Pollution Prevention and Waste Minimization as a Performance Enhancement Mechanism

The need to seek and find productivity enhancements to accelerate site cleanup and to meet goals set forth in the Department of Energy's (DOE) Strategic Plan and DOE's Environmental Management's 2006 Plan is a challenge that faces project managers daily. This challenge is further heightened by the lack of guidance and direction on techniques and approaches available to accomplish the goals.

Pollution prevention (P2) has been identified as a mechanism for achieving reduced cleanup costs through reduced waste volumes and reductions in associated disposal costs. In accomplishing this end, project managers in the environmental restoration program should combine effective project management with proven P2 and waste minimization (WMin) techniques to help meet cost reduction goals and efficiency targets. This can be done by routinely using a set of readily-available products and decision-making aides designed for environmental restoration (ER) project managers and teams in optimizing environmental restoration projects by the application of P2. These P2 aides were developed by Department of Energy's Headquarters and various Operations/Field Offices and provide ER personnel with the tools for improving overall cost effectiveness for ER projects.

The P2 aides discussed in this paper will be placed into an ER project time-table and will identify the most effective time frame to apply the tools and techniques. Examples of successful applications will be included in the discussion. P2 aides which will be highlighted include the following:

• P2 awareness training for ER personnel;

• Guidance Documents and P2 Users Guides to identify P2/WMin opportunities during cleanup projects;

• Waste Disposition Maps for identifying and forecasting high quantity waste volumes where application of P2 will result in high return on investment;

• Information exchange mechanisms;

• Tracking systems for monitoring overall performance in P2 and successes in achieving goals.

The objective of this paper is to identify a series of decision points during an ER project, utilizing the above aides, to provide project managers with a framework for easily assessing or reassessing opportunities for minimizing waste volumes. These aides, when seamlessly integrated into cleanup projects, will help to achieve a cost effective path forward for project personnel and provide documented performance enhancements.

Introduction

The Department of Energy (DOE) through congressional and public mandate has had to seek out and employ innovative techniques and methods to reduce the staggering cost for environmental cleanup activities. These techniques and methods must be evaluated and proven to generate significant cost savings while meeting accelerated project schedules and regulatory requirements. The paradox to this challenge is the fact that cleanup projects typically generate large amounts of waste and thus require substantial dollars for waste management. This paper will illuminate when and how cleanup projects can and should be evaluated for pollution prevention (P2) and waste minimization (WMin) opportunities from the outset of project planning in order to maximize project savings.

The "Accelerating Cleanup, Paths to Closure" (1) document has estimated that the current life-cycle cost of cleaning up the DOE complex is approximately $147 billion. Waste volumes have been estimated at over 30 million cubic meters. These numbers in themselves have caused DOE management to look for tangible opportunities to reduce costs and manage the cleanup more efficiently. The Paths to Closure document stipulates that P2 should be among six mechanisms identified to achieve enhanced performance measures and project efficiencies.

The DOE has recognized the value of integrating P2 concepts into cleanup activities for several years. The Complex-wide Study of the Successful Application of P2 into Environmental Restoration (ER) Activities" (2) completed in 1996 by EM-40, provided the basis for understanding how and when P2 and WMin can be incorporated into a project. This document contained 92 case studies of ER projects (remediation, transition, decommissioning, decontamination and dismantlement) which utilized a myriad of techniques to reduce waste volumes. This document, when coupled with EM-40's "Guidance for Incorporating P2/WMin into ER Activities", circa 1995 (3), provides a cornerstone in which to build a useful process for project personnel to use to routinely evaluate P2/WMin value.

A specific action taken by DOE to encourage the incorporation of P2 into all activities was to include P2/WMin as an objective in the 1997 DOE Strategic Plan (4). The Strategic Plan is the highest tier of planning for the Department. It sets the goals, objectives and strategies that will be implemented within the Department through the Annual Performance Plan, budget, and the Performance Agreement the Secretary has with the President. The P2 objective states that the DOE must "prevent future pollution". To accomplish this objective, the illustrative measure to "reduce secondary waste generation from cleanup and stabilization activities by 10 percent annually, beginning in FY 1999" was established. This measure provides the incentive for project managers to begin to evaluate and deploy technologies and techniques which will improve productivity and reduce life-cycle costs of their projects.

The body of this paper will discuss a structured, logical process to assess the potential for incorporating P2/WMin during each phase of a remediation and/or decommissioning project. Numerous linkages, tools and resources will be discussed and provided in a process framework which can be systematically used during each cleanup project. The information needed by project managers and project teams to utilize this process will be consistent from project to project but the user approach and interfaces may be different.

Process

The following process was designed to facilitate the incorporation of P2 principles and tools into the specific stages or phases of a project.

