Y-12 has implemented an effective Environmental Management System (EMS) that drives continual improvement by fully integrating pollution prevention (P2) into Y-12 operations. This is evidenced by the numerous P2 initiatives completed in Fiscal Year (FY) 2006. In FY 2006, Y-12 implemented 84 pollution prevention initiatives to reduce more than 138.6 million kilograms (more than 305.6 million pounds) of waste, and realized a cost savings/avoidance of almost $5.73 million. Y-12’s EMS drove not only ‘classic’ P2 projects for source reduction and recycling, but also included projects to integrate sustainability principles to conserve energy and habitat, and projects to maximize use of recycled-content products and bio-based fuels. In FY 2006, more than 4 acres of native grasslands and native wetlands were established at Y-12, and more than $1.14 million of products with recycled content were purchased. Y-12’s Kathene waste management project is an excellent example of this EMS-driven continual improvement that uses a life cycle approach to not only reduce wastes, but also streamline operations to improve efficiency, greatly reduce compliance liabilities and reduce the paperwork, labor and cost of managing and disposing waste.

Y-12’s Kathene project focused on streamlining the process for handling, managing, characterizing and disposing of used Kathene (lithium chloride) and Tri-solv (Resource Conservation and Recovery Act [RCRA] wastes). A team consisting of representatives from two Manufacturing organizations (Assembly and Special Materials), Waste Management, Environmental Compliance, Plant Services, and the Y-12 Pollution Prevention Program and Bechtel Jacobs worked together to develop and implement the streamlined process. The initiative reduced labor and sampling costs and wastes, as well as the risks and compliance liabilities related to accumulating RCRA wastes and potential container failures and spills. The improvement opportunity was identified and process developed using P2 techniques embedded in the Y-12 EMS.

P2 techniques are embedded within several elements of the Y-12 EMS. First, P2 habits are positively reinforced by designing the EMS aspect identification process in such a way that encourages facilities and organizations to list their P2 successes as positive environmental aspects and impacts during EMS Planning activities. Second, measurable EMS objectives and targets for recycling, waste reduction, environmentally preferable purchasing, bio-based fuel use, elimination of ozone depleting substances, and sustainable design integration, and other initiatives to improve efficiency and reduce compliance liabilities are formally established and tracked. Finally, P2 and sustainable design principles (such as conducting P2 operational assessments using a life cycle approach to problem solving) are ‘institutionalized’ into the Y-12 culture by continually posting P2 awareness articles on the Y-12 home page, maintaining a P2 web-site for easy access to all facets of P2, green products and sustainable design, and issuing written procedures for recycling, P2, and green purchasing that are required to be used by all Y-12 employees.

The Problem:
Kathene/Tri-solv waste is generated by maintenance activities on five Kathabar units that are filled with the Kathene solution (lithium chloride and water) and are used in Y-12 Manufacturing areas (Assembly and Special Materials) for dehumidification and air conditioning. Used Kathene requires annual change out and cleaning with Tri-solv, which generates additional rinse-water. More than 1,600 gallons of the used Kathene/Tri‑solv solution is generated per unit with every change-out (approximately 8,000 gallons annually).

In the past, the used Kathene/Tri-solv was dispositioned in an inefficient multi-step process involving numerous drums, samples and related paperwork, multiple handling steps and interim storage and weekly RCRA inspections. The waste solution was transferred from Kathabar units into lined 55-gallon metal drums. The drums were then placed on pallets and transferred to a 90-day RCRA accumulation area awaiting analytical sampling results. Samples were composited from each pallet of drums and sent for analysis (total radioactive activity, uranium isotopes, toxicity characteristic leaching procedure [TCLP], pH and flashpoint). A UCN-2109 form was prepared and processed for each drum (typically nearly 100 drums were prepared per shipment). The drummed waste remained in the 90-day area until pickup by the offsite Hazardous Waste vendor. New lined metal drums had to be reordered and purchased for every clean-out event.

The Solution
During EMS planning activities, the multi-organizational Kathene project team identified the Kathene/Tri-solv waste stream as a significant environmental aspect of their operations which would be worthy of setting an EMS objective and target for continual improvement. The multi-organizational team analyzed the waste stream using life cycle principles with consideration of the full range (cradle to grave) of applicable environmental cost elements including materials, packaging, sampling, environmental health and safety management and administrative labor, and disposal costs. The Kathene/Tri-solv waste stream had been minimized in previous efforts so no feasible option for eliminating or further reducing the RCRA waste stream is currently available. However, using the life cycle approach to problem-solving, the team identified several opportunities to streamline the management process. The team developed and implemented a strategy to bulk the used Kathene/Tri-solv waste in a tanker as opposed to transferring individual drums to the off-site waste disposal vendor, while incorporating pollution prevention recommendations regarding reusing containers and eliminating the need for multiple sampling, over-packing and storing waste drums in RCRA accumulation areas.

The streamlined process developed and implemented by the team involves: pumping the used Kathene/Tri-solv solution from the Kathabar units into reusable poly drums; using historical data and process knowledge for non-rad determination, RCRA determination, and flashpoint; temporarily staging the drums in the RCRA 90-day yard; bulking the drums into a lined steel commercial hazardous waste tanker; collecting one confirmatory pH sample and preparing one UCN-2109 form per tanker-load; and final review of the 2109 to release the tanker for transport to the offsite treatment on the same day. (The review and release was expedited through advanced preparation of a draft 2109 based on excellent process knowledge, historical data, non-rad determination, and other information).

The first tankered shipment of Kathene/Tri-solv was completed in August, 2006 as part of a cooperative effort between BWXT Y-12 (Special Materials Production, Assembly Operations, Plant Services, Waste Management, and Environmental Compliance), Bechtel Jacobs Company, and WESKEM. The first shipment included eighty 55-gallon drums (approximately 4,000 gallons) of Kathene/Tri-solv. The shipment was successfully bulked and transferred to a commercial 7,000 gallon tanker, and sampled at the BWXT Y-12 90-day yard prior to offsite transport and hazardous waste treatment.

The Savings
This improved process reduced paperwork and administrative requirements by 99 percent, greatly reduced compliance liabilities related to managing RCRA wastes and potential spills and releases during storage by cutting storage time of the drummed waste from nearly 90 days to 1 day, reduced sampling and analytical cost and resources, and eliminated nearly 100 percent of wastes generated due to packaging and sampling requirements. Empty vendor poly drums and wood pallets are now reused rather than disposed. Purchase of new lined steel drums for interim waste storage is no longer required.

The first tankered Kathene/Tri-solv shipment resulted in more than $111,000 in cost savings, eliminated over 3,600 pounds of waste drums and 800 pounds of wood pallet waste, and eliminated 20 analytical samples and their associated wastes. This project will have an estimated annual cost avoidance of more than $400,000 due to savings in sampling costs and waste (eliminates more than 70 samples), and reduced metal drum and wood pallet costs and waste (eliminating approximately 16,500 pounds of these wastes per year).

In addition, other cost savings that can not be easily quantified were realized due to the implementation of this project: 1) the amount of sample wastes generated was reduced (samples were reduced from more than 20 per shipment to only one); 2) the number of waste characterization forms (UCN-2109) that must be completed for each shipment was minimized (reduced from as many as 80 per shipment to just one UCN-2109 form per shipment); and 3) the extended management of RCRA hazardous waste accumulation areas/activities for the drummed Kathene/Tri-solv wastes including RCRA inspections and hazardous material inventories was eliminated.