Development and Evaluation of Hazardous Materials Inventory Status and Action Plan Final Report 509 Prepared by: Michael A. Sussman, E.I.T. AMEC Earth & Environmental, Inc. 3232 W. Virginia Ave. Phoenix, Arizona 85009 July 2003 Prepared for: Arizona Department of Transportation in cooperation with U.S. Department of Transportation Federal Highway Administration The contents of this report reflect the views of the authors who are responsible for the facts and the accuracy of the data presented herein. The contents do not necessarily reflect the official views or policies of the Arizona Department of Transportation or the Federal Highway Administration. This report does not constitute a standard, specification, or regulation. Trade or manufacturers' names which may appear herein are cited only because they are considered essential to the objectives of the report. The U.S. Government and the State of Arizona do not endorse products or manufacturers. Technical Report Documentation Page 1. Report No. 2. Government Accession No. 3. Recipient's Catalog No. FHWA-AZ-01-509 4. Title and Subtitle 5. Report Date July 2003 6. Performing Organization Code Development and Evaluation of a Hazardous Materials Inventory Status and Action Plan 7. Author 8. Performing Organization Report No. Michael A. Sussman, E.I.T. 1-114-002042 9. Performing Organization Name and Address 10. Work Unit No. 11. Contract or Grant No. AMEC Earth and Environmental, Inc. 3232 West Virginia Avenue Phoenix Arizona 85009 SPR-PL-1-(59)-509 12. Sponsoring Agency Name and Address 13.Type of Report & Period Covered ARIZONA DEPARTMENT OF TRANSPORTATION 206 S. 17TH AVENUE PHOENIX, ARIZONA 85007 Final Report - 2003 14. Sponsoring Agency Code Project Manager: Estomih Kombe 15. Supplementary Notes Prepared in cooperation with the U.S. Department of Transportation, Federal Highway Administration 16. Abstract AMEC Earth and Environmental (AMEC) has completed an effort to assist the Arizona Department of Transportation (ADOT) in complying with the requirements of Arizona Revised Statutes (A.R.S.) §49-961 through §49-973. These statutes require Arizona state agencies that generate certain quantities of hazardous waste or use certain amounts of toxic substances to develop a pollution prevention program and submit documentation regarding that program to the Arizona Department of Environmental Quality (ADEQ). Toxic substances are defined as those materials regulated under the United States Environmental Protection Agency’s (US EPA) Toxic Release Inventory Program. AMEC determined ADOT’s status with regards to the regulatory planning thresholds by collectiing information about purchases of toxic substances and the generation of hazardous waste. The quantity of hazardous waste generated by ADOT during the 2000 calander year was below the planning threshold. However, AMEC determined that ADOT used two toxic substances (methanol and ethylene glycol) in excess of the planning threshold during the 2000 fiscal year. Therefore, ADOT is required to submit a Pollution Prevention Plan to ADEQ. AMEC has developed an appropriate Pollution Prevention Plan for ADOT’s submital. In addition to the two materials used in excess of the planning threshold, the Plan addresses toxic substances for which the agency exceeds one half of the reporting threshold and chemicals identified as persistent, bioaccumulative, and toxic (PBT) by the US EPA that are used in excess of their Toxic Release Inventory reporting thresholds. 17. Key Words 18. Distribution Statement Pollution Prevention Toxic Substances Hazardous Materials Inventory Document is available to the U.S. public through the National Technical Information Service, Springfield, Virginia 22161 19. Security Classification 21. No. of Pages Unclassified 20. Security Classification Unclassified 137 22. Price 23. Registrant's Seal SI* (MODERN METRIC) CONVERSION FACTORS APPROXIMATE CONVERSIONS TO SI UNITS Symbol When You Know Multiply By To Find APPROXIMATE CONVERSIONS FROM SI UNITS Symbol Symbol When You Know Multiply By LENGTH To Find Symbol LENGTH in inches 25.4 millimeters mm mm millimeters 0.039 inches in ft yd mi feet yards miles 0.305 0.914 1.61 meters meters kilometers m m km m m km meters meters kilometers 3.28 1.09 0.621 feet yards miles ft yd mi square inches square feet square yards acres square miles in2 ft2 yd2 ac mi2 fluid ounces gallons cubic feet cubic yards fl oz gal ft3 yd3 ounces pounds short tons (2000lb) oz lb T AREA 2 in ft2 yd2 ac mi2 square inches square feet square yards acres square miles fl oz gal ft3 yd3 fluid ounces gallons cubic feet cubic yards 645.2 0.093 0.836 0.405 2.59 AREA 2 mm m2 m2 ha km2 2 square millimeters square meters square meters hectares square kilometers mm m2 m2 ha km2 Square millimeters Square meters Square meters hectares Square kilometers milliliters liters cubic meters cubic meters mL L m3 m3 mL L m3 m3 milliliters liters Cubic meters Cubic meters g kg mg (or “t”) g kg Mg grams kilograms megagrams (or “metric ton”) 0.0016 10.764 1.195 2.47 0.386 VOLUME 29.57 3.785 0.028 0.765 VOLUME 0.034 0.264 35.315 1.308 3 NOTE: Volumes greater than 1000L shall be shown in m . MASS oz lb T ounces pounds short tons (2000lb) 28.35 0.454 0.907 MASS grams kilograms