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Prepared By
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Procedure Validator
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Functional Procedures Configuration Control Board Chairperson
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Functional Policy Coordinator Date
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Plant Procedures Coordinator
Effective Date: _________________________________
This procedure has been reviewed by an Authorized Derivative Classifier and has been determined to be UNCLASSIFIED. This review does not constitute clearance for public release.
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Name and Date
II. REQUIREMENT REFERENCES
III. SCOPE/LIMITATIONS
IV. DEFINITIONS
V. GENERAL INFORMATION
VI. REQUIREMENTS
VII. RESPONSIBILITIES
B. Organizational Managers
C. P2 Program Office Personnel
D. Pollution Prevention Council Members
E. Waste Generators
IX. ADMINISTRATION
X. APPENDIXES
Project Activity Report Form
2. EPA PL 101-508: The Pollution Prevention Act of 1990 (November 5, 1990)
3. EPA Executive Order 12873: Federal Acquisition, Recycling, and Waste Prevention (October 22, 1993)
4. U.S. Department of Energy (DOE) Order 5400.1: General Environmental Protection Program (November 9, 1988)
5. DOE Order 5400.5: Radiation Protection of the Public and the Environment
6. DOE, Waste Minimization and Pollution Prevention Policy (September 1992)
7. Tennessee Department of Environment and Conservation (TDEC): TCA 68-212-301 et. seq., Tennessee Hazardous Waste Reduction Act of 1990 (1990)
8. Document Number: Company Name Pollution Prevention Program Plan (Date)
2. DOE Defense Programs: Guidance for the Preparation of the Waste Minimization and Pollution Prevention Awareness Plan (December 1993)
3. DOE, Document No. DOE/S-0118: Pollution Prevention Program Plan 1996
4. DOE: DOE Model Pollution Prevention Opportunity Assessment Guidance (February 1996)
5. DOE: DOE Model Process Waste Assessment Plan (January 15, 1991)
6. DOE Environmental Management, DOE Order 5400.1: Site WMin/PP Awareness Plans DOE-Wide Implementation Guidance - Update (March 1994)
7. DOE: Environmental Restoration and Waste Management 5-Year Plan, (1993)
8. DOE, Memorandum from Hazel R. O'Leary, Secretary of Energy, to Distribution (all elements of the DOE), "Implementation of Executive Order 12856, Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements" (November 15, 1994)
9. DOE Order 5400.3: Hazardous and Radioactive Mixed Waste Program (February 22, 1989)
10. DOE Order 5700.6C: Quality Assurance (August 21, 1991)
11. DOE Order 5820.2A: Radioactive Waste Management (September 26, 1988)
12. DOE Order 6430.1A: General Design Criteria (April 6, 1989)
13. DOE Secretary of Energy Notice SEN-37-92 from James D. Watkins, Admiral, U.S. Navy (Retired), DOE, Secretary of Energy: Waste Minimization Crosscut Plan Implementation (May 13, 1992)
14. DOE: Waste Minimization/Pollution Prevention Crosscut Plan (1994)
15. EPA, Document No. EPA/625/7-88/003: Waste Minimization Opportunity Assessment Manual (July 1988)
16. EPA Executive Order 12088: Federal Compliance With Pollution Control Standards (October 13, 1978)
17. EPA Executive Order 12856: Federal Compliance With Right-to-Know Laws and Pollution Prevention Requirements (August 3, 1993)
18. EPA, Federal Acquisition and Community Right to Know, Executive Order 12969, (August 8, 1995)
19. EPA, Federal Register Vol. 58, No. 102: Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program (May 28, 1993)
20. EPA PL 94-83: National Environmental Policy Act (August 9, 1975)
21. EPA PL 99-499: The Emergency Planning and Community Right-to-Know Act of 1986 (October 17, 1986)
22. EPA PL 101-549, 104 Stat. 2399-2712: The Clean Air Act Amendments of 1990 (November 15, 1990)
23. EPA PL 102-580: Clean Water Act of 1992 (October 31, 1992)
24. EPA PL 102-886: Federal Facility Compliance Act of 1992 (September 22, 1992)
2. DOE - XYZ: Department of Energy - Office Name Operations
3. DP: Defense Programs
4. EM: Environmental Restoration and Waste Management
5. EO: Executive Order
6. EPA: United States Environmental Protection Agency
7. EPCRA: Emergency Planning and Community Right-to-Know Act
8. P2: Pollution Prevention
9. PPOA: Pollution Prevention Opportunity Assessment
10. PWA: Process Waste Assessment
11. RCRA: Resource Conservation and Recovery Act
12. TDEC: Tennessee Department of Environment and Conservation
13. TSCA: Toxic Substances Control Act
C. Pollution Prevention (P2): Activities that minimize or eliminate the volume, toxicity, or both of waste streams, emissions, or discharges generated; recycling processes that use, reuse, or reclaim a material from a waste stream in any media. The primary method for pollution prevention should be through source reduction. Recycling opportunities should be explored secondarily to source reduction. Pollution Prevention does not include treatment; these are defined as implementation of best available technology or management practices.
