-based paint waste.

The University had some modest success with the previous P2 Plan. However, as the level of research has

IMPLICATIONS There is regulatory and economic pressure on educational institutions to reduce the amount of EPA-defined hazard- ous waste generated at their campuses. Although reducing and/or eliminating hazardous waste generation is a good management practice, institutions may face challenges in implementing this practice. These could arise from an in- crease in educational activities on campus or limited inter- nal resources to implement new waste management initia- tives. Regardless, a review of the current waste generation and disposal practices of the institution should be a priority. It is likely that waste reduction projects with attractive pay- offs, which can be implemented with existing resources, will be identified.

TECHNICAL PAPER ISSN 1047-3289 J. Air & Waste Manage. Assoc. 56:1320 –1324 Copyright 2006 Air & Waste Management Association

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grown 400% during the years 2000 –2005, the overall total quantity of waste generated continued to grow.10 In the year 2001, the University generated 30 t of waste, and by 2004 the total was 38 t. The EHRM expects that by im- plementing a more systematic review of the generating patterns of the University, a more effective P2 plan can be developed with minimal costs and without increasing staff.

DESIGNING A LOW-COST YET EFFECTIVE P2 PLAN The first stage of the plan development was to form a waste minimization team. The team was selected from the EHRM and then asked to follow a three-step process to identify potential projects. These steps included a review of the current waste generation profile, peer institution contacts, and identification of likely successful projects. Likely successful projects were defined as those that could be implemented with a fast payoff, such as �12 months, and with the existing manpower of the EHRM.

Review of Current Waste Generation Profile The team then reviewed the annual waste summaries for the years 2001–2004. These are required reports for regu- lated waste per the TCEQ rules.5 Figure 1 is representative of the waste generation of the University for the period of 2001–2004. The top six waste streams by quantity were waste oil derivatives, used photographic fixer, spent ha- logenated solvents, spent nonhalogenated solvents, and both EPA-defined hazardous waste and nonhazardous lab- oratory overpack drums.11 The associated disposal cost of these six waste streams is given in Table 1.

Peer Institution Contacts The team then contacted several other educational insti- tutions and inquired about their waste handling practices and facilities. The initial contacts were made via tele- phone. The primary objective of these telephone conver- sations was to review their successful waste minimization

practices and possibly identify those that could be imple- mented at the University of Houston.

A site visit was made to the University of Texas Health Science Center at Houston (UTHSC-H). This institution consists of six health-related schools and has �800 labo- ratories.12 The team was briefed on successful waste min- imization projects undertaken by the UTHSC-H Environ- mental Health and Safety Department and then was escorted on a tour of their waste facilities.

Identification of Likely Successful Projects The final step in the process was for the team to identify likely successful projects based on the waste generating profile of the University and the peer institution contacts. Each potential project was analyzed for time require- ments, equipment needed, safety precautions, cost and savings expectations, potential waste stream reduction, and regulatory compliance.13,14 Projects with the greatest cost benefit and ease of implementation were given the highest ranking. Likely successful projects were consid- ered as having a projected payoff of �12 months based on 2001–2004 waste generation data or being readily doable with existing EHRM staff.

Figure 1. University of Houston waste streams generation profile from 2001 to 2004.

Table 1. Top six waste streams generation and estimated disposal cost for 2004.

Waste Stream

Quantity Generated


Waste Disposal Cost


Nonhalogenated solvents 4146 651 Halogenated solvents 5030 1580 Hazardous lab pack 1769 328 Nonhazardous lab pack 10,046 7890 Waste oil derivatives 18,343 3411 Photographic fixer 11,713 5018 Total 51,047 18,878

Notes: Source—University of Houston 2004 Annual Waste Summary.11

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The team considered many different waste minimi- zation options for the six largest quantity streams. These included the following: (1) increase recycle of waste oil: expand existing program to include all recyclable oils on campus; (2) increase bulking of compatible liquid waste: safely combine as much compatible liquid waste in a single drum versus individual containers overpacked with absorbent material; (3) increase bulking of compatible solid wastes: safely combine as much compatible solid waste in a single drum versus individual containers over- packed with absorbent material; (4) install solvent recov- ery system for chlorinated solvent wastes: secure the equipment necessary to recover the hazardous constitu- ents of the chlorinated solvent waste stream, making the remaining material nonhazardous; and (5) installation of a silver recovery system for photographic waste: a system designed to capture the silver in the photographic fixer, which makes the remaining liquid waste nonhazardous.