megagrams (or “metric ton”) TEMPERATURE (exact) TEMPERATURE (exact) º F Fahrenheit temperature fc fl foot candles foot-Lamberts lbf lbf/in2 poundforce poundforce per square inch 5(F-32)/9 or (F-32)/1.8 Celsius temperature º C º C Celsius temperature lx cd/m2 lx cd/m2 lux candela/m2 N kPa N kPa newtons kilopascals ILLUMINATION 10.76 3.426 1.8C + 32 Fahrenheit temperature º F ILLUMINATION lux candela/m2 FORCE AND PRESSURE OR STRESS 4.45 6.89 0.035 2.205 1.102 newtons kilopascals 0.0929 0.2919 foot-candles foot-Lamberts fc fl FORCE AND PRESSURE OR STRESS SI is the symbol for the International System of Units. Appropriate rounding should be made to comply with Section 4 of ASTM E380 0.225 0.145 poundforce poundforce per square inch lbf lbf/in2 TABLE OF CONTENTS Page EXECUTIVE SUMMARY .......................................................................................................................... 1 1.0 INTRODUCTION............................................................................................................................... 3 2.0 PROJECT DESCRIPTION ................................................................................................................. 4 3.0 SUMMARY OF WORK COMPLETED............................................................................................ 5 3.1. Prepare Work Plan..................................................................................................................... 5 3.2. Review Prior ADOT P2 Filings and State Requirements.......................................................... 5 3.3. Meet with ADEQ P2 Unit ......................................................................................................... 5 3.4. Toxic Use Data Collection ........................................................................................................ 5 3.5. Toxic Use Data Analysis........................................................................................................... 7 3.6. Determine Hazardous Waste Generation .................................................................................. 7 3.7. P2 Plan....................................................................................................................................... 7 3.8. Tracking Mechanisms ............................................................................................................. 12 3.9. Training Documents ................................................................................................................ 13 4.0 CONCLUSION ................................................................................................................................. 15 BIBLIOGRAPHY AND REFERENCES ....................................................................................... 16 LIST OF APPENDICES APPENDIX A: Commodity Codes Selected for Review ....................................................17 APPENDIX B: Project Databases .......................................................................................21 APPENDIX C: Purchase Records Removed from the Project Database Titled “Purchase Records Final” ...............................................................................67 APPENDIX D: Toxic Chemical Usage Report ...................................................................71 APPENDIX E: Training Documents...................................................................................77 APPENDIX E: Additional Data for Pollution Prevention Opportunities.....................................83 LIST OF TABLES TABLE 1 - Toxic Substances used by ADOT above the Regulatory Planning Threshold .....................................................................................................7 TABLE 2 - Toxic Substances Addressed in the ADOT P2 Plan ....................................8 This page intentionally left blank EXECUTIVE SUMMARY AMEC Earth and Environmental (AMEC) has completed an effort to assist the Arizona Department of Transportation (ADOT) in complying with the requirements of Arizona Revised Statutes (A.R.S.) §49-961 through §49-973. These statutes require Arizona state agencies that generate certain quantities of hazardous waste or use certain amounts of toxic substances to develop a pollution prevention program and submit documentation regarding that program to the Arizona Department of Environmental Quality (ADEQ). Toxic substances are defined as those materials regulated under the United States Environmental Protection Agency’s (US EPA) Toxic Release Inventory Program. AMEC determined ADOT’s status with regards to the regulatory planning thresholds from information about purchases of toxic substances and the generation of hazardous waste. The quantity of hazardous waste generated by ADOT during the 2000 calendar year was below the planning threshold. However, AMEC determined that ADOT used two toxic substances (methanol and ethylene glycol) in excess of the planning threshold during the 2000 fiscal year. Therefore, ADOT is required to submit a Pollution Prevention Plan to ADEQ. AMEC has developed an appropriate Pollution Prevention Plan for ADOT’s submittal. In addition to the two materials used in excess of the planning threshold, the Plan addresses toxic substances for which the agency exceeds one half of the planning threshold and chemicals identified as persistent, bioaccumulative, and toxic (PBT) by the US EPA that are used in excess of their federally mandated Toxic Release Inventory reporting thresholds. 