D. P2 Activity Report Form: Forms used to populate the P2 Activity Data Base from which regulatory reports are prepared to provide the latest status to our customers, help with budgeting requests, identify barriers, and provide a general knowledge of activities occurring on site. The P2 Program Office uses the information exclusively to document activities, progress, etc., of the company program.
E. Pollution Prevention (P2) Council: The P2 Council is composed of Pollution Prevention Representatives from each Company Name Organization, central organizations located at Company Name, and the Environmental Restoration Organization at Company Name; the Company Name P2 Coordinator and Program Staff; DOE; and technical subject matter experts as needed. The Company Name P2 Coordinator chairs this council.
F. Pollution Prevention Opportunity Assessment (PPOA): The evaluation of process and operations for potential opportunities to apply pollution prevention techniques to reducing waste generation and disposal. PPOAs were previously known as Process Waste Assessments (PWA).
G. Pollution Prevention Program Office: Composed of the Company Name Pollution Prevention Coordinator and other dedicated staff members within the Company Name Organization to administer the P2 Program.
H. Project Activity Data Base: A data base developed to help with the tracking of pollution prevention activities. The information given to the Pollution Prevention Program Office on the P2 Activity Report Form is entered and maintained within the P2 data base. This mechanism allows for the easy retrieval of information to support various needs such as reporting functions, informational requests, and budget and programmatic planning activities.
I. Recycling: The use or reuse of waste as an effective substitute for a commercial product or as an ingredient or feedstock in an industrial process. It can occur on- or off-site and includes the reclamation of useful constituent fractions within a waste material, the removal of contaminants from waste to allow it to be used, or the use of waste as a fuel supplement or fuel substitute.
J. Source Reduction: The reduction or elimination of water, emissions, or discharges at the source, usually within a process. Any practice which (1) reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream, emission, or discharge or otherwise released into the environment (including fugitive emissions) prior to recycling, treatment, or disposal; and (2) reduces the hazards to public health and the environment associated with the release of such substances, pollutants, or contaminants. The term includes equipment or technology modifications; process or procedure modifications; reformulation or redesign of products; substitution of raw materials; and improvements in housekeeping, maintenance, training, or inventory control.
K. Waste Generators: All Company Name employees generate waste and are waste generators.
L. Waste Minimization: Any source reduction or recycling activity that results in either (1) reduction of total volume of waste; (2) reduction of toxicity of waste: or (3) both, as long as that reduction is consistent with the general goal of minimizing present and future threats to human health and the environment.
M. Waste Reduction: Any change in a process, operation, or activity that results in the economically efficient reduction in waste material per unit or production without reducing the value output of the process, operation, or activity, taking into account the health and environmental consequences of such change.
N. Waste Treatment: Any method, technique, or process that changes the physical, chemical, or biological character of any waste in a way that neutralizes the waste or renders such waste nonhazardous, less hazardous, safer to manage, amenable for recovery, amenable for storage, or reduced in volume.
Pollution prevention is a multimedia and multidisciplinary approach that advocates source reduction in which material substitutions and engineering solutions are sought to reduce the mass and toxicity of waste and pollutants. It supports the concept of as low as reasonably achievable in that it promotes the use of innovative approaches in the front end of a process to achieve maximum pollution abatement.
In addition to the Pollution Prevention Act of 1990, pollution prevention philosophy has been incorporated in other environmental statutes including the Clean Air Act, Clean Water Act, Emergency Planning and Community Right-to-Know Act (EPCRA) Title III, Resource Conservation and Recovery Act (RCRA) and Toxic Substances Control Act (TSCA). The P2 provisions included in these statutes are not discussed specifically in this procedure.
The overall objectives of the Company Name Program are to:
B. Promote the use of nonhazardous materials in Company Name operations to minimize the potential risks to human health and the environment.
C. Reduce or eliminate the generation of waste materials through input substitution; product reformulation; process modification; improved housekeeping; on-site, closed-loop recycling; and off-site recycling to achieve minimal adverse effects on the air, water, and land when technically and economically feasible and cost effective.
D. Comply with federal and state regulations and DOE requirements for pollution prevention.
B. Air emission and water effluent pollutants will be integrated into all source reduction/recycling efforts.
C. Planning, budgeting, and implementation of pollution prevention activities shall be an integrated function.
D. Pollution prevention budgeting and funding requests shall be established annually to provide for a comprehensive pollution prevention program.
