This appendix addresses the current status of Pantex Plant's Pollution Prevention and Waste Minimization (PP/WM) program. This section discusses the program's background; current elements, including source reduction, process change, material substitution, administrative policies, pollution prevention opportunity assessments (PPOAs), technology transfer, recycling/reuse, treatment, energy and water conservation, and future programs.
NEPA emphasizes minimizing the impacts that result from Federal activities. The Pollution Prevention Act of 1990 and the Hazardous and Solid Waste Amendments of 1984 enabled Federal agencies to develop and implement PP/WM programs. NEPA's original purpose, which was to "promote efforts which will prevent or eliminate damage to the environment..." was complemented by both acts (42 U.S.C. 4321; PC 1995a:1). This relationship was further strengthened in a 1993 memorandum from the Council on Environmental Quality, which recommended that Federal agencies incorporate pollution prevention principles, techniques, and mechanisms throughout their NEPA planning and decision making processes (PC 1993a:2).
To help facilities meet regulatory requirements, the Environmental Protection Agency (EPA) has published strategies and guidelines on PP/WM. The Pollution Prevention Act establishes an environmental protection hierarchy, with pollution prevention/source reduction as the most desirable environmental management option. If pollution cannot be prevented, then, in descending order of preference, environmentally sound recycling, treatment, and disposal are listed as alternative waste management options (PC 1993:Attach. 2).
Waste minimization centers on source reduction or recycling of solid wastes regulated by the Resource Conservation and Recovery Act (RCRA). Pollution prevention complements the concept of waste minimization by focusing on the following: source reduction and other practices that reduce or eliminate pollutants through increased efficiency in the use of raw materials, energy, water, or other resources or protection of natural resources by conservation (PC 1993:2). Waste minimization is an implied element of the pollution prevention process.
The State of Texas established the Waste Reduction Policy Act of 1991, Senate Bill 1099, which amended the Texas Solid Waste Disposal Act (Texas Statutes, Article 4477-7) to include requirements for the elimination of hazardous waste generation through source reduction and waste minimization. TNRCC serves to enforce this act by requiring:
- Operators of hazardous waste disposal facilities to maintain records necessary to determine the amount of hazardous waste disposed.
- Large quantity generators of industrial solid or hazardous waste to provide recordkeeping and use a manifest or other appropriate system to ensure that waste is transported to an authorized facility.
- Large quantity generators to provide plans for the reduction of the release of pollutants or contaminants into the air and water and to establish reasonable goals for the reduction in volume of generated hazardous waste and the amount of pollutants and contaminants using source reduction and waste minimization.
TNRCC promotes the Clean Texas 2000 program, which emphasizes pollution prevention programs as well as recycling and waste minimization activities (MH 1994:2-24). The goal of this program is to create a cleaner Texas by the year 2000.
DOE has developed an overall pollution prevention strategy and framework that is consistent with EPA's recommendations and other requirements (e.g., Executive Order 12856 and 12902) around which its facilities must structure their own programs. DOE Orders 5400.1, 5400.3, and 5820.2A establish policy requirements for environmental protection and waste management. This framework is the basis of Pantex Plant's strategy to implement PP/WM elements and techniques into all operations at the plant. Pantex Plant pollution prevention policy states its commitment to use available technology to reduce waste generation, monitor operations to encourage sound practices that discourage waste generation, develop an awareness of environmental concerns and practices, and comply with existing laws governing environmental protection (Battelle 1994:5). Chapter 6, Environmental Compliance Requirements for Implementing the Proposed Action and the Alternatives, provides additional information on these regulations.
The Pantex Plant PP/WM program is consistent with DOE and other legal requirements and designed to eliminate or minimize pollutant releases to all media and incorporate a pollution prevention ethic into the plant (Battelle 1994:1). In 1996, the PP/WM program at Pantex Plant received the White House Closing the Circle Award for achievements in recycling and waste prevention (MH 1996). A simplified schematic of the program is given in Figure G.3-1. Table G.3-1 presents the 16 elements of the Pantex Plant PP/WM program.
Pollution prevention encompasses all actions necessary to keep pollutants from being released into the environment (Battelle 1994:22). Source reduction emphasizes the aspect of preventing and reducing the creation of wastes through process change, material substitution, and administrative policies. Table G.3.1-1 provides a comprehensive list of source reduction techniques at Pantex Plant. The list contains 34 specific measures taken at Pantex Plant to reduce waste at the source.