1 This page intentionally left blank 2 1.0 INTRODUCTION This report provides details of the work completed by AMEC Earth & Environmental, Inc. (AMEC) under the Arizona Department of Transportation (ADOT) Purchase Order No. PGKS0843. The project title is “Development and Evaluation of Hazardous Materials Inventory and Action Plan” and has the AMEC Project No. 1-114-002042. This work was completed in accordance with the terms and conditions listed in Arizona Department of Administration Contract No. A7-0098-032. The purpose of this project was a determination of ADOT’s filing requirements under Arizona Revised Statutes (A.R.S.) §49-961 through §49-973, and the development of a Pollution Prevention Plan (P2 Plan) and associated documentation (as required by said regulations). 3 2.0 PROJECT DESCRIPTION According to A.R.S. §49-972, any state agency that generates more than 12,000 kilograms (kg) of hazardous waste or 1.0 kg of acutely hazardous waste in a calendar year, or that uses more than a threshold amount (10,000 pounds) of a single toxic substance (defined as those materials regulated under the United States Environmental Protection Agency’s Toxic Release Inventory Program) in a calendar year, must file a P2 Plan with the Arizona Department of Environmental Quality (ADEQ). Therefore, ADOT needed to determine its filing status with regards to these statutes, and if required, develop a comprehensive agency wide P2 Plan. 4 3.0 SUMMARY OF WORK COMPLETED 3.1. Prepare Work Plan AMEC developed a work plan to guide further work on this project. The work plan was submitted to the Technical Advisory Committee on March 30, 2001, and was subsequently approved for implementation. The work plan stated that the work would proceed in three steps. First, AMEC would gather information necessary to determine ADOT’s filing status with regards to Arizona P2 statutes. AMEC would then conduct a pollution prevention opportunity analysis at a representative selection of ADOT operations. Finally, the findings of this assessment would be organized into a formal or informal P2 Plan depending on ADOT’s filing status. 3.2. Review Prior ADOT P2 Filings and State Requirements As part of the development of the work plan AMEC received a copy of the ADEQ P2 Unit’s file on ADOT. AMEC reviewed this file which holds all previously submitted reports, P2 Plans, P2 Plan Amendments and correspondence. AMEC also reviewed applicable regulations and the “Pollution Prevention Amendment Guidance Manual”[1], published in July 1999 by ADEQ. This information was used to assist in the development of the work plan and in the completion of the project. 3.3. Meet with ADEQ P2 Unit AMEC was in continual communication with the ADEQ P2 Unit regarding specifics of this project. This consistent and free communication with the regulatory agency was undertaken to ensure that the project methods and results were acceptable to ADEQ. 3.4. Toxic Use Data Collection AMEC collected state-wide purchasing information from the ADOT Procurement Group and then screened this data for commodities which contained toxic substances as defined by Arizona Revised Statute §49-961.9. AMEC then totaled ADOT’s toxic purchases by chemical and compared those totals to the toxic use planning thresholds. AMEC procured a copy of the "State of Arizona Numeric Table of Commodities" [2], and identified the commodity codes that appeared to describe materials that contain toxic substances. The list of selected commodity codes was entered into a spreadsheet and sent to the ADOT Procurement Group. The spreadsheet listing the selected commodity codes is presented in Appendix A. The ADOT Procurement Group ran a query on the ADOT purchasing system and provided AMEC with a spreadsheet containing details from all purchase orders (POs) and invoices that were processed for the selected commodities during Fiscal Year 2000. It 5 was not possible to collect data for a calendar year as specified in the regulations so this review was conducted on a fiscal year basis. AMEC developed Microsoft Access databases to hold and process the data for this project. A database was used for two main reasons: it allows for easy handling of large quantities of data; and it allows for the relationships (or links) between data to be built in the database records and to be utilized by users for better data interpretation. AMEC created three databases for this project, one containing the purchase records received from ADOT titled “Purchase Records Final”, a second titled “Chemical With Paint Final” which contains information from the Material Safety Data Sheets (MSDSs) associated with the materials purchased, and a third titled “TRI Chemicals” which contains the names and Chemical Abstract Service (CAS) numbers of the chemicals defined as “toxic” by ADEQ and the U.S. Environmental Protection Agency (US EPA). The databases are presented in Appendix B. AMEC pared down the “Purchase Records Final” database