ER '97 Workshop 7 Pollution Prevention and Waste Minimization Principles

Objectives

To raise awareness and provide guidance in integrating pollution prevention (P2) into environmental restoration activities, to present case studies that demonstrate the viability of incorporating these P2 principles, and to discuss the benefits and results of applying P2 techniques in reducing waste volumes and overall project costs.

In addition, the workshop was designed to raise the awareness of and convince the workshop participants that incorporation of P2 and waste minimization principles into environmental restoration projects can be done successfully and results in added value (i.e., reduced waste volumes and lower waste management costs) which will contribute to achieving the goals of the Ten-Year Plan.

The workshop made clear that early integration of P2 and waste minimization concepts in project planning results in both successful reduction of waste volumes and lower waste management costs, and would be integral to the success of the Ten-Year Plan.

At the request of a full house of interested participants, the workshop was extended an additional hour, allowing eight presentations and meaningful interaction between the panelists and the audience.

PRESENTATION SUMMARIES

This section contains a brief summary of each panelist's presentation. Full presentation graphics or papers may be obtained by contacting the panelists.

P2 Concepts Used During the Oak Ridge K-25 Site Cooling Towers Demolition

Paul Larson
LMGS-OR

Paul Larson discussed the large-scale demolition project known as the K-25 Site Cooling Towers Demolition and focused on the development of a free-release protocol, which enabled the project team to characterize and release facilities and materials for recycle and reuse. The proactive, early P2 planning by the team resulted in cost savings of $3.5M (out of a $22M baseline estimate).

The Fernald Integrated Approach to P2 Utilization During Decontamination and Dismantlement Projects

Steve Hauser
Fluor Daniel Fernald

Steve Hauser presented a brief overview of the Fernald Environmental Management Project (FEMP) decontamination and dismantlement (D&D) planning process and how early considerations of P2 and waste minimization concepts and principles were incorporated up front to facilitate building debris disposition. Recycle and reuse examples, future opportunities for recycle of carbon steel, and issues surrounding the decision making processes for recycling versus other disposition options were also covered.

Nevada Test Site Application of P2 During Characterization Activities

Tom Wilczek
IT Corporation

Tom Wilczek discussed an underground storage tank remedial action at the Nevada Test Site (NTS). The project team formed a P2 working group and developed and implemented an inexpensive, innovative, and highly effective sampling tool to address sampling problems encountered during characterization activities. This sampling tool reduced the characterization costs by $17,000 and resulted in a large volume reduction of decontamination rinse waste and avoided excessive waste management costs.

Cost Savings Success via Lawrence Livermore National Laboratory's Cost-Effective Sampling Technique

Bill McConachie
Lawrence Livermore National Laboratory

Bill McConachie discussed Lawrence Livermore National Laboratory's (LLNL's) development and use of the Cost-Effective Sampling technique, which enables the sampling of ground water wells in a logical, clearly-defined manner so that sampling frequencies can be reduced (or modified) for wells that do not show a change in contaminant concentration over time. He provided strategies for dealing with the regulators on these types of issues. Results of applying this methodology at LLNL included 594 fewer samples collected, a 20,000-gal reduction in waste water volume, and FY 1996 cost savings of approximately $400,000.

Segregation Technology Reduces Waste Volumes for Formerly Utilized Sites Remedial Action Program

Jason Darby
Utilized Sites Remedial Action Program (Formerly)

Jason Darby discussed the application of the Segmented Gate System (SGS) technology at several Formerly Utilized Sites Remedial Action Program (FUSRAP) sites and explained the up-front evaluations performed to determine the cost effectiveness of implementing the technology. SGS separates (segregates) materials containing radioactive contamination from large volumes of excavated soil, resulting in large reductions in waste disposal volumes and waste management costs. For example, the New Brunswick Site achieved a 55% reduction in disposal volume and an estimated $1.2M cost savings.

