Pollution Prevention and Waste Minimization as a Performance Enhancement Mechanism
Pollution Prevention and Waste Minimization
as a Performance Enhancement Mechanism
for Environmental Restoration Projects
Mr. Robert Fleming
US Department of Energy
Office of Environmental Restoration
Germantown, MD 20874-1290
Ms. Lisa Allmon-Burns
P2 Project Manager
11499 Chester Road
Cincinnati, OH 45246-4012
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
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.
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
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
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
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
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
Table 1 summarizes the P2 tools available during planning phase
P2 Tools Available During Planning
WHEN TO USE
P2 Project Team Training Modules and Video, Sustainability Support Guidance Document
Prior to project initiation
P2 Training Modules developed by EM-40 presented to LANL/SNL personnel
Project team aware of P2 potential and opportunities
|P2 expert on team
When reviewing drawings, site information, past activities, etc. for P2 opportunities
Determine project boundaries and extent/type of contamination
Ensures accurate accounting of waste-generation
Sustainability Support Case Study Database
Use to search for examples of successful P2/WMin when discussing cleanup standards/release criteria
Flexible ROD's, risk-based closure instead of dig and haul
||Establishes risk-based cleanup standards; allows free-release of selected materials
|Material/waste management models, IPABS, EM-40 Core Database
Use when determining waste forecast data
Numerous waste forecasting models
Identifies high volume, highly regulated waste streams for future evaluation
Develop procedures after evaluating P2/WMin opportunities and incorporate P2 techniques and practices
Eliminate need to wear disposable PPE, reduce use of PPE, eliminate hazardous decon solutions
Assures P2 techniques are included in all procedures
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
P2 Tools Available During Assessment Phase
WHEN TO USE
|Project team approach, use P2 expert
When assessing project boundaries and amount of sampling needed
||Statistical Sampling Methodology
Reduce size of area to be sampled and amount of samples needed (secondary wastes)
|Utilize Sustainability Support Case Study Database, WMin Handbook and DOE Lessons Learned Database
When identifying P2/WMin techniques for reducing IDW generation and secondary waste
||Direct push technique, micro purge, cone penetrometer, segregation of waste, dry decontamination, recycling decon material
Reduces IDW and secondary waste generation; Reduces cost and improves schedule
|ER P2 IMS
To track waste reductions and document successes
||Track forecasted waste volumes against actual waste volumes generated
||Provides data for reporting P2 successes in annual reports and secondary waste goal
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
Table 3 summarizes the P2 Tools available during evaluation and
selection phase activities.
P2 Tools Available During Evaluation and Selection
|| WHEN TO USE
Pollution Prevention Opportunity Assessment, PPOA database, TechKnow database, DOE's Preferred Alternatives Matrix
Use when identifying where waste is coming from, why and how, and the type/volume of wastes generated from bench and pilot scale treatment studies
||Process modifications; eliminating carbon as filter media, using self-cleaning filters, chemical substitution for pH control to reduce sludge
Identifies methods and techniques for reducing waste (primary and secondary) from selected technology
|Life-cycle Decision Methodology, ALARA and RESRAD-RECYCLE Analysis
||Use when identifying and evaluating waste disposition alternatives
||Recycle of scrap metal, reuse of old buildings, using launderable PPE, reusing soil/concrete
Provides defensible data for choosing recycle/reuse or other dispositions
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
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
Table 4 summarizes the P2 tools available during implementation
phase activities .
P2 Tools Available During Implementation Phase
|| WHEN TO USE
|Standard P2 contract language
Use when developing/writing contracts. Look for incentives to reduce waste generation, maximize recycle/reuse, etc.
||Incentive Task Orders, Basic Ordering Agreement Contracts, Sales/Service Contracts
||Sub-contractors are required to evaluate P2/WMin potential and track waste reduction
|Sustainability Support Case Study Database, DOE's Lessons Learned Database, P2/WMin Users Guide for ER Projects
Use when assessing work practices for generation of unnecessary waste, cross-contamination potential
||Boundary controls (reduce size of contaminated area, unpackage incoming materials, control entry), segregation practices, etc.
||Reduces the generation of secondary wastes from the work area|
|ER P2 IMS
||Use to track waste reductions and document P2 successes
||Comparing forecasted wastes to actuals to determine P2/WMin success
||Provides documentation for annual reports and secondary waste goal
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
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
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.
US DOE. Accelerating Cleanup Paths to Closure.
Washington, DC: Office of Environmental Management; February
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.
US DOE. Pollution Prevention and Waste Minimization Guidance for Environmental Restoration Activities. Washington, DC: Office of Environmental Restoration; May 1995.
US DOE. Strategic Plan:
Providing America with energy
security, national security, environmental quality, science leadership.
Washington, DC: DOE; September 1997.
US DOE. P2 Training Modules for Project Managers
and Project Teams. Washington, DC: Office of Environmental
Restoration; May 1998.
US DOE. WMin Handbook, Volume 1.
US DOE. Lessons Learned
US DOE. ER P2IMS Database. Oak Ridge, DOE.
US DOE. Annual Report of Waste Generation and Pollution
Prevention Progress. Office of Environmental Management; Yearly.
Preferred Alternatives Matrix;
K.L. Yurako, et.al., A Life Cycle Decision Methodology
for Recycle of Radioactive Scrap Metal. 1997.
US DOE. Handbook for Controlling Release for Reuse or
Recycle of Non-Real Property Containing Residual Radioactive Material.
US DOE. P2/WMin Users Guide for Environmental Restoration Projects. DOE's Ohio Field Office, 1998.
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