by removing records for the purchase of items that clearly do not contain toxic chemicals or whose use does not meet the definition of toxic chemical use (i.e., tires, gloves). A large number of duplicate records were also removed. Approximately 70% of the records in the spreadsheet supplied by ADOT did not contain all of the information that was required for this study such as manufacturer’s name or quantity of material purchased given in pounds or in gallons. For each record that did not contain all of the needed information, AMEC reviewed the invoice or PO for the purchase. In about half the cases the necessary information was provided on this paperwork. For the remaining records that were still incomplete, AMEC contacted the product suppliers directly. A small number of records still remain incomplete. Since the remaining incomplete records are small in number and often represent small quantity purchases they have been removed from the final project database. A list of the excluded records is presented in Appendix C. AMEC collected material safety data sheets (MSDSs) for the materials listed in the project database. MSDSs were collected from the ADOT Safety Department, the internet and the manufacturers or suppliers of some of the materials. Some generic MSDSs have been used when specific brand names were not specified in the ADOT records or when brand specific MSDSs were unavailable. AMEC recorded the following data from the MSDSs: CAS numbers of toxic constituents, weight or volume fraction of each toxic constituent, specific gravity of the material and NFPA hazard classification of the material (if available). This data was entered into the “Chemical With Paint Final” database which links the toxic chemical information collected with ADOT purchasing information (“Purchase Records Final”) and the list of toxic substances contained in the “TRI Chemicals” database. All of the project databases are presented in Appendix B. 6 3.5. Toxic Use Data Analysis AMEC used the databases developed in the prior step in conjunction with the Microsoft Access report creating function to calculate the amount of each toxic substance used by ADOT during the 2000 fiscal year. Where purchased material quantities were in units other than weight, the weight of the material was calculated (in pounds) using the appropriate conversion factors and the densities of the materials. The weight of each material purchased was multiplied by the weight fraction of each toxic substance contained in the material to determine the weight of each toxic substance purchased. The assumption was made that the amount of toxic substance purchased equals the amount of toxic substance used during the same time period. The amount of each toxic substance used was compared to the thresholds adopted by ADEQ for P2 Planning (10,000 pounds of a single toxic substance used). The calculations show that ADOT used two toxic chemicals in excess of the above thresholds. Details of these two materials are presented in Table 1. ADOT is required to file a P2 Plan for at least these two chemicals. A complete Microsoft Access report of toxic chemical use during the fiscal year is presented in Appendix D. TABLE 1: Toxic Substances Used by ADOT above the Regulatory Planning Threshold Toxic CAS Major Planning Quantity Used by Substance Number Source Threshold (lbs.) ADOT (lbs.) Ethylene Glycol 107-21-1 Antifreeze 10,000 23,412.70 Methanol 3.6. 67-56-1 Paint 10,000 18,080.40 Determine Hazardous Waste Generation The aggregate quantity of hazardous waste shipped off-site for disposal by ADOT during the calendar year 2000 was determined by reviewing hazardous waste manifests submitted to ADEQ as recorded in the ADEQ Waste Shipment Database. According to the information received by ADEQ, ADOT generated and shipped offsite a total of 6,721.2 pounds of hazardous waste during the 2000 calendar year. Comparing this total quantity of waste generated to the statutory P2 planning threshold of 12,000 kg (26,400 lbs.) shows that ADOT is below the planning threshold for hazardous waste. 3.7. P2 Plan The information gathered showed that due to the use of toxic substances ADOT is required to file a formal P2 Plan per A.R.S. §49-972 and the July 1999 “Pollution Prevention Plan Guidance Manual” published by ADEQ. The ADEQ Guidance Manual states that a P2 Plan should at least address all toxic substances and wastes for which the facility exceeds planning thresholds. ADOT exceeds these thresholds for only two toxic substances. However, ADOT recognizes that 7 it has a responsibility to set a positive example. The agency will exceed these minimum standards by monitoring toxic substances for which the agency exceeds one half of the planning threshold and chemicals identified as persistent, bioaccumulative, and toxic (PBT) by the US EPA that are used in excess of their federally mandated Toxic Release Inventory reporting thresholds. Table 2 summarizes the materials addressed by the P2 plan. TABLE 2: Toxic Substances Addressed in the ADOT P2 Plan CAS Major Quantity Used Toxic Substance Number Source by ADOT (lbs.) Ethylene Glycol 107-21-1 Antifreeze 23,412.70 Reason for inclusion 1 Methanol 67-56-1 Paint 18,080.40 1 Dicamba 1918-00-9 Herbicide 6,560 2 Naphthalene 91-20-3 Herbicide 5,825 2 2, 4-dicchlorophenoxyacetic acid 94-75-7 Herbicide 6,238 2 Pendimethalin 40487-42-1 Herbicide 840 3 1 - Toxic substances for which ADOT exceeds the planning threshold. 