POLLUTION  PREVENTION OPPORTUNITY ASSESSMENT

           GEOCHEMISTRY LABORATORY
         SANDIA NATIONAL LABORATORIES
                      by

         Kurt  Whitford  and  George  Wahl
Science Applications International Corporation
            Cincinnati,  Ohio   45203
     EPA Contract No. 68-C8-0062, WA 3-51
     SAIC Project No. 01-0832-03-1003-010
            ;    Project Officer
            '    James Bridges
     Pollution Prevention Research Branch
     Risk Reduction Engineering Laboratory
            Cincinnati,  Ohio  45268
     RISK REDUCTION ENGINEERING LABORATORY
      OFFICE OF RESEARCH AND DEVELOPMENT
     U.S. ENVIRONMENTAL PROTECTION AGENCY
            'CINCINNATI, OHIO  45268

-------
                                  DISCLAIMER
      The Information in this document has been  funded wholly or  in part by the
United  States  Environmental  Protection Agency  under  Contract  68-C8-0062  to
Science Applications  International  Corporation.   It has  been  subjected to the
Agency's review, and  it  has  been  approved for publication as  an EPA document.
Mention of trade names or commercial products does not constitute  endorsement or
recommendation for use.

-------
                                   FOREWORD


      Today's  rapidly  developing  and  changing  technologies  and  industrial
products and practices  frequently  carry  with  them the increased generation of
materials that, if improperly dealt with,  can threaten both public health and the
environment.   The  U.S.  Environmental  Protection Agency is charged by Congress
with protecting the Nation's land,  air and  water resources.  Under a mandate of
national environmental  laws, the  agency  strives  to formulate  and  implement
actions leading to a compatible balance between human activities and the ability
of natural systems to support and  nurture  life.   These laws direct the EPA to
perform research to define our environmental  problems, measure the impacts and
search for solutions.

      The Risk Reduction  Engineering Laboratory  is  responsible  for  planning,
implementing and managing  research,  development and demonstration programs to
provide  an   authoritative,  defensible  engineering  basis  in  support  of  the
policies, programs and  regulations of the  EPA with respect to drinking water,
waste  water,  pesticides,   toxic  substances,   solid  and hazardous  wastes,  and
Superfund-related activities.  This publication is one of the products of that
research and provides a vital  communication link between the researcher and the
user community.

      The Pollution Prevention Research Branch of the Risk Reduction Engineering
Laboratory  has instituted  the  Waste Reduction  Evaluations at  Federal  Sites
(WREAFS) Program  to identify,  evaluate  and  demonstrate  pollution prevention
opportunities in industrial, military and other Federal facilities!  EPA believes
the WREAFS Program will  show pollution prevention to be a cost-effective tool in
reducing the generation  and disposal of hazardous and non-hazardous wastes.  This
report  summarizes  a  pollution  prevention  opportunity  assessment  of  the
Geochemistry Laboratory at Sandia  National  Laboratories  in  Albuquerque,  New
Mexico.   The  Geochemistry Laboratory performs analysis of earth materials and
simulates extreme conditions which earth materials may be subjected to.
                          E., Timothy Oppelt,  Director
                     Risk Reduction Engineering Laboratory

-------
                                   ABSTRACT


      This report summarizes work conducted  at the Geochemistry Laboratory (GL)
at the Department of Energy's (DOE's) Sandia National  Laboratories  (SNL) facility
in Albuquerque, New Mexico as part of the U.S. Environmental Protection Agency's
(EPA) Waste  Reduction Evaluations  at Federal  Sites  (WREAFS)  Program.   This
project was funded by EPA and conducted in cooperation with DOE officials.

      The  WREAFS  program   was  developed  to  identify new  technologies  and
techniques for reducing wastes from industrial  processes at federal sites, and
to  enhance  the implementation  of  pollution  prevention  through  technology
transfer.  New techniques  and technologies for  reducing waste  generation are
identified through pollution  prevention opportunity  assessments  and  may  be
further  evaluated  through   joint  research,  development,  and  demonstration
projects.

      A pollution prevention opportunity assessment  (PPOA) was performed during
July 1992 which identified  areas for waste reduction at the GL.  The assessment
also examined opportunities  for  site-wide pollution prevention at  SNL as related
to  the  GL.    The  study followed procedures  in the  EPA Facility  Pollution
Prevention Guide (EPA/600/R-92/088).   Preliminary evaluation  of the GL revealed
the greatest  opportunity  for pollution prevention to be associated with research
project design and implementation.   This report presents potential  research
project design and materials management initiatives, as well as recycling/reuse
options to enhance  current pollution prevention progress.  Inclusion  of pollution
prevention activities in  research  proposals  would  benefit the  GL,  and  is
consistent with DOE's  stance  on  pollution  prevention.    Site-wide  central
purchasing and central distribution could reduce the amounts of expired/unused
chemicals  requiring disposal.   The process  of  escrowing closeout money at the
beginning of research projects will insure adequate  money for proper management
of  samples and chemicals in  the  event  project  funding is  withdrawn  in mid-
project.  Establishment of a "checkout system" for researchers  leaving employment
at  SNL  will  reduce the  amount  of "orphan"  chemicals  and  samples, and foster
reuse.  Modifications to the chargeback!  system could provide greater incentive
for pollution prevention while funding site-wide  pollution prevention projects.
Concurrent to  this  work,   a  PPOA  was  performed on   SNL's  Manufacturing and
Fabrication  Repair Laboratory.   The results of  that  study are  published in a
separate document.