The environmental restoration process (both decommissioning projects as well as remediation projects) can be logically broken down into four phases; in this paper these are called project phases. Phases include; Negotiations and Planning; Assessment; Evaluation and Selection; and Implementation. These in turn can be further broken down into sub-phases or tasks.

It is important to lay out a logical sequence for project managers and project team members to follow when looking for ways to reduce large volume, high cost waste streams. This is done by looking at each project phase separately and identifying the normal sequence of actions used to evaluate potential P2/WMin initiatives. Each project phase is discussed below along with the appropriate and relevant P2 action that should occur and the P2 tool which can be used to execute the action.

Negotiations and Planning

The planning phase of projects offers the most valuable (higher percentage of cost saving potential) opportunities for P2/WMin. Once the regulators and stakeholders have determined that a cleanup project should commence, the project manager should assemble a project team. The team should consist of qualified ER and waste management professionals who will drive, review, and direct the project activities. The project manager and team will influence the integration of P2/WMin into project work and should be fully trained, using the training modules "P2 Training Modules for Project Managers and Project Teams" (5), on the benefits of P2 and the methods for incorporating P2 techniques into the process.

The training modules are tools which have been developed by EM-40 to provide environmental restoration personnel with the P2/WMin tools and resources needed to reduce waste generation during a project and achieve cost savings and project efficiencies. The project manager module is focused on the concerns that a manager may have such as cost, schedule and regulatory compliance issues. The training provides the managers with the information needed to document P2/WMin successes; incorporate P2 into contract language and procurement initiatives; promote P2 within the project; and link and reference applicable documents, Web sites, and case studies. The training is short; approximately 30 minutes.

The project team module includes more in depth discussions on techniques and methods for incorporating P2/WMin into each project phase and provides the necessary linkages between actual project activities and P2 opportunities. A video is also shown during the training to highlight several projects which utilized P2 principles to realize cost savings. The project team training runs approximately two and one-half hours.

The project team, as well as the project manager, should also utilize the Sustainability Support Guidance Document as a framework for executing a project while incorporating P2/WMin into each phase.

The project team can utilize numerous other documents such as site historical information and past activity documentation to develop a project plan where the project scope, cost, and schedule are outlined. At this point, forecasted waste generation data should be updated, reviewed and studied for potential P2/WMin opportunities. By studying this information, high volume, highly regulated wastes can be identified for future evaluation for reduction.

Waste and Material Disposition Maps provided as part of the Paths to Closure (1) can be used to understand the sites conceptual approach to managing wastes, nuclear materials and contaminated media. Other information sources on forecasted waste volumes include the EM-40 Core Database and the Integrated Project, Accounting and Budgeting System (IPABS). Several material/waste management models are available or are being developed which will provide credible and detailed waste volume estimates (primary and secondary) and the associated cost estimate based upon the approved project scope. The waste treatment, and disposition option scenarios can be varied in order to view the change to waste volumes and cost.

During the project negotiations phase with the regulators, the project team should have a clear definition of the cleanup standard to be met and, if appropriate, the approved release criteria. These two items directly affect the amount of material/waste which will be removed, decontaminated, treated, and/or disposed. Careful consideration should be given to these discussions and the ideas of risk-based closures, flexible Records of Decisions, and the approval of a free-release standard should be arbitrated. The Sustainability Support Case Study Database (2) can be used to identify examples of successful P2/WMin integration efforts from across the complex. All of the decisions reached, as well as P2 techniques and methods decided upon, should then be integrated into the project procedures.

Table 1 summarizes the P2 tools available during planning phase activities.

Assessment

During the Assessment Phase of projects, it is important for the project team to thoroughly evaluate all sampling and analysis and characterization procedures and techniques for reducing secondary waste generation. This phase of a project offers opportunities to directly affect the amount of investigative-derived waste (IDW) generated by utilizing segregation techniques, modifying decontamination procedures, evaluating statistical sampling methods, using innovative sampling and drilling techniques, and employing sound engineering practices.

The use of the Sustainability Support Case Study Database (2), the Argonne WMin Handbook (6), and the DOE Lessons Learned Database (7) will assist project teams in identifying successful techniques deployed during similar projects throughout the complex.

The Environmental Restoration P2 Information Management System (ER P2 IMS) (8) should be used to track actual waste reductions against the projected waste volumes. This will provide a means to report successful waste minimization and P2 activities in DOE's Annual Report of Waste Generation and P2 Progress (9) as well as progress towards the secondary waste reduction goal.

Table 2 summarizes the P2 tools available during assessment phase activities.

Evaluation and Selection

The evaluation and selection phase of a project consists of evaluating the most effective remedy for cleaning a contaminated site or building and determining what treatment method will be used. Waste reduction opportunities should also be evaluated with regard to secondary waste generation during bench- or pilot-scale treatment operations and during the evaluation of cost-effective recycle/reuse options for waste materials.

