Pollution Prevention

Draft 1/11/2006

FUNCTIONAL AREA GOAL: Demonstrate and confirm that the Department of Energy (DOE) and DOE contractors are operating facilities and conducting activities consistent with DOE P2 policies, requirements, and guidance to reduce or eliminate the generation of waste, the release of pollutants to the environment, and the use of Class I ozone-depleting substances (ODS) through source reduction including segregation and substitution, re-use, recycling, and sustainable development, and by procuring environmentally preferable products and services pursuant to the DOE P2 and Sustainable Environmental Stewardship goals. (Source: O 450.1 §4.b(3), O 450.1 CRD §2(c), ISO 14001)

These DOE goals are to protect the environment and enhance mission accomplishment through waste prevention, reduction of environmental releases, environmentally preferable purchasing, incorporating environmental stewardship in program planning and operational design, and post-consumer material recycling. (Source: O 450.1, Attachment 3)

REQUIREMENTS:

GUIDANCE:

PERFORMANCE OBJECTIVE 1: Contractor Program Documentation

Contractor EMS adequately documents the protocols, policies, and procedures that will ensure that P2 is integrated in facility operations in order to achieve the DOE P2 and Sustainable Environmental Stewardship goals.

Criteria:

  1. ISMS descriptions are updated to include an EMS that incorporates P2. (Source: O 450.1 CRD §3)
     
  2. The EMS/ISMS includes protocols for the systematic planning, integrated execution, and evaluation of P2 in contractor activities. (Source: O 450.1 CRD §1(a))
     
  3. Processes are in place to ensure that CRD P2 requirements flow down to subcontractors to the extent necessary to ensure contractor compliance with CRD requirements. (Source: O 450.1 CRD preamble)

Suggested lines of inquiry and review approach for this performance objective

PERFORMANCE OBJECTIVE 2: Contractor Program Implementation

Contractor adequately demonstrates that P2 is integrated into site activities by incorporating P2 operational assessments, objectives, and measurable targets in the site EMSs; integrating operational assessments in work planning processes; and developing and implementing programs that contribute to achieving the Department's P2 and Sustainable Environmental Stewardship goals.

Criteria:

  1. Operational assessments, such as pollution prevention opportunity assessments, of site operations are planned and conducted to identify opportunities for source reduction including material segregation and substitution, recycle/reuse, or other P2 projects. (Source: O 450.1 CRD §9)
     
  2. Cost-effective P2 projects, derived from operational assessments and the use of life-cycle assessment concepts and practices to determine return-on-investment, are implemented. (Source: O 450.1 CRD §9)
     
  3. Work is performed in a manner that ensures adequate protection of the environment. Contractors ensure that pollution prevention and waste minimization become an integral part of the contractor's work planning and execution processes. (Source: 48 CFR 970.5223-1)
     
  4. Acquisitions, as appropriate, are coordinated with the DOE operations/field/site office "Green Acquisition Advocate." (Source: O 450.1 CRD §8)
     
  5. Specifications for and acquisition of supplies cost effectively maximize procurement of recycled-content and biobased-content materials, and other environmentally preferable products and services. (Source: O 450.1 CRD §8; RCRA §6002; 48 CFR 970.5223-2)
     
  6. Programs and procedures to maximize the use of safe alternatives to ozone depleting sources (ODS) (Source: 48 CFR 23.803) are developed to ensure that the procurement of Class I ODS for all nonexcepted uses is discontinued by December 31, 2010. (Source: O 450.1 CRD §12)
     
  7. Environmentally and economically beneficial landscape practices are incorporated into all new landscaping programs, policies and practices for facilities, as appropriate. (Source: O 450.1 CRD §6)
     
  8. Reports and plans required under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Pollution Prevention Act (PPA) are developed and submitted to the proper authority. (Source: O 450.1 CRD §13; EPCRA §313; PPA §6607)
     