      This report  was submitted in fulfillment  of  Contract  No.  68-08-0061 by
Science Applications International  Corporation, under the sponsorship of the U.S.
Environmental Protection Agency. This report covers  a period from 1  October 1992
to 30 April  1992,  and work  was  completed  as of 30 September 1992.

-------
                               TABLE OF CONTENTS
                                                                i          Page
Disclaimer	,	       ii
Foreword	 .  .      -Mi
Abstract  		       iv
Tables	       vi
Figures		      vii
Acknowledgements	;	     viii
Introduction  	  	        1
      Purpose	„        1
      Procedures	        2
Site Description   ....'.•	        5
Process Review	•. .  .        6
Assessment of Pollution Prevention Opportunities  	 ...       11
      Type 1  Projects   .	       11
      Type 2  Projects	       12
      Type 3  Projects	       14
      Site-wide  Opportunities  ......... 	 ....       14
Feasibility	       19
Crossfeed to Other DOE Facilities	       21
                                                                i
Measurement of Pollution Prevention 	 ...       22
Implementation Plan	 	 ...       23
Research Development and Demonstration Needs  	       26
Recommendations/Conclusions  .  . .	L .  .       27
References	  -     28
Appendix:   Definitions of Criteria Used in Rating of Pollution
 Prevention Options  .....  	 ...       29

-------
                                    TABLES
                                       i
Number                                 ;

1     Pollution  Prevention Options

2     Rating  of  Pollution Prevention Options for GL:
        Type  1,  2,  and 3 Projects  .  .
      Rating  of Pollution Prevention Options:   Site-wide Projects
Page

  13


  24

  25
                                       Vi

-------
                                    FIGURES
Number                   .   !        '                            ;          Page
1     Pollution Prevention  Program Overview 	 ...        4
2     Division 6118,  Geochemistry Lab.
         Type 1 Research Projects, Process Flow	;. .  .  .      7
3     Division 6118,  Geochemistry Lab.
         Type 2 Research Projects, Process Flow	      8
4     Division 6118,  Geochemistry Lab.
         Type 3 Research Projects, Process Flow	      9

-------
                               ACKNOWLEDGEMENTS

      The authors wish to acknowledge the help and cooperation provided by James
Krumhansl, Dorothy  Stermer and Hugh  Reilly of  Sandia  National  Laboratories.
Other Sandia employees and officials at the facility were also very helpful and
cooperative.

      This report was prepared for EPA's Pollution Prevention Research Branch by
Kurt Whitford and George Wahl  of Science Applications  International Corporation
for the U.S.  Environmental  Protection Agency under Contract No. 68-C8-0062.  The
Work Assignment Manager for this project was Gary Baker  of Science Applications
International Corporation.

-------
INTRODUCTION

      The United States Government, through legislative and executive actions,
has mandated waste  minimization as a national  environmental  policy.   Federal
statutes, such  as the  Resource Conservation and Recovery Act Amendments of 1984,
and the Pollution Prevention Act of 1990 have emphasized the need for generators
to reduce the volume and toxicity of their waste.  These laws affect all waste
generators,  including federal  facilities.    To support  pollution prevention
activities at federal  facilities, the U.S. Environmental Protection  Agency (EPA)
has established the  Waste Reduction  Evaluations at  Federal Sites  (WREAFS)
program.  WREAFS, administered  by  EPA's Risk Reduction Engineering Laboratory
(RRF.L)  in  Cincinnati,  OH.,  provides  funding  and  technical assistance  for
pollution prevention efforts at a wide variety of federal facilities.

    .  Sandia National  Laboratories (SNL) is  a  federally  owned  Department of
Energy (DOE) facility located in Albuquerque,  New Mexico.   Under the purview of
the WREAFS  program, SNL and  EPA conducted   Pollution Prevention Opportunity
Assessments  (PPOAs)  for two laboratories within  the SNL  complex.   The F'POAs
followed  the  general  format  of   the   Facility  Pollution   Prevention  Guide
(EPA/600/R-92/088).  Portions of the PPOAs also utilized the Guides  to Pollution
Prevention,  The  Fabricated  Metal  Products   Industry  (EPA/625/7-90/006).
Additional  guidance was  obtained   from the  Guides  to  Pollution  Prevention,
Research and Educational Institutions (EPA/625/7-90/010).

      This report summarizes the PPOA performed for SNL's Geochemistry Lab.  The
major  focus of the  assessment was  identification  of  pollution prevention
opportunities  within  research  project  design  and  implementation  activities.
Preliminary review of the lab's operations revealed these larger issues as the
best opportunities for pollution prevention.  Concurrent to this work,  a PPOA was
performed on SNL's Manufacturing and Fabrication Repair Lab.  This second  PPOA
examined opportunities  from a  semi-quantitative  approach,  focusing  on  wastes
generated during repair and fabrication of electronic  assemblies.  This report
is available under separate cover.