Several P2 tools can be utilized to perform these evaluations. A Pollution Prevention Opportunity Assessment (PPOA) can be performed on the selected treatment technology to determine the opportunities for eliminating or reducing secondary waste generation. The PPOA Database (10), TechKnow Database (11), and the Preferred Alternatives Matrix (12) can also be used as resources for identifying potential P2/WMin techniques which have proven successful.

The Life-cycle Decision Methodology (13) developed by Oak Ridge National Laboratory is a decision-aiding framework used to support P2 decision-making for the disposition of materials. The Decision Methodology identifies and assesses all of the impacts (benefits and costs) that result from a course of action over an entire period of time affected by the action. This methodology has been successfully applied at several sites to support the decision to recycle/reuse structural steel, copper, scrap metal., soil, and concrete.

ALARA and RESRAD-RECYCLE (14) analysis provides the risk calculations needed to support the decision methodology such as analysis of exposures and risk (collective dose). Using these two tools will enable a project team to objectively defend decisions of recycle/reuse disposition options.

Table 3 summarizes the P2 Tools available during evaluation and selection phase activities.

Implementation

Finally, the project will move into the implementation phase which is actual field activities. This is where all of the previous planning for waste reductions is tested. Contracts are usually issued at this time to employ the services of a subcontractor. It is important to include P2 language in these contracts to ensure that all subcontractors are aware of P2 requirements. Adding incentives to the contract for accomplishing actual waste reductions and tracking of these successes can result in contractors exhaustively seeking ways to minimize wastes. DOE has collected standard P2 contract language which can be accessed from the DOE P2 webpage.

Re-evaluating work procedures and practices is essential prior to commencing the work and on a daily basis. Using the P2 in ER Case Study Database, DOE's Lessons Learned Database, and the D&D Users Guide (15) numerous opportunities can be identified such as shrinking the size of contaminated areas by decontamination, controlling the access to contaminated areas, using washable PPE, evaluating waste packaging procedures to ensure optimization, and segregating all materials and wastes.

The ER P2 IMS should be used to track successful waste reductions (primary and secondary) against the project baseline. This will provide a method for retrieving this information for reporting purposes as well as assessing progress towards the secondary waste reduction goal.

Table 4 summarizes the P2 tools available during implementation phase activities .

Conclusions

The P2 tools identified in the previous tables provide methods and links to assist ER project managers and project teams with identifying P2/WMin opportunities. Executing these opportunities are an important component of each cleanup project and provide DOE with cost savings and the attainment of enhanced performance.

ER project managers and project teams are responsible for establishing and catalyzing a P2 and waste minimization mind-set during cleanup activities and should be innovative when examining ways to reduce waste. Each member of a project team should be cognizant of the following:

• Evaluating for P2/WMin opportunities should be routinely performed during each phase of a cleanup project

• Taking advantage of the P2 tools which exist will provide project teams with the means to identify and apply P2/WMin

• Achieving savings from implementing P2/WMin is worth the effort and should be documented

• Meeting efficiency targets as well as DOE-wide and site specific P2 goals is the responsibility of the ER project manager and project team

• Employing P2/WMin exhibits environmental stewardship and professional responsibility to the regulators, the stakeholders and the public.

When project teams use the P2 tools which have been developed and described in this paper, the project will realize cost and schedule efficiencies and will establish a linkage to other sites by building upon each others successes and initiatives.

References

1. US DOE. Accelerating Cleanup Paths to Closure. Washington, DC: Office of Environmental Management; February 1998.

2. US DOE. Complex-wide Study on the Successful Integration of P2 into ER Activities (Volume 1), Case Studies (Volume 2). Washington, DC: Office of Environmental Restoration; October 1996.

3. US DOE. Pollution Prevention and Waste Minimization Guidance for Environmental Restoration Activities. Washington, DC: Office of Environmental Restoration; May 1995.

4. US DOE. Strategic Plan:  Providing America with energy security, national security, environmental quality, science leadership. Washington, DC: DOE; September 1997.

5. US DOE. P2 Training Modules for Project Managers and Project Teams. Washington, DC: Office of Environmental Restoration; May 1998.

6. US DOE. WMin Handbook, Volume 1. Argonne National Laboratory: 1996.

7. US DOE. Lessons Learned Database.

8. US DOE. ER P2IMS Database. Oak Ridge, DOE.

9. US DOE. Annual Report of Waste Generation and Pollution Prevention Progress. Office of Environmental Management; Yearly.

10. PPOA Database;

11. TechKnow;

12. Preferred Alternatives Matrix;

13. K.L. Yurako, et.al., A Life Cycle Decision Methodology for Recycle of Radioactive Scrap Metal. 1997.

14. US DOE. Handbook for Controlling Release for Reuse or Recycle of Non-Real Property Containing Residual Radioactive Material.

15. US DOE. P2/WMin Users Guide for Environmental Restoration Projects. DOE's Ohio Field Office, 1998.

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