8070 Appendix T1
and Pollution Prevention Program
1.0 Strategy, Objectives, and Goals
The Wmin/P2 program should serve to assist line management to obtain accurate and current information on waste stream generation and waste management costs, which could provide the basis for the implementation of specific Wmin/P2 techniques and technologies. The program lays the foundation for procedures for collecting information, evaluating options, and identifying cost-effective waste minimizing techniques. The essential elements of the strategy are to
(1) recognize that line management is responsible for implementing Wmin/P2 program,
(2) identify targets to reduce waste and prevent pollution, and
(3) develop a method for tracking the performance and progress of the program.
Under the Lab’s Environmental Management System (EMS), a few Jefferson Lab environmental aspects that can have effects reduced by applying Wmin/P2 are:
· Air emissions—hazardous air pollutants (e.g., radionuclides)
· Air emissions—ozone-depleting substances (e.g., chlorofluorocarbons and halon)
· Air emissions—volatile organic compounds (e.g., diesel fuel and paints)
· Wastewater discharge—surface-storm water (e.g., sediment and earth disturbance and from fertilizers)
2.0 Program Objectives
The objectives of the Wmin/P2 Program are to:
Individual waste streams should be reviewed and reduction measures determined. Large waste streams should be reviewed first. A variation of this procedure has been followed in past years. The goal is to reduce or eliminate waste and prevent pollution whenever the opportunity exists and its implementation is practicable.
Jefferson Lab does not treat or dispose of hazardous, radioactive, or mixed wastes of any kind on-site and has no plans to do so in the future.
2.2 Performance Measures
Environmental, Safety, Health, and Quality (ESH&Q) performance measures in the DOE/Jefferson Science Associates, LLC (JSA) contract regularly address Wmin/P2. A portion of the Laboratory’s performance is evaluated using Wmin/P2 and other ESH&Q measures.
3.1 Wmin/P2 Awareness Plan
The need for a Wmin/P2 Awareness Plan is identified in some regulatory citations (e.g. PL101-598, 42 U.S.C. 13010 et. seq., and E.O. 12856). This Plan, as identified here, has been incorporated, using a graded approach, into the site Wmin/P2 Program.
The purpose of the Wmin/P2 Awareness Plan is to foster the philosophy that prevention is superior to remediation. The goal of the program is to incorporate Wmin/P2 into the decision-making process at every level throughout the organization.
3.2 General plan
Jefferson Lab is committed to minimizing pollution and to ensuring that staff are aware and knowledgeable about Wmin/P2. Line management should ensure aspects of Wmin and P2 are incorporated into programs and activities as applicable.
The Wmin/P2 Awareness plan has the following objectives:
· Make employees aware of general environmental activities and hazards at the site and Wmin/P2 program requirements, goals, and accomplishments.
· Inform employees of specific environmental issues, including opportunities for recycling.
· Keep employees aware of their responsibility in Wmin/P2.
· Recognize employees for significant improvements in environmental conditions through Wmin/P2.
· Publicize success stories.
3.4 Plan Elements
The Wmin/P2 Awareness Plan consists of five elements.
3.4.1 Education and Awareness
One of the most important elements of the Wmin/P2 Program is staff education and awareness.
The goal of the awareness program is to make the Jefferson Lab community aware of waste generation, its impact on the site and the environment, and the ways waste can be reduced and pollution prevented. Supervisors should encourage staff to seek Wmin/P2 opportunities.
3.4.2 Employee Orientation
A Wmin/P2 awareness orientation is part of the lab-wide ESH&Q orientation training for all workers new to the site. The orientation program should include the following elements:
· the need for, and benefits to be derived from, Wmin/P2,
· the contribution each employee can make to an improved working and living environment,
· management commitment to the Wmin/P2 philosophy, and a brief overview of policy and regulations.
Jefferson Lab project and work plans should include mention of the requirement for Wmin/P2, where appropriate.
3.5 Special Awareness Campaigns of Jefferson Lab Community Interest
Site newsletters, bulletin boards, and/or other appropriate techniques should be used to enhance employee awareness of available opportunities or on-site Wmin/P2 initiatives.
3.6 For Specialized Interests
Specialized awareness sessions on P2 policy and procedures and Wmin techniques will be tailored for management, line, and staff positions where such special awareness is determined by Laboratory management to be of value. Specialized awareness sessions could include:
· improved operation practices for reducing waste generation, and
· solicitation of Wmin/P2 ideas and the discussion of solutions to identified situations or problems.
The adequacy of procedures and of any special equipment needed to perform Wmin functions will be determined by the responsible Supervisor.
3.7 Information Exchange
The Wmin/P2 Coordinator is available as a resource to inform appropriate Laboratory staff about items of interest in Wmin/P2. Contact the ESH&Q Reporting Manager at ext. 7007 or the Wmin/P2 Coordinator at ext. 7308 to share information or for assistance in obtaining information.
As well, multimedia resources are available to share Wmin/P2 information across the site. Some of these resources are listed at the end of this appendix.
Recognition should be provided for extraordinary achievements in Wmin/P2.
3.9 Performance Evaluation
Wmin/P2 should be given appropriate consideration in annual evaluations of job performance, with explicit discussion of exceptionally good or bad performance.