2 - Toxic substances for which ADOT exceeds one half of the planning threshold. 3 - PBT chemicals used in excess of their Toxic Release Inventory reporting thresholds. AMEC reviewed how these materials are used by ADOT and then researched potential pollution prevention opportunities for those activities. AMEC collected information regarding potential pollution prevention opportunities from previous site visits, through consultations with ADOT personnel, from interviews with chemical manufacturers/ suppliers and industry associations, as well as from state and federal government websites. Each opportunity is discussed in detail in the next section. AMEC has completed a Pollution Prevention Amendment Form per ADEQ guidance that discusses the locations that use the identified toxic substances, how those toxic substances are used, what opportunities exist for reduction of the usage of those toxic substances and goals that ADOT can set for the reduction of the usage of those toxic substances. The P2 Amendment Form was initiated by the project consultant and completed by relevant agency staff, signed by a senior ADOT official, and submitted to ADEQ. Before the Amendment form was submitted to ADEQ, ADOT determined the feasibility of each opportunity that was identified and set goals based on those opportunities. For each opportunity that was not selected an explanation was provided in Section 6, Subpart 5 of the Amendment Form. 8 Pollution Prevention Opportunities Ethylene glycol ADOT currently uses ethylene glycol based coolant (antifreeze) in all state owned equipment, including automobile engines. Antifreeze is used in the engines to provide freeze protection and to act as a heat transfer medium to prevent engine overheating. Antifreeze also provides corrosion protection to certain engine components. Antifreeze generally consists of a chemical material dissolved in water. The presence of the chemical increases the boiling point and depresses the freezing point of the water thereby increasing the effective temperature range of the coolant. Ethylene glycol is the industry standard chemical additive that is used for the majority of coolant applications. Antifreeze will, over a period of time, become contaminated with oils, fuel and dissolved metals that are picked up from the engine. Because of this contamination, it is standard practice to replace used antifreeze in engines with uncontaminated antifreeze. Currently ADOT removes antifreeze from state vehicles and equipment on a regular time- and/or mileage-based schedule. The used antifreeze is collected and transported off-site for recycling by an outside contractor. AMEC recommended four opportunities for consideration by ADOT. These opportunities are described below. Additional information is supplied in Appendix E. Opportunity A: Reduce ratio of ethylene glycol to water used ADOT currently purchases antifreeze that consists of 50% ethylene glycol and 50% water (50/50). The ratio of ethylene glycol to water determines the recommended minimum and maximum temperature for the antifreeze. A ratio of 50/50 is a standard ratio that suppliers use. However, this ratio could be altered so that less ethylene glycol is used per vehicle filling. ADOT would need to determine how low this ratio can be set, considering the conditions and demands of equipment use. Opportunity B: Recycle used coolant on site. ADOT currently sends used antifreeze off-site for recycling, refilling the engines with virgin antifreeze. ADOT could recycle the antifreeze on site and put the recycled antifreeze back into the vehicles. Antifreeze recycling is a common practice in the private sector and public sector, particularly the Department of Defense. Three technologies are currently used for ethylene glycol recycling; ultrafiltration, distillation and deionization. Antifreeze can either be recycled directly from the vehicle and back into the same vehicle or it can be collected and recycled in bulk. Opportunity C: Substitute propylene glycol based coolant for current material Propylene glycol has similar thermal properties as ethylene glycol however propylene glycol is much less toxic. Propylene glycol can be substituted directly for ethylene glycol with no performance problems. Propylene glycol usually costs more to purchase but the disposal costs may be less than for ethylene glycol. Glycol substitution has been 9 commonly used across the country both for fleet and private vehicles as a way to minimize environmental impact and regulatory burden. Opportunity D: Reduce frequency of antifreeze changes Currently antifreeze is changed on a time or mileage-based schedule, however, antifreeze does not need to be changed unless it is contaminated. By regularly testing in-use antifreeze, ADOT could determine the extent of contamination and therefore make a more informed decision regarding when to replace it. Testing is usually conducted for one or more of the following parameters: pH, freezing point depression, total dissolved solids, density and viscosity. The