Efforts to reduce and eliminate emissions and waste at Pantex Plant have greatly reduced emissions and waste generation (e.g., from 1987 to 1994, the plant's generation of hazardous waste decreased by more than 96 percent). These reductions have meant significant savings on the cost of waste disposal as well as benefiting the environment. Disposal costs in 1994 were less than a third of those in 1992, saving more than $2 million (DOE 1995a:3-6). Table G.3.1-2 provides waste generation data for the 1992-1995 period. All waste types were reduced with the exceptions of hazardous and Toxic Substances Control Act (TSCA) waste. Hazardous waste has increased as a result of the remediation of contaminated soils under the Environmental Restoration program (DOE 1996:17). An increase in TSCA waste reflects asbestos removal during facility modifications (DOE 1996:22). Overall wastes are down by 53 percent since 1993.
Waste reduction goals are listed for all types of waste in Table G.3.1-3. In accordance with Executive Order 12856, Federal Compliance with Right-to-know Laws and Pollution Prevention Requirements, Pantex Plant is required to reduce the volume of toxic chemicals requiring disposal by 50 percent. Table G.3.1-3 details the required reduction through 1999. In any given year, wastes are expected to be reduced by 2 to 40 percent.
Process changes (i.e., affirmative procurement, technical redesign, procedural controls, and maintenance procedures) were examined to ensure that wastes are minimized to an extent that is technically and economically feasible (Battelle 1994:21). With the 1994 implementation of new procedural controls (i.e., a required visual inspection) for high explosive(s) (HE)-contaminated waste, a 99 percent reduction in the generation of HE-contaminated hazardous waste was achieved. This decrease has resulted in the use of fewer active thermal treatment units and reduced air emissions at the Burning Ground (DOE 1995a:3-7). The savings are estimated at $80,000 per year (PC 1995:8). The fireloop construction project utilized process changes (reevaluation of solid waste management unit data, rerouting piping, and recharacterization of wastes) that resulted in reducing the amount of hazardous and Class 1 wastes by 215 cubic meters (281 cubic yards) at a savings of $516,750 in January of 1995 (PC 1995:4).
Material substitution is achieved by reviewing existing products and searching for environmentally preferable products that are as efficient as current products. One type of material substitution concerns solvents and cleaners used for removing several types of contaminants before preparing, removing, or replacing parts or components. Since 1995, Safety Kleen Premium Solvent has replaced several hazardous solvents (i.e., toluene, Blue Gold, LPS, acetone, and Freon TF) in the Vehicle Maintenance Facility, instrument shop, bicycle shop, and DOE's transportation couriers. The use of Safety Kleen Premium Solvent resulted in an estimated annual savings of $103,000 and reduced volatile organic compound emissions. Additionally the generation of hazardous waste was reduced by 8,706 liters (2,300 gallons) per year. In 1993, the security division substituted a citrus-based nonhazardous solvent in place of the old hazardous solvent and reusable rags in place of disposable kimwipes, which resulted in a 90 percent decrease of hazardous waste and an annual savings of $2,400 (PC 1995:3, 6).
Top management is committed to take appropriate action to support the objectives of the PP/WM program by ensuring the availability of adequate personnel, budget, training, and materials. Administrative policies (e.g., Waste Minimization Plant Procedure) at Pantex Plant ensure involvement of all employees in the plant's PP/WM program through the implementation of a PP/WM team, employee incentives, program feedback, employee training, database tracking system, and cost allocation. Two important projects utilized to ensure continuous commitment are PPOAs and technology transfer.
Pantex Plant created a PP/WM team to coordinate and track a PP/WM program that promotes the exchange of related information. This team, made up of waste coordinators from each division as well as the plant PP/WM Coordinator, is responsible for the coordination of waste assessment teams that conduct PPOAs.
The function and purpose of PPOAs are to identify viable PP/WM projects (Battelle 1994:15). This program is designed to achieve maximum effectiveness with minimal procedural constraints (Battelle 1994:16). PPOA is an ongoing program that identifies, screens, and analyzes options to reduce generated wastes.
Pantex Plant prioritized specific sources responsible for the consumption of materials and waste generation. Weighted sums were derived from three screening criteria: volume of waste produced (40 percent), toxicity of waste (30 percent), and per unit disposal cost (30 percent). The top 150 entries were designated as priority targets for PPOAs in the first 2 years (Battelle 1994:15). Of the top 150 PPOAs for the 1992-1994 period, 45 were from the Manufacturing Division, 41 were from the Facility Operations Division, 38 were from the Explosive Technology Division, 23 were from the Environmental Safety and Health Division, and 3 were from the Quality Division.
Graphs depicting the projected waste reduction by the implementation of the PPOAs are provided in Figures G.3.5-1 through G.3.5-4. A separate graph is provided for each waste type under consideration. Activities expected to impact waste generation volumes are noted on each graph as well as the 50 percent reduction goals and past progress made toward meeting those goals.