Purpose

      The PPOAs at SNL were designed to fulfill several purposes.  The primary
purpose  was   to  identify i  pollution  prevention  opportunities  within  two
laboratories that  typify  a large percentage  of operations at the Albuquerque
facility.   By  participating  in  the PPOA process, waste minimization personnel
(MinNet Representatives) would learn the mechanics of the process  and be able to
conduct  future PPOAs  themselves.   Knowledge gained  from the PPOAs  would be
distributed  throughout DOE  to  assist  other  facilities  in  their  pollution
prevention  efforts.   Also,  the findings from  the PPOAs  would  direct  future
pollution prevention research and projects.

                                       1

-------
      The WREAFS Program, whose purpose is to  identify  and  promote the use of
pollution prevention techniques and  technologies  through technology transfer,
provides an appropriate vehicle to accomplish these purposes.  Under the WREAFS
Program, innovative pollution prevention techniques/technologies are identified
through  the PPOA  process.    Various ppllution  prevention  opportunities  and
alternatives  may  then   be   evaluated   through   research,   development,  and
demonstration (RD&D)  projects.  In the past, EPA has initiated and conducted both
individual  and  joint  RD&D  projects  that  investigate pollution  prevention
alternatives.  The  results of these projects are then provided to both the public
and private sectors through various technology transfer mechanisms, including:
project reports, project  summaries, conference presentations, workshops, and EPA
information clearinghouses, libraries and document repositories.
                                       I

Procedures

      The basic  approach to  PPOAs is presented  in  EPA's  Facility Pollution
Prevention  Guide.   Figure 1 depicts  the  process.  The major  categories are:
developing a pollution  prevention program, developing  and implementing pollution
prevention projects,  measuring pollution prevention progress, and maintaining
the pollution prevention program.

      Developing a pollution prevention program  is the  initiating step in the
process.  The first four boxes in Figure 1 outline the steps.  DOE,  through Order
5400.1 has required the establishment ofiwaste minimization programs, "that will
contain  goals  for  minimizing the  volume  and  toxicity  of all  wastes  that are
generated".   Also  required  is  the  establishment of  a  Pollution Prevention
Awareness Program.   SNL has already  established  an  active  waste minimization
program  and published  a pollution prevention  awareness plan  (Sandia National
Laboratories, 1991).  Representatives frc^m line organizations and management have
formed the  waste minimization network (MinNet) to carry out  this program and
plan.   The  program and  plan are  good  starting  points for  SNL's pollution
prevention  program,  but  are  somewhat  cursory  in  nature.    These  current
initiatives  are not based  upon quantitative  waste  generation data  from the
laboratories, largely due to the absence  of sufficient historical  data on which
to base the assessments.

      Developing and implementing  pollution  prevention  projects   is the  second
step of the process.  The next five boxes  depict this part of the program.  These
activities  have already begun  at SNL. Several  pollution  prevention projects
(including  high grade paper recycling and  a chemical   exchange  program) are
currently operational.  The focus  of this PPOA was to  target  specific generators
of waste and identify opportunities  that  may also apply to  a variety of SNL
operations.   Implementation  of the opportunities  is at  the  discretion of SNL.

      Measuring pollution prevention progress will  be accomplished at SNL through
several  mechanisms,  including  a  "chargeback" system  which will  track waste
generation  in  addition  to  providing funds  for future  pollution prevention
projects.

-------
                g the  pollution  prevention  program  will   involve  continuing
education in pollution prevention for SNL employees.  Periodic program evaluation
and reporting  to DOE also increases the visibility and  viability of the program.
                           i                                     i
      The specific approach taken  for the Geochemistry Lab  (GL)  differs from
other PPOAs in  that  it focuses on  the larger issues of research  and testing
design  instead  of quantitative  assessment  of  specific waste  :streams.   The
approach was chosen after discussions with SNL staff identified termination of
funding in mid-project  as generating the largest amount of waste.  Concerns with
disposal of samples after completion of projects also pointed to opportunities
for pollution prevention  in  research design.   It was also noted that  the GL
engages in a variety of small  research projects  spanning  a range of subjects.
Consequently,  research design modifications would produce more consistent results
than identifying individual processes which are not consistently'used from year
to year.  Finally, this approach for the GL complements the  other PPOA performed
concurrently at  SNL under WREAFS which examined specific waste streams generated
by  a  repair  lab.    This  second  report,  Pollution  Prevention  Opportunity
Assessment;  Manufacturing and Fabrication Repair  Laboratory at Sandia National
Laboratories  is available  from  the National  Technical   Information  Service
(Telephone, 703-487-4650).

      The approach was implemented by  involving SNL staff  in  the PPOA process
through  several  meetings  and  tours  of the  GL.    During  these  meetings
representatives  of  SNL's  pollution  prevention  program,  GL staff,  EPA-RREL
personnel, and the EPA contractor discussed the genesis, development, funding and
implementation of projects.  Opportunities and constraints on building pollution
prevention into research  projects were discussed.   SNL policies  that  impact
pollution prevention also were examined.   These discussions have been distilled
into  recommendations  presented within  this  report.    Implementation  of these
recommendations is at the discretion of SNL and DOE.