  9. Progress is made in reducing or eliminating the generation of waste, the release of pollutants to the environment, and the use of Class I ODS through source reduction including segregation and substitution, re-use, recycling, and sustainable development, and by procuring environmentally preferable products and services is monitored and information is made available annually to the DOE operations/field/site office. (Source: O 450.1 CRD §7)
     
  10. Processes are in place to ensure that CRD P2 requirements flow down to subcontractors to the extent necessary to ensure contractor compliance with CRD requirements. (Source: O 450.1 CRD preamble)
     
  11. The EMS/ISMS includes protocols for the systematic planning, integrated execution, and evaluation of P2 in contractor activities. (Source: O 450.1 CRD §1(a))

Suggested lines of inquiry and review approach for this performance objective

PERFORMANCE OBJECTIVE 3: P2 Oversight and Requirements

Programs, protocols, and resources are in place for assuring appropriate contractor oversight and completing P2 requirements incumbent upon DOE elements.

3.1 Line Management Oversight of Contractor Integration of P2: Line management ensures that contractor EMSs and activities at sites under their purview provide for the systematic planning, integrated execution, and evaluation of P2 and the monitoring and reporting of their progress in achieving the P2 and Sustainable Environmental Stewardship goals.

Criteria:

  1. All necessary actions are taken to integrate environmental accountability into agency day-to-day decision making and long-term planning processes across all agency missions, activities, and functions. (Source: EO 13148 §101)
     
  2. Centralized procurement and distribution programs for purchasing, tracking, distributing, and managing materials with toxic or hazardous content are implemented, where appropriate. (Source: O 450.1 §5.d(5))
     
  3. Environmentally and economically beneficial landscape practices are incorporated into all new landscaping programs, policies, and practices, where appropriate. (Source: O 450.1 §5.d(4); EO 13148 §§601 and 704)
     
  4. P2 progress is monitored and reported to EH-1. (Source: O 450.1 §5.d(9))
     
  5. Contractor ES&H performance objectives, performance measures, and commitments include appropriate environmental elements based on the environmental risks, impacts of activities at the site, and the Departmental P2 and Sustainable Environmental Stewardship goals. (Source: O 450.1 §5.d(17))

Suggested lines of inquiry and review approach for this performance objective

3.2 Headquarters Oversight of Contractor Integration of P2: Headquarters management (e.g., PSOs, NNSA and Power Administration Administrators) ensures that EMSs at sites under their purview provide for the systematic planning, integrated execution, and evaluation of P2 in site activities and the reporting of their progress in achieving the P2 and Sustainable Environmental Stewardship goals.

Criteria:

  1. Sites include site-specific goals in their ISMS that contribute to the accomplishment of the DOE P2 and Sustainable Environmental Stewardship goals. (Source: O 450.1 §5.c(3))
     
  2. Sites develop and implement cost-effective P2 programs that use life-cycle assessment concepts and practices in determining program return-on-investment (ROI). (Source: O 450.1 §5.c(3); EO 13101 §§101, 601, 705; EO 13148 §304)
     
  3. Sites monitor their P2 progress and report it to EH-1. (Source: O 450.1 §5.c(5))
     
  4. EMS implementation is assessed. (Source: O 450.1 §5.b)

Suggested lines of inquiry and review approach for this performance objective

3.3 Line Management Requirements to Ensure P2 Integration

Line management (i.e., operations/field/site office managers) satisfies its requirements related to the systematic planning, integrated execution, and evaluation of P2 in site activities and the reporting of progress in achieving the P2 and Sustainable Environmental Stewardship goals.