exact parameters and tests along with the parameter tolerance would need to be determined by ADOT. Methanol Small amounts of methanol are in the latex paint used by ADOT for roadway signing and striping. The paint manufacturer adds methanol to the paint to provide freeze protection to the paint during storage. To reduce methanol usage, ADOT can either reduce the amount of methanol in the paint or reduce the amount of paint used. AMEC has recommended three potential opportunities for ADOT’s consideration. Each of these is described below and additional information is supplied in Appendix E. Opportunity A: Reformulate paint without methanol. The manufacturer of the paint stated that the paint could be reformulated without the methanol. The methanol would be replaced with propylene glycol to provide freeze protection. Arkansas, New Hampshire and New Mexico currently purchase and use methanol free road paint from this supplier. Opportunity B: Delineate lanes with plastic reflectors instead of paint. Plastic reflectors are used on many roadway construction and resurfacing projects to delineate lanes. They increase visibility and provide a tactile warning to drivers if they cross over the lines. Usually both paint and reflectors are used but ADOT could eliminate the paint and rely solely on the reflectors. Opportunity (C): Eliminate painting by inserting dry pigment into pavement when pavement is originally laid. This opportunity was previously selected for development as a goal by ADOT for the P2 Amendment submitted in 2000 which applied to the ADOT District II Grant Road facility only. If this is still a viable goal it should be expanded agency wide. This is a research opportunity for ADOT to determine if it is feasible to place the striping directly into the road surface thereby eliminating the use of paints and reducing or eliminating the need to repaint the roads over time. 10 Herbicides ADOT uses herbicides to control plant growth in the right-of-ways along state owned roads. Vegetation is controlled in these areas to increase visibility for drivers and to reduce the chances of vehicles striking animals. Herbicides are by their nature toxic chemicals, they not only affect the target weeds but also have various effects on nontarget plant species, animals and humans. By reducing the usage of herbicides or by reducing the potential exposure of non-target resources to the herbicides, ADOT can decrease their impact on the environment and human health. Opportunities A - C were previously selected for development as goals by ADOT for the P2 amendment submitted in 2000 which applied to the ADOT District II Grant Road facility only. They should be expanded agency wide. Opportunity A: Post notifications of spray application on roadways during use to reduce the risk of human exposure. By posting notifications in the area in advance of herbicide applications and for a period of time afterwards, human exposure could be reduced. People who use the area that is sprayed and the surrounding area may be exposed to airborne herbicide particles or droplets during the application. These same people may be exposed to herbicides after the application if they come in contact with the foliage that the herbicide was applied to. Opportunity B: In areas where high risk of human contact exists (i.e. where camping occurs within ¼ mile of the roadway), use physical means to remove unwanted plants (mowing, tilling, mulching, paving, planting short stature competitive ground cover). ADOT can eliminate the usage of herbicides in areas of high risk by using physical plant management methods. Established plants can be physically removed by mowing the plants to a desired height or tilling the plants into the soil. These techniques will control existing plants but will require repeated applications to continue control. Tilling can be followed by covering the right-of-way area with some form of ground cover (mulch, gravel, pavement) to restrict the future growth of plants in the area. Tilling can also be followed up with seeding the right-of-way with native short stature plants that will out compete the taller plants. Short plants do not pose the risk to drivers that tall plants do since they do not obstruct the drivers’ view. Opportunity C: Ensure materials are not spilled when trucks are filled with water by installing an automatic shut off valve or requiring an attendant to monitor the operation. When ADOT herbicide application vehicles are filled, herbicide is placed in the tank and then dilution water is added. Tanks can be overfilled resulting in a spill of herbicide solution. By installing float valves or some other automatic shutoff device to the water fill lines this problem can be eliminated. Another way to address this issue is to require someone to watch the filling process to ensure overfilling does not occur. 