-------
         Establish Pollution Prevention Program
                  •  Executive Laval Decision
                  •  Policy Statement
                  .  Canton*)* Building	
                   Organize Program
                     •  Name Taak Force
                     •  State Goals
              Oo Preliminary Assessment
                    • Collect Data
                    • Review Site*
                    • Establish Priorities
                  Write Program Plan
                 •  Consider External Groups
                 •  Define Objective*
                 •  Identify Potential Obstacles
                 •  Develop  Schedule	
                Do Detailed Assessment
                • Name Assessment Toam(s)
                • Review Dsts end Srts(s)
                « Organize end Document Information
Define Pollution Prevention Options
* Propose Options
• Screen Options
! i
>
Do Feasibility Analyses
• Technical
* Environmental
• Economic
1

Write Assessment Report
i
>
Implement the Plan
• Select Projects
• Obtain Funding
• Innall
                   Measure Progress
                    I  • Aoouire Oats
         Maintain Pollution Prevention Overview
Figure 1.  Pollution Prevention  Program Overview.

-------
SITE DESCRIPTION           ,  "       '.-
                           !
      Sandia National  Laboratories (SNL)  is  owned by the U.S. Government arid is
operated by Sandia Corporation,  a subsidiary  of AT&T,  under a prime operating
contract  with the  DOE.   :SNL  has  two  major  locations,  Livermore,  CA  and
Albuquerque, NM.  SNL,  Albuquerque is  located south  of Albuquerque within the
boundaries of Kirtland Air Force Base, in Bernalillo County.  SNL, Albuquerque
consists of five technical areas and several remote test areas.  SNL's primary
mission has been national security, with principle emphasis on nuclear weapons
development and engineering.   In the process of  carrying out  this mission, SNL
has evolved into a multiprogram laboratory  pursuing  broad aspects of national
security issues.  As  a  byproduct of production, research  and development, and
environmental restoration activities, SNL generates a variety of waste materials
that are regulated by the federal government  and state and local  agencies (Sandia
National Laboratories,  1991).

      In  the  process  of  pursuing  compliance  with  DOE  orders  requiring
organization and implementation of waste minimization projects, SNL has developed
an active pollution prevention  program.  In  Sandia  National Laboratories Waste
Minimization and Pollution Prevention Awareness Plan, the level  of importance is
established by the Statement of Management Support and Commitment:

      "Sandia's Environment,  Safety and Health Council (SEC),  comprised of
      the President,  the  Executive Vice  Presidents,   all  of  the Vice
      Presidents, and the Director of Environment, Safety  and  Health, is
      totally committed to minimizing  the  generation of waste by  giving
      preference  to   source   reduction,   material   substitution,  and
      environmentally sound Recycling over treatment, control  and  disposal
      of wastes.  The  SEC will take appropriate action to provide  adequate
      personnel, budget, training, and material on a continuing  basis to
      ensure that the objectives of the Waste Minimization and Pollution
      Prevention Awareness Program are met."

      SNL has established the Waste Minimization Steering Committee composed of
a cross-section of SNL  staff.  A network of waste minimization representatives
(MinNet Reps) also has been developed.  MinNet  Reps assist the line organizations
in planning,  organizing and  directing  activities  to meet pollution prevention
goals within  the line organizations.  They participate in review of proposed
projects, and receive  pollution  prevention training at  SNL,  Albuquerque and
Livermore.                 i

-------
PROCESS REVIEW

      The GL, located  in Building 823, was  chosen  for one of  the  two WREAFS
PPOAs.  The  lab performs analysis of  earth  materials  (primarily physical  and
composition analysis) and simulates earth  conditions  (e.g., subjecting rocks to
high temperatures and pressures).  The types of research performed by  the GL fall
into three major categories.  For the purposes of this PPOA these project types
are considered  the  three types of processes performed by the lab.   Figures 2
through  4 show  the process  flow diagrams.   All  types  of projects  produce
relatively similar types of wastes, including:  used  samples; materials generated
in  the process  of  sample  analysis;  and synthesized  materials from  sample
preparation.                           j
                                       !
      Type 1  projects are those where the GL prepares an  unsolicited proposal and
submits it to one of several DOE sponsors for approval  and funding (see Figure
2).  The DOE sponsors include  Basic Energy Sciences,  Energy Services, and other
DOE groups funding military/intelligence projects.  The proposals are developed
from the researcher's interests in areas jof geochemistry that could further DOE's
research objectives.  An example of proposals for type 1 research projects is,
"Isotopic and Mineralogical Indicators \ of Infiltration in Unsaturated Zones"
(Lambert, 1992).  The general approach for these projects  is:   preparation and
submission of proposal; acceptance by a sponsor; implementation of the project;
and shutdown/closeout.   Type  1 projects  are the largest  in scope  and budget,
typically generating funding  for  1  or 2 people  for several years ($100,000 to
$300,000/yr).  While funding is renewable, the funding is approved on a one year
basis.  Typically less than 10 percent of these projects are terminated before
the anticipated project end; this would only  happen if there were major changes
in  DOE policy/funding.   This type  of project  accounts  for  approximately 40
percent of the lab's workload.

      Type 2 projects are those where a proposal  is  being implemented by another
group and the GL is  asked to assist due to  their  capabilities and expertise (see
Figure 3).  These projects are the most likely to be prematurely terminated and,
consequently, are the largest producers  of waste.   Bench top  wet chemistry
research in this type of project  also contributes to  GL waste production.  Type
2 projects are  usually of medium duration and  funding.   This type  of project
typically does not have a formal statement  of work (SOW)  or  similar instructions.
An example of this type of project is the examination of brine inclusions in salt
formations at DOE's Waste Isolation Pilot Plant (WIPP) site.   Funding for this
project was withdrawn before completion,  leaving the GL with 50 pounds of rock
salt that reportedly must be disposed  of as chemical  waste. The  project did not
generate  any unique chemicals that  could  not  be used  in ongoing  or future
projects.   These  projects  account  for   approximately  50 percent  of the  GL
work! oad.