Uranium Soil Cleanup - A Pilot Project Using the Segmented Gate System in Conjunction with Containerized Vat Leaching

Roy Michelotti
Los Alamos National Laboratory

Roy Michelotti discussed the combination of the SGS industrial process with the Los Alamos National Laboratory (LANL) Containerized Vat Leaching (CVL) technology to conduct a clean-up pilot project with the objective of generating cost and applications data to evaluate appropriateness at other larger sites. Significant cost savings over the conventional dig-and-haul approach resulted.

Beneficial Reuse of Metal from Special Metallurgical Building Demolition at the Mound Plant Results in Project Cost Savings

Gerry Maul
EG&G Mound Applied Technologies

Gerry Maul discussed the D&D of the Special Metallurgical Building and the integration of P2 techniques early in the planning phase of the project. He included how the project team evaluated the cost effectiveness of smelting the metal from the building demolition for beneficial reuse and how the team calculated the final cost avoidance. Smelting of 300,000 lb of steel for use as shield blocks at the LANL and the disposal at the NTS of only 37,000 lb of returned material resulted in project cost savings of $155,000 over baseline estimates.

Radiologically Contaminated Equipment Decontamination, Recycle, and Reuse at the Savannah River Site

Paul Huber
Bechtel Savannah River

Paul Huber discussed the use of a decontamination and recycle/reuse subcontract to clean heavy construction equipment that was contaminated during the closure of the M- Area Settling Basin. The cleaning of the equipment enabled the material to be either recycled or reused instead of disposed as low-level waste (LLW) or mixed waste. The best value approach generated project cost savings of more than $1M.

DISCUSSION SUMMARY

Extensive interaction occurred between the presentation panelists and the audience participants during this workshop, requiring an hour-long extension of the workshop. The combination of the successful application of P2 and waste minimization techniques presented by the panelists and the questions, answers, and exchange of information discussed with participants is captured as responses to the ten questions of the ER '97 workshops.

1.   What activity, position, approach, method of performance, etc., was successful and why?

The proactive, early P2 and waste minimization planning by the Environmental Restoration project teams resulted in significant volume reductions and cost savings. The following are examples.

1. Development of a Release Protocol
   To maximize the commercial recycle or disposal of materials from the demolition process, a protocol for release of facilities for recycle/disposal was developed for the K- 25 Site Cooling Towers Demolition Project. With the U.S. Department of Energy (DOE) and the State of Tennessee concurring on the protocol, the project team was able to decontaminate and subsequently determine that any radioactive contamination was below the regulatory requirements for these facilities, thus making them candidates for commercial recycling/disposal. This proactive planning resulted in free release of approximately 1,700,000 lb of nonradioactive scrap metal for recycling, netting approximately $2.5M in cost savings. The concrete rubble generated during demolition was used on site as fill material as part of a State-approved, unpermitted landfill, avoiding additional project costs for transporting and disposing of the concrete rubble. Without the up-front development, negotiation, and acceptance of the "free release" protocol, the cost associated with the traditional approach would have required the disposal of 5,500 yd3 of concrete rubble. With an estimated disposal cost for LLW of $27/yd3, the project's approach resulted in a cost avoidance of $148K. Also addressed was the handling of approximately 900,000 gal of free-standing water that had accumulated in the basins. The project team negotiated with the State to allow the use of this water for irrigation of grassy fields, thus saving approximately $870K. As a result of incorporating P2 and waste minimization early in the project planning, a total cost savings of approximately $3.5M was realized.

2. Improved Waste Management
   A detailed decision process for dispositioning debris resulting from D&D of Fernald buildings is part of the planning phase of each project. Secondary waste generation, including wash-down water and personal protective clothing, is estimated, and opportunities are evaluated to minimize the generation of these wastes. Structural steel and lead sheet metal have been decontaminated for free release. The conclusion is that the successful project cost reduction coincides with improved waste management.

3. Decontamination and Recycling
   Large contaminated equipment used during the closure of the M-Area Settling Basin at the SRS needed to be dismantled and disposed of because of the radiological hazard it posed. Decontamination and recycling/reuse resulted in significant cost savings and volume reductions. When compared with the dismantling and disposal option, decontamination and recycling/reuse saved more than $1M and reduced the projected waste volumes from 13,500 to 6 ft3 for LLW and from 1,200 to less than 50 ft3 for mixed LLW.