3.10 Spill Prevention, Control, and Countermeasure (SPCC) Plan
The SPCC Plan is a vital facet of Jefferson Lab’s P2 program. The SPCC Plan is required under the Clean Water Act at 40 CFR 112 and has a primary focus of preventing pollution to the environment from spills of oil and oil products.
Requirements and information concerning the SPCC Plan can be found in ES&H Manual Chapter 8030 Appendix T5 Oil-Spill Prevention, Control, and Countermeasures, as well as the SPCC Plan located in the ESH&Q Division Office.
The As Low As Reasonably Achievable (ALARA) Process is designed to minimize staff exposure to radiological materials, as well as to minimize or eliminate the production of radiological waste.
This process is managed and overseen by the Radiation Control Group (RadCon) and program specifics are found in ES&H Manual Chapter 6310 Protection from Ionizing Radiation, and the site-specific Radiation Control Manual.
4.1 Waste Assessments
Line management should consider exceptional Wmin/P2 issues and opportunities during the performance of line management self-assessments. For additional recommendations regarding the conduct of Wmin/P2 assessments, please contact the ESH&Q reporting Manager or the Wmin/P2 Coordinator.
4.2 Hazardous Waste Minimization Requirements
The standard hazardous waste manifest (shipping papers) specifies that the waste generator make a good faith effort to minimize hazardous waste production and select the best affordable management practices. Jefferson Lab honors this commitment and has made a commitment to itself and to external agencies to protect human and environmental health. Jefferson Lab aims to further this commitment by eliminating or minimizing the production of hazardous wastes through process changes and materials substitution.
Jefferson Lab achieves these requirements by assessing process procedures to identify methods for reducing toxicity and quantity of waste generated. Management practices are regularly enhanced as new technology emerges and as potential sources of waste reduction are identified.
4.3.1 Information Exchange And Outreach
All staff are encouraged to make regular use of the latest Environmental Protection Agency (EPA) database and the DOE Environmental Protection Information Clearinghouse (EPIC) system. The Wmin/P2 Coordinator and other involved staff foster participation in business, education, and government forums that are designed to provide technical assistance and exchange Wmin information. The Wmin/P2 Coordinator may propose representatives to potentially attend DOE workshops and/or conferences on Wmin/P2 issues.
4.3.2 Technology Transfer
The transfer of federally developed technology between laboratories and potential users is a contractual responsibility of DOE facilities and laboratories. Activities involving technology transfer should be coordinated through the Jefferson Lab Technology Transfer Office. This office reports to the Associate Director for the Accelerator and promotes technology transfer through links to the public and private sectors.
Opportunities for transfer of technologies specific to Wmin programs may develop from information exchange systems, workshops, or topical conferences.
4.3.3 Research and Development
Proposals for research and development (R&D) projects may utilize results from an ESH&Q Division preliminary evaluation and ranking of Wmin options. Some options may require development work before being implemented. The assessment may also identify process inefficiencies that offer the potential for significant waste reduction. Specific process modifications may require R&D work before implementation can be scheduled. Budget requests may include support for appropriate R&D. Specific proposals for R&D work should be coordinated through the proposer’s Associate Director.
NOTE: ESH&Q Division staff work closely with and Lab staff on Wmin/P2 concerns.
4.3.4 Program Evaluation
The Wmin/P2 Program should be evaluated every three years by the Environmental Engineer. All major activities should be reviewed. The evaluation should document program achievements and identify potential areas for improvement.
Contract Performance measures may be used to demonstrate the effectiveness of Wmin/P2 efforts. Examples of past measures include:
· Jefferson Lab environmental exceedances per fiscal year
· Number of reportable and recordable exposures to hazardous substances
· Affirmative Procurement score for fiscal year
The Environmental Engineer should consider these performance measures when evaluating the success of process or other changes to achieve waste volume or toxicity reductions.
4.3.5 Cost Accounting
The “true cost” of waste that is generated should be kept in mind when considering Wmin/P2 options. These costs include: (1) underutilization of raw material found in the waste stream, (2) management of the wastes that are generated, (3) waste disposal, and (4) third party liabilities if the waste is improperly disposed of. Other costs include personnel, recordkeeping, transportation (including on-site movement), pollution control equipment, treatment, storage, disposal, liability, compliance, and oversight costs.
4.3.6 Tracking and Reporting Systems
Tracking and reporting activities in the Wmin/P2 Program are performed to comply with requirements and standards referenced in the DOE/JSA contract. The information gathered is important because it is used to measure laboratory performance, as well as to monitor our adherence to various laboratory, federal, and contractual commitments.
4.3.7 Quality Assurance
Federal and State regulations, as well as our site contract and permits, stress the requirement and need for quality assurance (QA) in conducting waste reduction or other pollution prevention activities. The requirements indicate that waste reduction or minimization programs are required to retain an appropriate level of documentation and accountability.
The documentation of any waste minimization program or review should be designed to satisfy the requirements of the Laboratory’s Quality Assurance Program Manual.
Informational Documents and Reference Material available through ESH&Q Reporting at x7308:
Office of Pollution Prevention
c/o Virginia Department of Environmental Quality (DEQ)
Ph (804) 698-4545
REVIEW REQUIRED DATE