-------
                                          Researcher Prepares
                                          UnsoUalad Proposal
                                       Researcher Submits Proposal
                                            to DOE Sponsor
                                          DOE Funds Resoarch?
                                      Researcher Implements Protect
                                       Researcher Complete* Project
                                        Surplus Sampla Remoinng?
Sample or Previously Archmd
Samp* Obpocad. Soimmo*
    asOMmiealWUti
                                       SurpkjB Chemcato RomainJng?

                                                     •
                                                   YES
                                        Chemcats Potanlatty U»tul
                                            in Other Projeca?
   Chemicals or Prevousty
 Retamod Cnemcala Otspcoed
     as CtMmcaJ Wast*
   Sufroenl Space
for Retanng Crtemcahi?
                                           Chemcals Hotamed
                                        Proiad Racuns Compted
                                             andPuMshed
        Figure 2.  Division 6118 Geochemistry  Lab.
          Type 1 Research Projects.  Process Row

-------
                                                       Assistance in Projact
                                                    Requested From Researcher
                                                  Researcher Commences Work
                                                    Funding for Work Continues?
  Work on Project Ceases
  Funds Available for Closeout?
                                                    Surplus Sample Remaining?

                                                                mm
                                                                YES
   Samples, Chemicals,
   Wastes Remain in Lab
                                                      Sample to be Archived?

                                                                •H
                                                                YES
Sample or Previously Archived
    Sample Disposed a*
      Chemical Waits
                                                         Sufficient Space
                                                      for Archiving Sample?
                                                        Sample Archived
                                                   Surplus Chemicals Remaining?

                                                                MB
                                                                YES
Project Closeout Completed
                                                    Chemicals Potentially Usaful
                                                        in Other Projects?
   Chemicals or Previously
Retained Chemicals Disposed
     as Chemical Waste
                                                        Sufficient Space
                                                     for Retaining Chemcalo?
                                                       Chemicals Retained
              Figure 3.  Division 6118 Geochemistry Lab.
               Type 2 Research Projects, Process Flow

-------
Assistance in Performing 1
Specific Task Requested i
From Researcher fl
1
r
                                                  Researcher Commences Work
                                                   Researcher Completes Work
                                                    Surplus Sample Remaining?

                                                                HBI
                                                                YES
                                                       Sample to be Archived?

                                                                •H
                                                                YES
Sample or Previously Archived
    Sample Disposed aa
      Chemical Waste
                                                         Sufficient Space
                                                      for Archiving Sample?
                                                         Sample Archived
                                                   Surplus Chemicals Remaining?

                                                                 ••
                                                                 YES
Project Closeout Completed   I
                                                     Chemicals Potentially Useful
                                                         in Other Projects?
   Chemicals or Previously
 Retained Chemicals Disposed
     as Chemical Waste
                                                        Sufficient Space
                                                     for Retaining Chemicals?
                                                        Chemicals Retained
                Figure 4.  Division 6118 Geochemistry Lab.
                 Type 3 Research Projects. Process Row

-------
      Type  3  projects  are  those  wher£  the  GL  is  requested  by  other  SNL
researchers to do a specific task  (see Figure  4).   An  example of this type of
project is where the GL  is asked to determine the types  of chromium compounds in
a soil sample.  For these projects neither a formal  SOW, nor a work request is
generated. These projects are commonly done  as  "freebies" which, if successful,
can turn into  type 2 projects.  They are of short duration, usually requiring one
to three days of laboratory work.  These projects account for approximately 10
percent of the GL workload.                                        /

      The GL has established at  least two "libraries"  where materials accumulate.
The sample  library is where rock and soil  samples  are archived.   Samples are
usually archived to allow retesting,  should  the validity of previous results be
questioned.   Other samples  are archived due to their  uniqueness  of origin or
composition.  Samples continue  to accumujlate until there is  no more space.  They
are then disposed usually as chemical waste.   Unique  samples are either retained
indefinitely  or archived at sites where they  were collected.   The  chemical
library is the second collection, consisting of chemicals that were not consumed
during projects.

      The GL utilizes a variety  of analytical  instruments in performing research,
including:  an atomic emission spectrophotometer; scanning electron microscope
(SEM);   x-ray  diffraction   analyzer;  scintillation  counter;   and   an  ion
chromatograph.   Various wet chemistry  techniques  are also  utilized.   Sample
preparation employs grinding, sieving and polishing  equipment.  Additionally, a
small machine shop, comprised of  a  drill press, lathe and grinder,  is located in
the lab.