From this list of potential projects, three were chosen by the team with the expectation that a significant reduc- tion in waste generation could be made with the resources available to the department. The selected projects were: (1) increase bulking of compatible liquid waste; (2) instal- lation of a silver recovery system for photographic waste; and (3) increase recycle of waste oil.


Increase Bulking of Compatible Liquid Waste This project consists of safely bulking compatible liquid chemical wastes by combining individual containers into a single larger container, such as a 55-gal drum. Compat- ible liquid waste would be considered as being in the same classification according to the Department of Transporta- tion Hazardous Materials table.15 Successful bulking of more chemical waste would lead to a reduction in the quantity of laboratory overpack (lab pack) waste. A lab pack waste drum typically contains 14 –16 individual bot- tles placed throughout the absorbent packing material. The entire drum is considered hazardous waste, although a significant percentage may be the packing material. By bulking compatible wastes whenever possible a signifi- cant reduction in the total quantity of lab pack waste could be achieved. The team estimated that this project

could reduce the cost of lab pack waste from $8218 to $569 per year. This would be a 93% cost savings.

The project would likely require an additional 8 hr per week of EHRM staff time to segregate chemicals ac- cording to their compatibility and bulk them into drums. A reassignment of duties for existing personnel could be made to accommodate the 8 hr. In addition, there is always a possibility of an unforeseen chemical reaction while bulking chemical waste. Historically, bulking was conducted under a flexible exhaust line in the waste fa- cility. The team identified a method to facilitate safer bulking by moving the operation to a fume hood. This could be accomplished by retrofitting the hood at a cost of �$2307 dollars. Due to the savings potential of this project, the alterations were made to the fume hood. Figure 2 shows the modifications made to enhance the bulking process in the university waste facility.

Installation of a Silver Recovery System for Photographic Waste

The photographic laboratories at the University of Hous- ton generated a total of 6 t of liquid silver-containing waste in 2003 and 6.5 t in 2004. Silver is one of the primary components of film and photographic paper that make it possible to form an image. Although it is not an ingredient of the original photographic solution, it is a byproduct of the film and paper processing. Silver is a heavy metal and is considered a hazardous waste by EPA.4

Discharge of silver to the City of Houston wastewater treatment system is strictly regulated.16

Silver has an economic value, and recovering it from the photographic waste saves the University money from two sources. First, the University receives a monetary value or credit for the silver recovered, and second, the University reduces the amount of hazardous photo- graphic waste generated and the associated disposal cost.

Silver in the form of thiosulfates anionic complex can be removed from photographic processing solutions by a number of techniques including electrolytic recovery, me- tallic replacement, precipitation, and ion exchange.17,18 The best alternative for the University is a combination of an electrolytic recovery system followed by a chemical recovery cartridge system. This combination will provide a higher

Figure 2. Original flexible exhaust line (left), original fume hood configuration (center), and retrofitted fume hood—note modification to easily roll drum underneath for safe bulking (right).

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silver recovery, allowing the remaining solution to be dis- posed into the city sewer system. The necessary equipment can be leased, and a vendor can service and maintain the silver recovery unit. The equipment lease, service, and main- tenance cost is expected to be �$676/yr. There will be ad- ditional costs for setup and installation. This project is ex- pected to reduce the cost of photographic fixer waste disposal from $5018 to $676/yr, an 87% savings.

The EHRM expects to eliminate �11,713 lb of pho- tographic waste per year with the addition of the new silver recovery unit. By using a lease service option, there will be minimal impact on staff requirements to service the unit.

Increase Recycle of Waste Oil One of the benefits of developing a systematic P2 plan for an institution is that it is possible to improve on existing recycling efforts that are already in place.5,19,20 This was the case for the University in terms of used oil recycling. The University has a fleet of 139 assorted trucks and cars and also has an auto shop that performs routine mainte- nance on these vehicles. The auto shop has a used oil collection system with a pump, associated piping, and a 1000-gallon storage tank. The auto shop had an arrange- ment with a local used oil reclamation firm to have the tank pumped out on a regular basis at no cost.