Criteria:

  1. Contracting officers are notified as to the contracts which must include the CRD. (Source: O 450.1 §3.b(3))
  2. Operational assessments, such as pollution prevention opportunity assessments, of site operations are conducted to identify opportunities for source reduction including material segregation and substitution, recycle/reuse, or other P2 projects. (Source: O 450.1 §5.d(6))
  3. Cost-effective P2 projects derived from operational assessments are implemented. (Source: O 450.1 §5.d(6))
  4. Life-cycle assessment concepts and practices are used to determine return-on-investment for P2 projects. (Source: O 450.1 §5.d(6))
  5. Site annual budgetary processes include the funding and resources necessary to implement and monitor site P2 activities. (Source: O 450.1 §5.d(7); EO 13148 §301)
  6. Programs and procedures are developed and implemented to maximize the use of safe alternatives to ODS whereby procurement of all Class I ODS for all non-excepted uses is discontinued by December 31, 2010. (Source: O 450.1 §5.d(10))
  7. Acquisitions are coordinated with the Department's "Green Acquisition Advocates." (Source: O 450.1 §5.d(12); EO 13101 §102)
  8. Specifications for and acquisition of departmental supplies incorporate P2 to cost effectively maximize procurement of recycled content and biobased content materials, and other environmentally preferable products. (Source: O 450.1 §5.d(11); EO 13101 Parts 4 -6; RCRA §6002)
  9. Reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA), and the Pollution Prevention Act (PPA) are satisfied. (Source: O 450.1 §5.d(13); EO 13148 §501; EPCRA §313; PPA §6607)

Suggested lines of inquiry and review approach for this performance objective

3.4 Headquarters Elements' Requirements to Ensure P2 Integration

Headquarters elements satisfy requirements related to the systematic planning, integrated execution, and evaluation of P2 in site activities and the reporting of progress in achieving the P2 and Sustainable Environmental Stewardship goals.

Criteria:

  1. All necessary actions are taken to integrate environmental accountability into agency day-to-day decision making and long-term planning processes across all agency missions, activities, and functions. (Source: EO 13148 §101)
     
  2. All site/facility management contracts involving activities associated with the use, storage, disposal and transportation of waste; emissions to air; discharges to water; and management of cultural and other natural resources include the CRD, as appropriate. (Source: O 450.1 §3.b(1); EO 13101 §701)
     
  3. The CRD is incorporated in contracts via the laws, regulations, and DOE directives clause of the contract for all applicable contracts. (Source: O 450.1 §3.b(3))
     
  4. Clauses requiring a waste reduction program are contained in solicitations and contracts for contractor operation of government-owned or government-leased facilities and solicitations and contracts for support services. (Source: 48 CFR 52.223-10)
     
  5. Environmental protection directives, policies, guidance, requirements, and procedures are developed or revised by EH-1 to maximize the use of safe alternatives to, evaluate present and future uses of, and disseminate information regarding successful efforts to phase out ODS. (Source: O 450.1 §5.a(1); EO 13148 §505)
     
  6. Directives, policies, and documents are developed or revised by the Office of Management to ensure procurement policies and procedures encourage the Department's acquisition of recycled-content and biobased-content materials, and other environmentally preferable products and services. (Source: O 450.1 §5.g(2)).
     
  7. Training is provided to ensure awareness of the requirements of EO 13101 and EO 13148. (Source: EO 13101 §801(b); EO 13148 §§404.a and 701.a)
     
  8. Agency environmental directives, policies and documents incorporate the goals and requirements of EO 13148 by April 2001. (Source: EO 13148 §305)
     
  9. Internal agency-wide awards program are developed to reward and highlight innovative programs related to the goals of EOs 13101 and 13148. (Source: EO 13101 §802; EO 13148 §403.b)
     
  10. "Best in class" recipients from site P2 nominations are selected by PSOs and NNSA and Power Administration Administrators. (Source: O 450.1 §5.c)
     
  11. Annual corporate reports demonstrating progress in implementing EO 13101 and EO 13148 are prepared by EH-1. (Source: O 450.1 §5.a(2)(b); EO 13101 §302(b))
     
  12. Funding and resources needed for the systematic planning, integrated execution, and evaluation of P2 and to address the findings from oversight and self-assessment activities conducted pursuant to DOE P 450.5 are requested through the annual Departmental budgetary process by PSOs and NNSA and Power Administration Administrators. (Source: O 450.1 §5.c(2))

Suggested lines of inquiry and review approach for this performance objective



< BACK TO PREVIOUS PAGE