      The largest waste  stream, by  volume, generated by the^GL  is Polaroid film
backs from SEM photography.   The estimated annual production of this waste  is 14
kg.   The largest waste  stream,  by weight,  is  discarded unused  samples  (e.g.
cement cores,  rocks,  soils,  etc.).  As, discussed above, this waste stream is
generated on  an infrequent basis.  Consequently, annual generation data is not
available.  The balance of remaining wastes are mostly spent solutions and solids
from  various  analytical  techniques employed in the  GL.   The estimated annual
production  of these  wastes  is 77  kg.   Due to the  varied  nature of research
perfumed in the GL,  waste generation is  not consistent between projects and/or
years.   The use of prior waste generation  data, therefore,  is not an optimal
indicator of future waste generation, or a sufficient "yardstick" for measuring
the success of pollution prevention projects.
                                       10

-------
ASSESSMENT OF POLLUTION PREVENTION OPPORTUNITIES
                            '                                    i
      While this report proposes pollution prevention opportunities related to
laboratory research, it acknowledges that investigators  must  primarily focus on
performance of  successful  research.   If  researchers  have the perception that
pollution prevention projects could jeopardize reproducible scientific results,
they may be resistant  to  implementation  of the concepts.  Hopefully,  there is
some middle ground between pollution prevention and  research  concerns that will
allow research  work to proceed efficiently  while  simultaneously reducing the
amount of waste generated.                                      ;

      Each of the three types of research  projects performed  by the GL presents
opportunities  for  pollution prevention.    The ability  to   affect  pollution
prevention increases with increasing control  of the  project by GL staff.  Table
1 lists pollution prevention!options for the GL,  as well as site-wide options for
SNL.  Additional  pollution  prevention ideas  for SNL can be  found in Guides to
Pollution Prevention. Research and Educational Institutions (EPA/625/7-90/010 ).

Type 1 Projects

      Type 1 projects afford the most opportunity to  design pollution prevention
into  research  activities.    Since  the  research hypothesis  is generated  by
laboratory personnel,  the  research design  is  limited  only by  imagination,
technology, and perceived budgetary constraints. The  design  can therefore take
into  consideration  potential  wastes generated and  methods to reduce  their
quantities and toxicity.

      Proposals for research should reflect DOE's stated  commitment to pollution
prevention.   While the proposal may  include increased cost  due  to pollution
prevention activities,  the document should emphasize the need for these aspects
within  research,   and  point  out  the  benefits  to  DOE  derived! from  funding
environmentally sound research.  These benefits include: transferable experience
in applying pollution  prevention to  research projects;  increased publicity of
DOE's environmental  efforts'; and  decreased  liability associated with  funding
research that generates excessive amounts of environmental pollutants.  Inclusion
of pollution  prevention activities  in research proposals also will increase DOE
awareness of implementation opportunities.                      ;

      When designing  the  proposal,  the   researcher  has the opportunity  to
incorporate micro-techniques for analysis and  good laboratory practices for waste
handling.  Several  pertinent references for obtaining information iin these areas
are available.  One such reference, published by the American Chemical  Society
is, Less is Better, Laboratory Chemical  Management for Waste  Reduction (1985).
                                      11

-------
      Type 1  research projects  also  offer the  best  opportunity to  build  in
funding for proper waste management.  A portion of the  budget could be allocated
for waste characterization, to reduce the amount of nonhazardous waste that is
disposed as  hazardous.   The funds necessary to  implement  in-lab treatment of
wastes, such as neutralization of acids, could be included. This treatment would
reduce  the  quantity  of  hazardous waste  disposed through  less  appropriate
practices (e.g., incineration of acids present in lab packs).   Current federal
regulations allow elemental neutralization of acids at the laboratory (40 CFR,
1991).      ,                           ;

      Another opportunity to reduce the quantities of waste generated by these
projects  is   to   include   mechanisms  and  funding   for  return  of  unused,
uncontaminated samples of environmental media to the point of collection, or to
the  SNL grounds.   While  the  initial  perception  of  such  a  practice  may  be
negative, EPA, through their "contained in" policy has  stated that environmental
media are not solid waste (56  FR 24456, 1991).   Unused portions of samples that
were not collected from contaminated sites, and were not contaminated while at
the laboratory would not meet the federal definition of solid waste.  As such,
these  samples  could  be  stored until  transportation  back  to  the  point  of
collection became  available.  Another  alternative would be  to  place the media
with  like materials  at  the  SNL  complex.   Analytical  records  from initial
analyses, or sample testing could be retained in order to verify the non-waste
status of the material.  This approach could be expanded  to include construction
material  samples,  such as  concrete.   These  uncontaminated samples  could  be
processed into usable materials (e.g., concrete and rock samples  could be reduced
to appropriate size and used as  aggregate  in road construction activities.)

      Given DOE's  commitment  to waste minimization,  researchers could submit
proposals for  the  development of pollution prevention techniques within their
research specialty.  These proposals could include research on microanalytical
techniques,  minimum  quantities  of  samples  needed  to  generate reproducible
results, and comparison of standard and innovative methods.  Funding of pollution
prevention research would have immediate and long term benefits for DOE.

Type 2 Projects

      As previously discussed,  this  type of GL  project generates the largest
amount of waste, primarily due to withdrawal of funding (and consequent shutdown
of the project) prior  to project  completion.  Researchers in this  situation have
no money  to  complete  the work,  or to clean up  from the project.  Samples and
specialty  chemicals may  remain in  the  lab  until  storage  capacity  requires
disposal.   If a significant amount  ofitime has  elapsed,  the  composition and
regulatory status  of  materials  may no longer  be known,  requiring "worst case
scenario" disposal.                    :

      Prior to  participating  in this type of  project,  a portion of available
funds could be escrowed to cover the cosjt of project closeout.   This money would
remain available for characterization and disposal of  wastes from the project.
                                       12

-------
                          TABLE  1.   POLLUTION  PREVENTION  OPTIONS
 ARE-A
                        OPTION
Geochemistry Lab

  Type 1  Projects
  Type 2 Projects
  Type  3  Projects





Site-Wide

  CMIHS
 Design pollution prevention into proposals
 for research,act i vi t i es.