A key Pantex Plant mission, initiated through administrative policies consistent with the Stevenson-Wydler Technology Innovation Act of 1980 (15 U.S.C. 3701), is technology transfer. Activities involving technology transfer are coordinated through the PP/WM team and the Federal Laboratory Consortium (Battelle 1994:27). The consortium promotes technology transfer through links to the public and private sectors and support services such as training and assistance in implementing partnership opportunities. The purpose of technology transfer programs is to enhance the competitiveness of U.S. industries in the global economy.
Technology transfer opportunities will also aid in reducing DOE's cost for maintaining nuclear competence by making onsite facilities available to U.S. industries through User Facility Agreements. Some facilities that could have dual use are Metrology, Nondestructive Evaluation Testing, Analytical Laboratories, Synthesis and Formulation, Machining, and Explosives Testing. Cooperative Research and Development Agreements with local colleges and universities for teaching and research will provide DOE with a trained and highly qualified labor pool that could help maintain and enhance the capabilities at Pantex Plant (DOE 1995:14).
To reduce future emissions and stabilize wastes to meet land disposal restrictions standards (LDRs), DOE technology transfer efforts include the development of DOE and/or commercially developed technologies. Macroencapsulation and stabilization are technologies which are being considered for development at Pantex Plant.
For operations, technology transfer efforts are currently being explored in conjunction with future programs (see Table G.3.11-1) at Pantex Plant. An example of this is with the Nondestructive Evaluation Facility, proposed for construction in 1997. Approximately 30 percent of the workload at this facility would result from technology transfer operations such as high energy radiography, computer tomography, and digital imaging (DOE 1994a:1, I.b-4).
Waste reduction and elimination is promoted through the implementation of onsite and offsite recycling, reuse, and reclamation activities. The scope of the recycling program focuses on hazardous and office-generated waste (e.g., aluminum cans and office paper). Many of the recycling programs currently in place, such as the recovery and sale of precious metal, show a profit (Battelle 1994:22). Table G.3.7-1 provides examples of Pantex Plant's recycling and reuse activities, accomplishments, and savings. As an example of PP/WM, Building 11-29 recovers silver from photo solutions and wastewater previously discharged to the wastewater treatment facility and Playa 1. The closed-loop system is an ion exchange process. Another example of PP/WM is the recovery of dimethyl sulfoxide and HMX high explosives from Class 1 nonhazardous industrial solid waste solutions resulting from weapon dismantlement operations (PC 1996:1, 2).
Low-level mixed waste (LLMW) and hazardous waste (HW) are generated as a result of plant operations associated with the dismantlement of weapons, associated support, and environmental restoration activities. LLMW contains both radionuclides and hazardous constituents (Pantex 1996:14.5). HW is any material that is a solid waste and a listed HW or exhibits any of the characteristics of ignitibility, corrosivity, reactivity, or toxicity (Pantex 1996:14.5).
Limited physical treatment and processing of waste (e.g., compaction, sorting, repackaging, and wastewater filtration) is currently performed. HW produced must be shipped offsite for treatment, processing, and disposal. Some LLMW has been sent by DOE to a permitted offsite commercial facility; the remaining LLMW, regulated under the Federal Facility Compliance Act (42 U.S.C. 6901), is currently being stored at Pantex Plant (Battelle 1995:13, 15).
With the completion of the proposed Hazardous Waste Treatment and Processing Facility in 1999, Pantex Plant would conduct LLMW processing and treatment operations using DOE developed technologies that would enable stored and future generated LLMW to meet LDRs and be disposed of offsite (Battelle 1995:15). When applicable, Pantex Plant would pursue commercial LLMW treatment. HW would continue to be shipped offsite for treatment and disposal at commercial facilities when the Hazardous Waste Treatment and Processing Facility is operational. The new facility would allow for enhanced waste sorting/repackaging, sampling, compacting, drum rinsing and crushing, and waste minimization opportunities (e.g., solvent recovery) (Battelle 1995:13). Benefits include reduced air emissions and stabilized wastes.
HE-contaminated waste material may be characterized as a RCRA HW that exhibits the characteristic of reactivity pursuant to RCRA under 40 CFR 261.23 (Pantex 1996:14.5). This waste is thermally treated by open burning/open detonation (OB/OD). Discussions of the affected environment and impacts are presented in chapter 4.
A Best Available Control Technology (BACT) analysis for air emissions from explosives treatment at Pantex Plant Burning Ground was conducted and documented in a DOE letter to TNRCC dated October 15, 1993. The BACT review concluded that controlled open thermal treatment with existing administrative controls constituted BACT. In March 1994, a formal literature search was conducted to investigate treatment/processing methods for HE other than OB/OD. The review identified processes currently in use (e.g., OB/OD and chemical treatment) as well as those in various stages of development. The results of the literature search were forwarded to TNRCC.