11 Opportunity D: Replace dicamba and 2,4-D with imazapyr (Trade names Arsenal or Chopper) The herbicides dicamba and 2,4-D are highly toxic chemicals that can have serious impacts on animals and humans. Both herbicides are used to control a broad spectrum of broadleaf weeds and woody plants. The herbicide imazapyr (CAS# 81334-34-1) is used for pre- and post-emergent control of grasses, broadleaf weeds, and woody plants and poses much less risk to animal and human populations. Imazapyr is also not listed as a “toxic substance” under the Arizona statutes. Information sheets on these three herbicides are presented in Appendix E. General grounds/storage Opportunity A: Use secondary containment. Implement regular storage area inspections, and be sure that a spill containment kit is available to employees. Toxic materials can be accidentally released into the environment during the loading and unloading of storage containers. Secondary containment should be provided for areas that could pose a substantial risk of releasing toxics into the environment in the case of an accident. For example, an underground "catch" can be built into a service bay where large such transfers take place. Following a spill, recovery is made considerably easier. Secondary containment not only keeps materials from entering the environment but may also allow for the recovery and reuse of the materials. 3.8. Tracking Mechanisms Certain data must be tracked over a period of time to allow for the determination of ADOT reporting requirements with regards to the Pollution Prevention Statutes. The data required to determine if an agency has used more than the threshold amount of a toxic substance include; (1) a list of items purchased, (2) the quantity and corresponding units of the items purchased, (3) details regarding the composition of those items, (4) a list of statutorily defined toxic substances, and (5) the individual allowed thresholds. To allow for easy threshold calculations a data collection and management system must be in place. An ideal system would first evaluate if a purchased item contained a toxic substance and if so would then record the information necessary to determine the amount of toxic substance purchased (number of items, size of items, content of toxic substances in each item). At the end of a specified timeframe (one year) the system would sum the purchases of each toxic substance to give a total purchase quantity for each toxic substance. ADOT currently records some information regarding all purchases made by the agency. Paper copies of purchase requests and invoices are submitted to a central processing location. Data from these sources are recorded in a computer database and the original hard copies are filed. This system is effective in tracking financial information, but does not easily support the collection of the information required to determine the amounts of toxic substances used by ADOT. The system does not necessarily have enough information to calculate total quantity purchased, nor does it record information regarding the composition or toxicity of the materials. The system currently does not provide for 12 unique identifiers for either materials or vendors; it allows multiple names for one vendor (i.e., prior names, full and shortened names) and allows multiple formats for the name of one material. In some instances this has led to a single purchase being given multiple records each with a different material or vendor name. Additionally a review of paper invoices revealed many cases where only the first of multiple items on an invoice was recorded in the database. Several things could be done to allow for easier extraction of the toxic use data from ADOT’s system. The first changes relate to the collection and entry of purchase data. These would require training data entry personnel to collect and enter the data properly and making modifications to the structure of the database: • • • • • • Require purchased quantities to be entered in a standard unit (i.e., pounds). Require the total quantity of material to be entered rather than the number of units. Restrict the unit of measure database field with the use of a pull down menu. Restrict the description field with a look-up table so that multiple descriptions are not used for a single material. Change the database linkages so that only one name is used for a vendor and only one record is generated for each purchase. Require that all items on an invoice or purchase order be entered into the system The second set of system reforms relate to collecting and recording information regarding the composition of the materials purchased. There are several options for collecting and tracking this data. All of the options require that MSDSs be collected for each material purchased. These MSDSs should be collected and filed in a central location. The following options are available: • • • Collect and enter information from MSDSs for each purchase. This requires an MSDS to be submitted with all invoices or purchase orders and for the data entry personnel to be able to locate the required data on the MSDS. Enter and link purchase names to MSDS data each time a new unique material is purchased. This would require a one time set up and then the required data would be automatically linked to the material. This would only require one person to be trained in MSDSs but would restrict data entry to a previously set up list. Purchase data can be collated with MSDS data off-line whenever a threshold determination is required. 