The waste minimization team quickly realized that used oil from other parts of the University could be added with this oil. EHRM waste personnel could easily bring used oil collected on campus to the collection system and have it pumped to the storage tank. The impact on the EHRM staff would be minimal to implement this procedure. The team conducted a compliance check of the current vendor with the TCEQ and also visited the reclamation site. This project is expected to eliminate used oil disposal costs from $3411 per year to $0, a 100% savings.

THE COST-BENEFIT ANALYSIS Table 2 displays the potential impact of the new P2 plan. The table lists the total waste generated before the plan is implemented and the projected implementation quanti- ties of the proposed projects.

Comprehensively, all of the projects combined could benefit the University in reducing the waste generated from the six largest waste streams from 51,047 lb per year

to 20,991 lb/yr. This will lead to a reduction in overall disposal costs.

The most significant remaining challenge is the re- duction of unknown waste. Although the amount of un- known waste is minimal, the analytical expense to iden- tify the waste and assure proper disposal is significant, greater than the collective disposal cost of the six largest waste streams. This challenge can be addressed by educat- ing the laboratory personnel of the importance of waste identification and segregation.

Figure 3 demonstrates the University waste genera- tion profile for the base years 2001–2005 and the pre- dicted waste generation for the years of 2006 –2010. The figure shows the projected waste reductions with the im- plementation of the three selected projects described pre- viously. The forecast shows the elimination of the photo- graphic fixer and waste oil derivatives streams. Lab pack waste also shows a very significant reduction. The halo- genated and nonhalogenated solvents show an increase due to the shift from lab pack waste to bulked solvents. However, the increase in disposal costs for the bulked halogenated and nonhalogenated waste solvents is offset by the projected savings in lab pack waste disposal costs.

CONCLUSIONS AND RECOMENDATIONS The University of Houston is a large teaching and research institution that generates a significant amount of chemi- cal waste that will likely increase as the University con- tinues to grow. Much of the waste generated is considered hazardous per EPA regulations. The University faces in- creasing regulatory and economic pressure to reduce the amount of hazardous waste generated and the associated disposal costs. The EHRM has had modest success in the past in reducing hazardous waste generation; however, it faces staff and budget limitations. A more effective P2 Plan was necessary using the available departmental resources.

A waste minimization team was formed, and a three- step process to identify likely successful projects was fol- lowed. These steps consisted of profiling current waste generation processes, contacting peer institutions, and selection of projects. By following this process, the uni- versity has identified several projects and is expecting to reduce its six largest waste streams collectively by 50%. Fur- thermore, the University expects to achieve these goals with its existing staff and also expects to pay the cost of imple- mentation within the first 12 months of each project.

Waste minimization is a long-established environ- mental and economic best practice. The University has faced challenges in trying to reduce waste generation with the available resources while at the same time experienc- ing growth. Other institutions and organizations may face similar challenges. The University has found that despite these challenges, an effective P2 Plan to minimize waste generation can be developed with the resources available to the organization. Such a P2 Plan can be sur- prisingly effective in reducing waste quantities and can be highly cost effective.

ACKNOWLEDGMENTS The authors thank Alan Lucas, environmental protection manager at the University of Texas Health Science Center at Houston, for his ideas and suggestions on this project.

Table 2. Projected impact of the waste minimization program (6 largest waste streams).

Major Waste Streams

Quantity Generated Before (lb)

Projected Quantity

Generation (lb) Project

Nonhalogenated solvents 4146 5824 Bulking Halogenated solvents 5030 14,558 Bulking Hazardous lab pack 1769 518 Bulking Nonhazardous lab pack 10,046 91 Bulking Waste oil derivatives 18,343 0 Recycle Photographic fixer 11,713 0 Silver recovery Total 51,047 20,991

Notes: Source—Expected waste reduction by implementing waste reduction projects: (1) bulking, (2) recycling, and (3) silver recovery.

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Volume 56 September 2006 Journal of the Air & Waste Management Association 1323

They also wish to thank Mark O’Riley, hazardous waste coordinator, and Rocio Harrelson, biological safety man- ager, both members of the Environmental Health and Risk Management Department, for their assistance in the preparation of this paper.