4. Smelting of Metal versus Disposal
   The cost of the conventional disposal approach for contaminated metal from D&D of the Special Metallurgical Building at the Mound Plant was estimated at $500K. Mound also evaluated and estimated the cost of smelting the metal and sending the secondary waste slag to the NTS. This cost was estimated at approximately $268K. The smelting option was selected. Approximately 300,000 lb of steel was smelted, 21,000 lb of aluminum scrap was compacted, and 16,000 lb of slag was generated. Total cost of this option was $395K for a total savings of $105K off the baseline estimate. Although the P2 and waste minimization alternative encountered a number of hurdles, the conclusion is that it was the cost-effective and environmentally correct way to go.

2.   What activity, position, approach, method of performance, etc., was unsuccessful and why?

New Waste Stream Through Cross-Contamination
During the discussion of the successful smelting experience at the Mound Plant, a member of the audience shared his melting experience on a FUSRAP project. In this case, overall project costs were increased because of the need to dispose of a new waste stream that was created from cross-contamination, thus making the beneficial reuse option less attractive.

3.   What new P2 and waste minimization concept(s) have been identified and applied, and what were the results?

1. P2 Information Management System
   The new P2 Information Management System developed and managed out of the Oak Ridge Operations Office tracks and documents P2 opportunities that result in cost savings from the avoidance or reduction of generated waste. P2 Opportunity Assessments are performed on waste-generating activities such as decommissioning or remediation to determine the most efficient use of resources. The system can be used to prepare performance measures, project update sheets, and required reports. The system has been tailored to ER projects and assists project managers in documenting successful P2 methods/techniques employed during the project.

2. Incentive Task Order Contracting
   The K-25 Site Cooling Towers Demolition Project work was performed using an Incentive Task Order Contract. Performance specifications allowed the contractors to be innovative. End results and project criteria rather than methods of accomplishment were specified. The project team issued clear and concise, integrated, project-specific procurement packages bound as one document. The integrated procurement package resulted in the average bids being within 1% of the DOE estimate. The three awarded bids were, on average, 28% lower than the DOE estimate. The estimated cost at completion of the project was $19M, resulting in a total savings to DOE of approximately $4M. The project was also completed three months ahead of schedule.

3. "Best Value" Contract for Decontamination Vendor
   Savannah River embarked on an effort to obtain the services of a commercial vendor to decontaminate and recycle/reuse the large equipment used for the M-Area Settling Basin closure. A competitive "best value" contract was awarded. The contract also included incentives that required the selected vendor to minimize to the maximum extent possible the volume of secondary wastes generated. This approach not only resulted in cost savings of more than $1M but also reduced the projected waste volumes from 13,500 to 6 ft3 of LLW and from 1,200 to less than 50 ft3 of mixed LLW.

4.   What new P2 and waste minimization technologies have been identified and applied, and what were the results?

1. Alternate Sampling Technologies
   During site characterization activities, NTS project personnel discovered approximately 40,000 gal of uncharacterized multiphasic substances in four 10,000 gal underground storage tanks. Drilling muds that had settled at the tank bottoms broke the composite liquid waste samplers, necessitating use of alternate sampling technologies. Acrylic samplers cost $1,200 each and would require decontamination after each use, increasing the volume of secondary waste. Project personnel consulted with a national laboratory metallurgist, who recommended commercial-grade copper pipe. For a total of $2,400, the team purchased copper pipe from a local supplier, cut it into 10-ft lengths, and equipped each section with check valves. They then installed one copper pipe device in each sampling location. Uncontaminated samplers were removed and reused. Contaminated samplers were left in the tanks until characterization was completed. Use of this sampling tool for this phase of the project reduced project costs by $17,000 and minimized waste stream generation. The technology is easily modified for application at other restoration sites.