3.9. Training Documents AMEC has developed two training documents for use by ADOT as part of the statutory pollution prevention - training program. The first is a graphic poster that is designed to remind employees that they are responsible for preventing pollution and waste and to encourage them to evaluate their current work habits. The second is an article that could be printed in the ADOT newsletter or disseminated in some other way on a regular basis. The article discusses the topics required by ADEQ: Definition of P2, the waste 13 management hierarchy, benefits of P2, and ADOT’s P2 Plan. Both documents are included in Appendix F. 14 4.0 CONCLUSION AMEC has completed the work under the Arizona Department of Transportation (ADOT) Purchase Order No. PGKS0843 for the project titled “Development and Evaluation of Hazardous Materials Inventory and Action Plan.” AMEC has determined that ADOT is required to file a Pollution Prevention Plan and associated documentation under Arizona Revised Statutes (A.R.S.) §49-961 through §49973, because ADOT is a state agency that did use more than 10,000 lbs. of a single toxic substance in a calendar year. AMEC has reviewed ADOT practices with regards to the use of the toxic substances that exceed one half of this 10,000 lbs. threshold and substances that are classified as PBT chemicals. AMEC has generated P2 opportunities for these materials and summarized them in a Pollution Prevention Plan Amendment. AMEC has also developed P2 training documents for ADOT’s use and recommended tracking mechanisms that ADOT could use to simplify the P2 filing requirement determination process. 15 BIBLIOGRAPHY AND REFERENCES 1. Pollution Prevention Amendment Guidance Manual. Arizona Department of Environmental Quality (ADEQ), 1999. [cited 15 February 2003]; Also available from the World Wide Web at: http://www.adeq.state.az.us/environ/waste/hazwaste/p2/plan.html 2. State of Arizona Numeric Table of Commodities. Arizona Department of Administration, State Procurement Office, 25 May 1999 [cited 15 February 2003]; Available from World Wide Web at: http://sporas.ad.state.az.us/download/docs/commodty.pdf 16 APPENDIX A Commodity Codes Selected for Review Due to size, a .pdf version of this file is not loaded on the Internet Link here to a WinZip file of Appendix A APPENDIX B Project Databases Due to size, a .pdf copy of this appendix is not loaded on the Internet. Link here to a WinZip file of Appendix B. APPENDIX C Purchase Records Removed from the Project Database Titled “Purchase Records Final” 67 This page intentionally left blank 68 PURCHASE RECORDS REMOVED FROM PROJECT DATABASE CLASS 69 075 SUB DESCRIPTION CLASS 66 OUT LAST BLK DA 6801 075 66 075 075 075 66 66 66 075 66 175 175 13 13 190 90 190 90 190 90 190 90 190 90 315 20 FLOOR CLEANER FOR SHOP AS PER TERRY SLUDER 7210 INVOICE NUMBER 02676883001 INVOICE # 0071903002. FOR INVOICE # 0452485001, WAS SENT TO WRONG ADDRESS AND JUST CML WASHER SOLVENT FOX WWS32 SPEEDY REAGENT (E-8801) CHEMICALS, LABORATORY (ACS, CP, PRACTICAL, REAGENT GRADE, ET SOLVENTS (NOT OTHERWISE ITEMIZED) SAXARR795-01 WINDSHIELD WASHER SOLVENT SAXARR795-01 WINDSHIELD WASHER SOLVENT ARR795-01 WINDSHIELD WASHER SOLVENT ARR795-01 WINDSHIELD WASHER SOLVENT ADHESIVE, GENERAL PURPOSE (795A OR 130244) QUANTITY UNIT VENDOR INVOICE DATE VI55145561 20010215 24 EA 176.250 EA DRUMMOND AMERICAN CORP NATIONAL CHEMICAL 261.500 740.210 946.150 EA EA EA CURTIS INDUSTRIES CURTIS INDUSTRIES CURTIS INDUSTRIES VI50276883001 VI50071903002 VI50452485001 20000323 19991123 20000629 36 GL VI520-023627 20010524 2 6.000 CS EA FACTORY MOTOR PARTS COMPANY L R KEROFSKY INC NU-TECH DIVERSIFIED VI5925 VI59774 20000925 20010314 1.000 GL RC5OV000001024 20001120 16 GL 12 GL 20 GL 12 GL 100.000 EA BORDER PRODUCTS CORPORATION FASTENERS PLUS INC DBA VANCO FASTENERS PLUS INC DBA VANCO FASTENERS PLUS INC DBA VANCO FASTENERS PLUS INC DBA VANCO BUNZL EXTRUSION TACOMA INC RC5MC69403459 20010705 VI53998 20001208 VI54016 20001212 VI52977 20000718 VI53727 20001030 VI50000035515 20010613 630 SUB DESCRIPTION CLASS 48 17456/SPRY MARKING GREEN 12 OZ 630 48 17459/SPRY MARKING WHITE 630 630 630 48 48 57 885 QUANTITY UNIT VENDOR INVOICE DATE 1 LB WOODLAND BUILDING CENTER INC VI5A400011150 20000830 1 LB VI5A600012541 20000829 2.000 20.280 36.000 GL AB GL 46 CANS OF PAINT SEAL SPRAY COATING PAINTS (NOT ITEMIZED HEREIN) (ACOUSTIC CEILING PAINT) U17950 ALLSTAR ODOR GUARD (40J1147) WOODLAND BUILDING CENTER INC TRUE VALUE HARDWARE AIRCOOL PAD SUNLIFE INC 16 GL VI543608485 885 46 U17950 ALLSTAR ODOR GUARD (40J1147) 20 GL 885 46 U17950 ALLSTAR ODOR GUARD (40J1147) 4 GL UNISOURCE CORP/TUCSON DIVISION UNISOURCE CORP/TUCSON DIVISION UNISOURCE CORP/TUCSON DIVISION VI5093644 20010406 VI547050 20010423 RC5DD000003174 20010117 20010406 RC5OV000001176 20010514 VI543693595 20010430 70 CLASS APPENDIX D Toxic Chemical Usage Report Due to size, a .pdf copy of this appendix is not loaded on the Internet. Link here to a WinZip file of Appendix D. APPENDIX E Training Documents Due to size, a .pdf copy of this appendix is not loaded on the Internet. Link here to a WinZip file of Appendix E. APPENDIX F Additional Data for Pollution Prevention Opportunities Due to size, a .pdf copy of this appendix is not loaded on the Internet. Link here to a WinZip file of Appendix F. 83