REFERENCES 1. The University of Houston. UH at a Glance. Available at http://www.

uh.edu/uh_glance (accessed 2005). 2. Massachusetts Institute of Technology. Environmental Virtual Campus.

Available at http://www.c2e2.org/evc/about.html (accessed 2005). 3. The Campus Safety, Health and Environmental Management Association

(CSHEMA) List Server. Available at: listserv@lists.umn.edu (accessed 2005). 4. Environmental Protection Agency. Fed. Regist. 2002, 40, 260 –265. 5. Texas Commission on Environmental Quality. Standards Applicable to

Generators of Hazardous Waste; Sections 335.61-335.78; Texas Commis- sion on Environmental Quality: Austin, TX, 2003.

6. Environmental Protection Agency Sector Program Colleges and Uni- versities. Environmental Compliance Assistance Guide for Colleges and Universities. Available at http://www.epa.gov/ispd/colleges/index.html (ac- cessed 2005).

7. Texas Commission on Environmental Quality. Pollution Prevention: Source Reduction and Waste Minimization; Sections 335.471-335.480; Texas Commission on Environmental Quality: Austin, TX, 2003.

8. The Texas Commission on Environmental Quality. A Guide to Pollution Prevention Planning; Texas Commission on Environmental Quality: Austin, TX, 2004.

9. The University of Houston. 2001–2005 Waste Reduction and Waste Minimization Plan Executive Summary; The University of Houston: Houston, TX. 2000.

10. The University of Houston Division of Research. Annual Research Re- ports. Available at http://www.research.uh.edu/downloads/PDF_format/ Annual2003/compare_award_by_agency.pdf (accessed 2005).

11. The Texas Commission on Environmental Quality. University of Houston 2001–2004 Annual Waste Summaries. Available at http://tceq.state.ex.us/ permitting/registration/ihw/waste_reporting.html (accessed 2005).

12. The University of Texas Houston Health Science Center. Status Report 2000; The University of Texas Houston Health Science Center: Hous- ton, TX, 2000.

13. Schwartz, C.; Howard, W. Waste Minimization: Cornerstones for a Suc- cessful Implementation; McGraw-Hill: New York, NY, 2002.

14. Selg, R.A.; Norkus, A.M.; Olson, C.M. Cost-Effective Waste Minimization Techniques; McGraw-Hill: New York, NY, 1991.

15. Keegan, R.J. 2004/2005 Hazardous Materials Substances and Wastes Compliance Guide; Hazardous Materials: Kutztown, PA, 2004.

16. City of Houston. Water and Sewer Code Ordinances; Article V; Dis- posal of Industrial Wastes through City Sewer System; Section 47-186, 3284.3-3284.4, Section 47-194, 3287-3289; City of Houston, Houston, TX, 2004.

17. Silver Council. Code of Management Practices: Guide for Photo Processors. Harrison: New York, NY, 1997. Available at http://www.silvercouncil.org/ codes/Photo_Manual.pdf (accessed 2004).

18. Eastman Kodak Company. Sources of Silver in Photographic Processing Facilities, 1998. Available at http://www.kodak.com/eknec/documents/f9/ 0900688a800f80f9/J210ENG.pdf (accessed 2005).

19. The University of Houston Environmental Health and Risk Manage- ment Department. Policies and Procedures. Chemical Recycling and Waste Minimization Procedures. Available at http://www.uh.edu/plantops/ emanual/forms/ehrm/ecbs_ChemRecycleWasteMinProc012605.pdf (ac- cessed 2005).

20. The Texas Commission on Environmental Quality. Resource Exchange Network for Eliminating Waste (RENEW). Available at http://tceq. state.tx.us/assistance/P2Recyclr/renew/renew.html (accessed 2005).

About the Authors Yurika Diaz Bialowas is a chemical engineer intern and an environmental compliance at the University of Houston En- vironmental Health and Risk Management Department. Emmett Sullivan is the University of Houston environmental compliance manager and Robert D. Schneller is the direc- tor of the Environmental Health and Risk Management Department. Address correspondence to Yurika Diaz Bialowas, 935 Rock Springs Dr., Richmond, TX 77469; phone: �1-832-588-8385; fax: �1-281-344-0094; e-mail: yurikadiazbialowas@houston.rr.com.

Figure 3. University of Houston major waste stream generation profile.

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