At that time, the alternatives were determined to be either technically infeasible for Pantex Plant explosives or economically infeasible on a cost-per-unit mass of air pollutants that could be controlled (Radian 1994:1). The alternative emerging explosive treatment technologies were identified as: advanced thermal treatment methods (i.e, molten salt destruction, supercritical water oxidation, and advanced plasma incineration), chemical/biological treatment methods (e.g., base hydrolysis, chemical/electrochemical oxidation, and biological oxidation), and explosives recovery/reuse technologies (e.g., critical fluid extraction, explosives as supplemental fuels, and solvent recovery).
Since 1994, the development of refined procedures for HE chemical treatment has warranted the further investigation of a base hydrolysis treatability study program to be housed in building 11-36. Though the most commonly generated HEs resulting from dismantlement processes are HMX based, this treatability study can accommodate other types of HE (e.g., RDX, TNT, HNS, TATB, and some of their respective formulations). The total amount of waste that will be used in this study program is 1,000 kilograms (2,200 pounds) where 52 kilograms (115 pounds) will be the maximum per process. As a result of this study, the plant will expect to:
- Obtain the information required to determine the feasibility of treating explosives by base hydrolysis.
- Confirm the composition of the residues from the process.
- Confirm the constituents of the gases emitted to the atmosphere.
- Define the optimum operating parameters for the explosives to be treated (MH 1995:2, 3, 4, 6).
In 1995, Pantex Plant consumed 80,046 megawatthours of electricity, compared to 82,224 megawatthours in 1993. Electrical usage decreased as the plant population increased. Pantex Plant employed a total of 3,470 people in 1993, and it employed approximately 3,800 in 1995. It is expected that by the year 2004, electricity consumption will decrease to 62,000 megawatthours. This decrease in consumption is consistent with Executive Order 12902, Energy Efficiency and Water Conservation at Federal Facilities (DOE 1994:1, 7; Pantex 1996:2.0, 9.0).
Pantex Plant used 515,277 thousand cubic feet of gas in 1994, as compared to 468,969 thousand cubic feet in 1995, representing a net decrease of 9 percent. The future forecast predicts a net decrease of gas usage by 11 percent from 468,969 thousand cubic feet in 1995 to 416,000 thousand cubic feet in FY 2005 (DOE 1995:10, Pantex 1996:9-0).
In 1993, 920 million liters (243 million gallons) of water was pumped from the Ogallala aquifer. In 1994, this decreased by 9 percent to 836 million liters (221 million gallons) of water. Table G.3.10-1 provides information on the amounts of water used at Pantex Plant from 1989 to 1994. Texas Tech University consumed about 25 percent of the water used annually. It is predicted that, by the year 2004, 738 million liters (195 million gallons) of water will be pumped, and by 2005 it will decrease to 568 million liters (190 million gallons) (DOE 1994:7; DOE 1995:10). This reduction in water usage parallels the criteria for Executive Order 12902 which mandates both energy efficiency and water conservation at Federal facilities.
Wastewater decreased by 19 percent from 587 million liters (155 million gallons) generated in 1993 to 477 million liters (126 million gallons) in 1994. In the year 2004, Pantex Plant plans to generate 473 million liters (125 million gallons) of wastewater instead of the 477 million liters (126 million gallons) generated in 1994 (DOE 1994:7; DOE 1995:10).
Future programs consist of evaluating PPOAs, identifying and implementing new technology transfer efforts, employee training, program feedback, and program evaluation. Table G.3.11-1 provides information on 7 future projects at Pantex Plant and their relationship to PP/WM efforts. These planned and tentative projects utilize various facets (e.g., source reduction, treatment, recycle/reuse, energy conservation, and technology transfer) of the PP/WM program to provide for future reductions in waste. Please see appendix H (Environmental Considerations subsections) for additional information regarding each project's compliance with Executive Order 12902.
DOE has developed an overall pollution prevention strategy and framework consistent with EPA's recommendations and other requirements (e.g., Executive Order 12856) around which its facilities must structure their own programs. This framework is the basis of Pantex Plant's strategy to implement PP/WM elements and techniques which will use a preventive approach to reduce waste by 50 percent. The program has successfully reduced waste and saved taxpayer dollars. In 1994 alone, Pantex Plant saved $2,000,000 in disposal costs. Source reduction (i.e., process change, material substitution, and administrative policies), recycling/reuse, and treatment are not designed as end products but are means for continued success.
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