E. An aggressive pollution prevention program will be established with primary emphasis on reduction of all wastes and pollutants at the source. Following source reduction options, recycling alternatives will be investigated and instituted.
F. A waste stream prioritization matrix will be established to determine which streams should be targeted for reduction.
G. Waste streams and other pollutants will be prioritized. Following prioritization, characterization of waste streams and airborne and aqueous effluent will be conducted to:
2. provide a baseline by which reductions can be ascertained and quantified.
2. report pollution prevention efforts and accomplishments in accordance with DOE orders and state, local, and federal regulations and permits.
J. Employee training programs in pollution prevention will be developed to support the company's overall initiatives.
K. Methodologies for monitoring and quantifying pollution prevention successes will be developed.
L. Incentive and awards programs for individual and team efforts associated with positive pollution prevention efforts will be established and maintained.
M. Characterization information from waste and pollutants should be used to conduct the following assessments of waste and pollutant-generating process and activities to determine the most effective pollution-abatement methodology.
2. Develop options to minimize waste and pollutants.
3. Evaluate and prioritize reduction options.
4. Implement practicable low-cost or no-cost options.
5. Assess project expenditure options for cost savings/avoidance.
6. Budget for economically or environmentally practicable expenditure options.
O. A proactive approach, including the development of internal mechanisms to increase the purchase of recycled materials in accordance with EO 12873, will be established and maintained.
P. Procurement practices will be developed which favor the purchase of more environmentally preferred products (e.g., less toxic, smaller quantity, recyclable, etc.).
Q. Future regulatory trends and initiatives in pollution prevention will be identified and communicated within the company.
R. Pollution prevention achievements and lessons learned will be communicated.
S. Pollution prevention information will be exchanged within the company and DOE facilities and with industry.
T. Pollution prevention research needs will be communicated to federal research facilities, academia, and industry.
U. Compliance with all orders, agreements, compliance schedules, or compliance agreements issued by federal or state regulatory agencies shall be maintained and documented.
2. Recognizes employee(s) achievements related to P2 activities (e.g., issue letters of appreciation).
2. Appoint Pollution Prevention Representatives, who are knowledgeable in organization processes and waste generation, to represent their organizations on the Pollution Prevention Council.
3. Develop and maintain organization-specific P2 Plans that outline goals and activities.
4. Ensure that funding is requested to meet P2 Program objectives, plans, and data requests.
5. Monitor and keep records of organizational pollution prevention activities (Appendix).
6. Conduct a semiannual assessment of the P2 Program elements within the organization.
7. Participate in the use/reuse of material surplus through various material exchange mechanisms.
8. Submit P2 Projects/Activities for nominations toward applicable award recognition programs (e.g., Award of Excellence, Presidents Award for Continuous Improvement, DOE-XYZ Waste Minimization Award, etc.).
9. Appoint PPOA team members as needed to support preparation of assessments.
2. Communicate with the P2 Council to exchange information, provide updates on pollution prevention developments, discuss problems, receive suggestions, and review the program. Hold meetings of the Council.
3. Maintain open channels of communication laterally and vertically among the Company Name organizations to enhance awareness and convey pollution prevention objectives, goals, ideas, methods, lessons learned, and successes.
4. Prepare, review, and revise P2 Policy and Plans for approval and signature of company management.
5. Establish tracking and communication systems that are designed to provide waste stream characterization and baseline waste stream generation data and to enable quantitative evaluation of pollution prevention efforts.
6. Develop and maintain a system of reporting pollution prevention activities and results of minimization efforts both internally and in accordance with regulatory and DOE requirements.
7. Track, report, and keep records of the company P2 activities and accomplishments.
8. Support the identification and implementation of pollution prevention methods and technologies to reduce generated waste volume and toxicity.
9. Test and evaluate new pollution prevention opportunities and associated technologies as applicable.
10. Target any policies, procedures, or practices that may be barriers to pollution prevention.
11. Review other procedures and practices for incorporation of P2 philosophy [e.g., incorporating P2 opportunities into the early planning stages of proposed projects (National Environmental Policy Act)].
12. Evaluate on an annual basis progress made in implementation of pollution prevention opportunities identified in previous PPOAs, and determine if additional PPOA activities are required.
13. Develop and revise, as necessary, specific goals and schedules for pollution prevention activities.
14. Conduct management briefings to keep management abreast on P2 activities, barriers, and successes.
15. Develop performance measures for which to assess the P2 Program elements. Administer a self-assessment of organization and the entire program on a semiannual basis.
16. Determine a mechanism to prioritize waste streams, emissions, and discharges for additional studies/recommendations for targeting reduction.
17. Identify funding and personnel requirements and establish schedules for the implementation of selected pollution prevention options and program activities.