 Build in funding for proper waste management.

 Include mechanisms and funding  for  return of unused uncontaminated samples of
 environmental  media to the point of collection, or to the SNL grounds.

 Escrow a portion of available funds to cover the cost of project closeout.

 Contact other  labs within SNL before ordering chemicals in order to determine
 their availability.

 Encourage chemical suppliers to accept returned, unopened chemicals and issue
 refund or credit.                                             '

•Exert tighter  controls on sample sizes sent to GL.

 Determine sample quantities needed  and alternatives to sample analysis.

 Continue/expand use  of microanalytical techniques.             ;

 Return to requestor  unused portions of samples.
                        Provide a life cycling and control mechanism for chemical materials from the
                        point of entry to departure from the facility.                 '
  Central Purchasing     Educate procurement personnel  to  spot material substitution,opportunities.
  Central
  Distribution
 Checkout System



 Chemical Exchange





 Chorgeback System
 Determine usage patterns of operations that commonly use and dispose of certain
 chemicals.

 Order specialty chemicals through a site-wide stockroom.

 Identify other  potential users in order to utilize the remaining portion of the
 minimum lot  prior  to  the expiration date.

 Require employees  retiring or leaving the lab to report the status of chemicals
 and samples  present in their labs.


 Require supplying  researcher to certify that the contents of an opened container
 have not been altered by the addition of contaminants or improper storage.

 Explore ways 'to use expired chemicals for other applications.

 Use chargeback  money  for site-wide pollution prevention projects instead of
 laboratory-specific applications.
                                                   13

-------
Timely determination  of  waste status would decrease the need  for  "worst case
scenario" disposal.  These  funds could also be used to locate potential users of
remaining chemicals within SNL.

      Before ordering chemicals for the  project, other labs within SNL could be
contacted to determine the availability of the materials.  The GL  could use a
portion or  all  of the chemical in demand, reimbursing  the providing lab with
laboratory funds or the same amount of chemical the next time the GL receives a
supply.   This  sharing could  have  the added  benefit of using  older chemicals
first, reducing the quantities of expired chemicals generated by SNL.

      Due to  the  potential  for type 2  projects  to be  terminated  prior  to
completion, suppliers should be urged to accept returned, unopened chemicals and
issue a refund  or credit.  'Agreements with  suppliers concerning this practice
will reduce the need for  disposal of specialty chemicals  for which no other need
is apparent over  the material's shelf life.

      Although the  exact amount  of sample needed  for this type of project is
difficult to  estimate,  tighter controls  on  sample size sent  to the GL would
reduce the quantities of waste requiring disposal.  Samples could be collected
(and homogenized  if necessary) at the site, with only the estimated quantities
required for analysis shipped to the lab.   If additional quantities are needed,
the "stockpiled"  sample  could  be shipped to the lab to continue the analysis.

      The form in which  samples are generated could be specified to facilitate
use of samples not required  for analysis or archival.  For example, samples of
uncontaminated concrete could be cast into usable shapes, such as paving blocks,
and used at SNL after subsamples were collected and the project completed.

Type 3 Projects                         !

      Since  this  type  of  project  is  dictated  by   the  requester,   (e.g.,
determination  of the species  of chromium present in soil  samples) pollution
prevention opportunities are  the most constrained.  Notwithstanding,  measures can
be taken to reduce the amount of waste generated.   Through discussions with the
requester, sample quantities needed and  alternatives  to  standard analyses could
be  determined.    The  data  quality objectives  for  the analysis could  allow a
reduction  in  the number of  replicate analyses, reducing  the  amount of sample
required.  As with the other  types of projects, microanalytical  techniques could
be employed to reduce waste generation.•! These techniques  are currently  used in
the GL,  and could  be expanded as  new  methods are developed.   If  subsequent
analyses are to be performed on the material in question, unused portions of the
sample could either be  retained by the  GL (if that lab is performing the next
analysis) or returned to the requester, in order that the same samples can be
forwarded to the  next lab  for analysis.

Site-wide Opportunities

      In  addition  to  pollution  prevention  opportunities  described   above,
additional  approaches,  if  implemented  site-wide,   could  offer   significant
reduction in waste generation at SNL.  These opportunities cut across  laboratory

                                      14

-------
boundaries and are applicable to a variety of SNL operations.

Chemical Materials Management System

      A comprehensive Chemical Materials  Management  System (CMMS)  could be an
effective pollution prevention tool  at  SNL.  This type of system (called CIS) is
currently in use at SNL,  Livermore and  in the design  stages at SNL, Albuquerque.
The CMMS at Kelly Air Force Base's San Antonio Logistics Center  has proven to be
an effective chemical use and waste tracking system.   The system provides a life
cycle tracking and  control mechanism  for  chemical materials from the point of
entry to departure from the Center.  The system was designed to  satisfy several
objectives, including:

      •   meeting federally mandated chemical exposure and release ("right-to-
          know")  information, standards.                         ;

      •   assessing the hazardous nature of chemicals to be used at the facility
          prior to use      ;

      •   development of  a "paper trail" to keep managers  informed of quantities
          and  locations  of materials currently  in use

      •   identification  of unauthorized practices, such as improper storage and
          excessive stockpiling of  chemicals

While changes  in  the form of chemicals,  via chemical reactions, may make tracking
by mass-balance analysis  difficult in smaller labs, the system still could be an
important pollution prevention tool.