2. Cost-Effective Sampling
   Sampling to evaluate contaminant migration and the effectiveness of cleanup generates large volumes of waste water that must be collected, transported, and treated before discharge. Additionally, it is difficult and time consuming to evaluate the data manually because of the large number of wells sampled and the amount of data collected. LLNL developed a Cost-Effective Sampling (CES) methodology and associated software for estimating the lowest monitoring well sampling frequency required to provide adequate data for remedial action and compliance-related decisionmaking. It resulted in a reduction of 35,868 gal of waste during the collection of ground water samples by reducing the amount of samples taken during the remedial investigation. The CES process saved approximately $400,000 in FY 1996 and has regulator and stakeholder concurrence.

3. Separation of Radioactive Soils
   During cleanup of a FUSRAP site in New Brunswick, NJ, approximately $1.2M was saved by applying the SGS to the contaminated soil cleanup. Designed and operated by Thermo Nuclean, this technology effectively separates materials containing radioactive contamination from large volumes of excavated soil. This application resulted in a 55% reduction in the amount of waste disposed offsite. At another FUSRAP site, the Middlesex Sampling Plant, of the 200 yd3 processed for the test, more than 90% met clean-up criteria. Use of this technology at Middlesex for large-scale cleanup could reduce remediation costs by 50% or more.

4. Separation and Leaching Technologies
   LANL combined the SGS process with CVL to conduct a clean-up pilot project. After 220 yd3 of contaminated soil was processed through the SGS and CVL, 211 yd3 was returned to the site as clean. Combining these technologies has the potential to save $46M to $52M for DOE if used for the remediation of the 100,000 yd3 swatches of contaminated soil at LANL. Larger sites, such as Mound and Fernald, are also looking at large-scale use of these technologies.

5.   For the subjects of P2 and waste minimization discussed, what issues were identified and how were they dealt with? What issues remain to be resolved and what approaches were proposed?

1. Internal Issues
   During the evaluation period for deciding between the conventional disposal approach for contaminated metal from the D&D of the Special Metallurgical Building at the Mound Plant and the smelting alternative, a number of issues/hurdles arose. Lawyers were concerned about the liability for the release of non-real Government property. This concern was resolved with the approach that all metal product would be shipped to LANL for use as shield blocks, and slag from the smelter would be returned to Mound for disposal. The purchasing agent wanted the work to be bid competitively, but no other bidders existed. Waste Management personnel were concerned initially because of the different waste form. This concern was resolved after a waste management audit was conducted at the smelting site.

2. External Regulator Issues
   Regulator acceptance and/or approval was necessary for use of the copper pipe sampling device at the NTS, the LLNL methodology to reduce sampling frequency, and the free-release protocol at the K-25 Site Cooling Towers Demolition Project. In each case, project personnel involved regulators in thinking through and planning the P2 and waste minimization opportunities, typically engaging them early in the project. Regulator concurrence resulted in each case.

6.   For the subjects of P2 and waste minimization, what decisions were made? What decisions remain to be made and what was recommended?

Early Integration of P2 and Waste Minimization in Project Planning P2 and waste minimization should be factored into the environmental restoration and D&D processes early on in the planning phase. P2 and waste minimization practices should be encouraged and required because of the measurable degree of success. Furthermore, the integration of P2 Opportunity Assessments into the environmental restoration and decommissioning processes is highly recommended because waste stream volumes would be minimized; results of P2 implementation would be measured properly, quantified, and documented for use on other projects; and negative impacts to human health and the environment would be decreased.

7.   For the subjects of P2 and waste minimization, what data are important and play a crucial role in the outcome? What data remain to be collected, and how is collection recommended?

1. Socioeconomic Evaluation
   If one refers to the Fernald decommissioning experience, materials potentially suited to recycling should be subjected to a detailed socioeconomic evaluation to document which disposition alternatives present the best balance of stakeholder preference, risk, and life-cycle cost. Stakeholder/regulator input continues to favor recycle/reuse options; however, site economics may prescribe disposal, particularly where on-site disposal cells are available.

2. Documentation/Tracking and Lessons Learned/Transfer of Info
   Understanding of the results and benefits of P2 and waste minimization principles should move beyond "anecdotal awareness," as a member of the audience characterized it, to demonstrable links between specific P2 and waste minimization activities and cost savings, risk reduction, environmental protection, and other positive outcomes. Data supporting these links should be collected and disseminated. Development of computer software, such as the tracking system under development at Oak Ridge, is part of the answer. Information exchange opportunities, such as this workshop, and publication of project results also contribute to the demonstration of beneficial results associated with P2 and waste minimization.