18. Track associated resource utilization to allow evaluation of use and needs.
19. Create incentives for pollution prevention by establishing a program of awards for pollution prevention suggestions and accomplishments and establishing achievable, measurable pollution prevention goals as part of each organization manager's annual measures of performance.
20. Plan and organize incentives and awards programs for individual and team efforts associated with P2 activities.
21. Develop and implement employee pollution prevention awareness and occupational training programs.
22. Sponsor an annual awareness event to focus on environmental issues and general awareness of pollution prevention opportunities (usually conducted in conjunction with Earth Day, April 22).
23. Support the procurement and use of products containing recovered materials.
24. Collect and exchange pollution prevention information through technology transfer, outreach, and education networks.
25. Develop and maintain mechanisms for fully disseminating current technical information to company users.
26. Share pollution prevention information with other DOE sites in Location and across the DOE complex. Participate in information exchange (e.g., attending when appropriate, EPA Seminars, DOE Contractor Waste Reduction Workshops, EM and DP Conferences on P2, P2 Coordinators meetings, Company Name P2 Task Team, etc.).
27. Communicate P2 achievements and difficulties (lessons learned) within the company.
2. Attend P2 Council Meetings. The members provide a comprehensive approach to meeting various pollution prevention and waste minimization requirements, and the meeting serves as a forum for increased communication and consistent implementation of pollution prevention activities. The meeting also serves as an information exchange mechanism to promote general awareness of pollution prevention information, while providing a system to document pollution prevention progress, and to identify resources necessary to implement pollution prevention opportunities.
3. Implement the Company Name P2 Program Plan and Organization P2 Plan, if applicable. Review the objectives of the Company Name program in accordance with the facility's mission and needs.
4. Develop pollution prevention goals and implement programs and activities necessary to reduce both the amount and toxicity of waste and environmental pollutants within the organization.
5. Ensure that progress in pollution prevention implementation is documented and communicated for activities within the organization.
6. Advise Company Name Management on methods to initiate and carry out pollution prevention initiatives, as well as promotion of employee awareness and incentive programs.
7. Assist in long- and near-term pollution prevention planning activities, including evaluating technical issues and recommending resource requirements.
8. Ensure that project activity report forms are completed and submitted to the P2 Program Office for all P2 proposed or ongoing activities as soon as the project/planning is initiated.
9. Periodically communicate program objectives to organization personnel.
10. Obtain waste generator support and input for the plant program.
11. Facilitate integration and coordinated interaction between waste generators on new and current pollution prevention matters.
12. Evaluate and revise pollution prevention goals and objectives in accordance with regulatory, DOE, and Company Name requirements.
13. Prioritize waste streams or production areas for assessment.
14. Support the selection of teams to conduct or update pollution prevention opportunity assessments (PPOA) if required.
15. Support the evaluation of the technical and economical feasibility of options to reduce waste generation.
16. Support the recommendations and ranking of options for specific implementation by management.
17. Support monitoring the performance of pollution prevention options that have been implemented and evaluating the performance according to established criteria.
18. Support the monitoring and reporting of progress of the program through evaluations such as audits and reviews.
19. Solicit personnel nominations for achievement and incentives awards for P2 Activities.
20. Coordinate program participation within organization.
21. Support, sponsor, and suggest ongoing and proposed employee awareness and training.
22. Facilitate technology transfer and pollution prevention awareness.
23. Submit budget and project information to support reporting functions of the P2 Program as necessary.
2. Communicate P2 initiatives/issues to the P2 Representative for their organization and complete a project activity report form (Appendix) for activities with the help of the P2 Representative.
3. Support PPOA activities related to their wastes and investigate and implement pollution prevention techniques.
4. Support the development and implementation of new pollution prevention techniques as necessary.
5. Request technical assistance as needed from the P2 Program.
6. Participate in plant-wide source reduction and recycling programs.
7. Participate in P2 related training and awareness activities.
B. Other reporting requirements that are fulfilled to satisfy regulatory requirements are maintained in the P2 Program Office. The following is a list of the reports that are required to date:
2. Tennessee Annual Generator Report (Waste Minimization Information Summary), and
3. Hazardous Waste Reduction Progress Report.
B. A hard copy of this procedure shall remain in the Company Name Procedures Group office in Building (Insert Bldg. Number), in the HS&E Organization Procedures Representative's office in Building (Insert Bldg. Number), and in the Company Name Organization Procedures Representative's office in Building (Insert Bldg. Number). The master copy of this procedure is done in PC WordPerfect 5.1, and the electronic (disk) storage is to be kept in the Electronic Publishing office in Building (Insert Bldg. Number).
PROJECT ACTIVITY REPORT FORM
(Please see Wordperfect version)