8.   For the subjects of P2 and waste minimization discussed, what next steps were identified and responsibilities assigned or advocated?

Because of the range of understanding for incorporation of P2 and waste minimization principles in environmental restoration and decommissioning activities, the workshop organizers assumed the responsibility of reviewing what has actually been formalized within the DOE Environmental Restoration system and evaluating the need to update and strengthen that which is already in place and disseminate it to the field. This activity will include looking at P2 and waste minimization tools for training, tracking, and information exchange that different sites either have in place or are developing to identify any with Environmental Restoration Program-wide application.

9.   For the subjects of P2 and waste minimization discussed, what agreements or disagreements were voiced? Was consensus reached on one or more positions (or opinions) for actions or approaches not yet taken?

1. Factor in P2 and Waste Minimization Early
   Workshop participants agreed fully that P2 and waste minimization principles should be factored into and evaluated in the environmental restoration and decommissioning projects early on to reap the largest cost savings to the Environmental Management complex.

2. Incentivize Contracts
   P2 and waste minimization incentives should be incorporated in environmental restoration and decommissioning project contracts to require contractors to plan consciously to reduce volumes of primary and secondary wastes destined for disposal.

3. Share Lessons Learned and Transfer Information
   Clean-up site workshops need to take place on a timely, regular basis to share successes and lessons learned, such as those discussed in this workshop. (See also responses to Questions 1 through 4.) Holding the ER '97 workshops in conjunction with the WM '97 Conference was a cost-effective method to accomplish this need. Subsequent site specific visits and relevant briefings on new P2 tools will also be necessary for in-depth discussions and viewing of the techniques at work.

4. Document and Track
   Workshop participants agreed that a system should be developed and implemented to facilitate the actual tracking and documentation of P2 and waste minimization processes. Site project personnel found it difficult at best to perform necessary tracking and documentation.

10.  What Departmental or other policies/procedures were explained in the workshop?

Policies Used
The K-25 Site Cooling Towers Demolition Project team used DOE Order 5400.5, NUREG 1.86, and NUREG 5849 as bases for the development of the protocol for radiological release of facilities for recycle/disposal. This step was taken to maximize the commercial recycle or disposal of materials from the demolition process. The project was able to recycle scrap metal commercially, reuse concrete rubble, and cost effectively handle large volumes of basin water, resulting in a total cost savings of approximately $3.5M.

CONCLUSION

P2 and waste minimization principles have been applied to environmental restoration and decommissioning projects and have been both successful in reducing large volumes of wastes destined for disposal and effective in reducing waste management costs. P2 and waste minimization should be incorporated early in the project planning process by thoroughly integrating the concepts into the project teams and evaluating forecasted waste streams for P2 and waste minimization opportunities. Documentation and dissemination of successful (and not so successful) methods and techniques to other sites performing cleanup are also necessary to demonstrate the links between P2 and waste minimization activities and their results. With the inclusion of P2 and waste minimization concepts into environmental restoration and decommissioning projects, DOE can reduce significantly the amount of primary and secondary wastes that require treatment and disposal. This action would, in turn, reduce risks to the workers, the public, and the environment, and lower overall project and DOE waste management costs, ultimately contributing to the success of the Ten-Year Plan.

REFERENCES

Complex Wide Study on the Successful Integration of Pollution Prevention into the Environmental Restoration Program, U.S. DOE, Office of Environmental Restoration, Executive Summary and Vols I and II, IT Corporation, September 31, 1996.

Pollution Prevention and Waste Minimization Guidance for Environmental Restoration Activities, U.S. DOE, Office of Environmental Restoration, May 1995.

Brochure on the Pollution Prevention Information Management System, U.S. DOE, Office of Pollution Prevention, Lockheed Martin Energy Systems, 1997.

Video, Tooling Up for Success Integrating P2 into ER, U.S. DOE, Office of Environmental Restoration, Bechtel Nevada Remote Sensing Laboratory Video Services, 1996.

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