Central Purchasing                                      -  .     \

      At SNL the current practice is for  individual laboratories,  or at most,
divisions to identify their chemical needs and order  supplies through a central
purchasing department.  Central  purchasing treats this request as an individual
need, ordering the  specific; type and  quantity requested.   Depending on usage
rates, shelf life and minimum lot sizes, the potential exists for generation of
significant quantities of waste in the form of unused chemicals.  This type of
waste represents a double cost to SNL,  since the chemicals were!purchased and
never used, and now must be disposed.                            ;

      SNL could potentially reduce the  amount of waste  generated  by educating
procurement personnel  to  spot material  substitution opportunities.   It  is
realized that procurement personnel  cannot order less hazardous materials  when
specific chemicals  are  requested by  researchers.    Personnel   can  be trained,
however, to identify and purchase  less  hazardous materials for more  generic
functions.  Implementation could begin with chemicals used in large quantities.

      Central  purchasing personnel  also  could  require potential suppliers  to
forward information on chemical manufactures' assignment of expiration  dates.
Chemical manufacturers often set  expiration dates based upon worst case storage
scenarios or conservative judgement.  By requiring documentation on expiration

                                      15

-------
date testing, SNL can assess the actual:site specific shelf life of chemicals,
and reduce the quantity of unused chemicals that are disposed.

Central Distribution

      SNL also could reduce  the  amount  of unused chemical waste by establishing
a central distribution system, or site-wide stockroom. Using central purchasing
and waste disposal records,  operations  that commonly  use and dispose of certain
chemicals  could  be  identified  and  their  usage  patterns  determined.   These
chemicals could be purchased in  bulk, or minimum lots (depending  on usage).  The
end users could then  receive the  needed  amount  from the stockroom.   Specialty
chemicals for which a laboratory uses less  than minimum lot quantities during a
lot's shelf life could also be ordered through the site-wide stockroom.  Other
potential users could be identified (including operations that could substitute
one of these chemicals for those currently  in use) and the remaining portion of
the minimum lot could be utilized prior to  the expiration date.  One example of
the benefit of this system is with the  Materials Fabrication Repair Lab (MFRL).
This lab  repairs  electronic equipment  by,  among other operations,  applying an
adhesive to connect electronic parts. The type of adhesive can only be purchased
in  minimum lot quantities  that the MFRL  cannot use  prior to  exceeding  the
expiration date for the shipment.   Usual  operations require  several  drops of
adhesive, and since the adhesive comes  ih 1 ml  syringes,  the remaining amount is
routinely  discarded.  The MFRL  currently  shares  the purchased  adhesive with
another operation, but still does not utilize the entire lot prior to expiration.
If  a site-wide stockroom purchased the adhesive, and identified other users of
adhesives, SNL could potentially use the entire lot prior to the expiration date.

Checkout System                        \

      SNL could establish a  "checkout system" for  researchers that are retiring
or  otherwise  leaving  employment.   These  researchers possess the most detailed
knowledge  of their laboratory operation^ and the status of samples and chemicals
present  in their  labs.   Prior  to terminating  employment, the researcher could
review all retained samples, properly  disposing of those no longer needed, and
clearly  documenting the composition and  regulatory status of those remaining.
If this procedure were followed, subsequent researchers in that lab  would  not be
saddled with  disposal  of samples  of  unknown materials.

      Similarly, laboratory  chemicals used by the researcher could be inventoried
and properly managed.  All chemicals  remaining in the lab after departure  of the
researcher could be clearly  labeled with a minimum of chemical name, manufacturer
and expiration date.  Chemicals that will no longer be used by the lab  should be
made available to other researchers via ;the chemical exchange system.  Chemicals
for which there are no further  uses,  and  wastes,  could be disposed while the
researcher is still  available to  answer  questions about the materials.

Chemical  Exchange                     !

      SNL could further reduce  disposal  of chemicals by modifying  the  chemical
exchange program  to include opened, expired and waste chemicals.  The primary
concerns  with these materials are adulteration  and  performance.  Concerns  with

                                       16

-------
adulteration  potentially  could  be  alleviated  by  requiring  |the  supplying
researcher to certify, through personal knowledge,  that the contents of opened
containers have not been altered by addition of contaminants or improper storage.
This  type of  accountability  should  decrease  concerns  about  quality,  since
researchers will  be certifying usability  to  their peers.   While the supplying
researcher  may be  reluctant  to  certify   chemical  purity (due  to perception
concerns), savings  in costs  incurred via the chargeback system, and heightened
awareness of the  need for effective pollution prevention, may offset concerns.

      Many chemicals  used for  laboratory  purposes are produced  in differing
grades of purity (e.g. HPLC, analytical,  technical).  While expired chemicals may
not be suitable for use within their original  grade,  they could be: used for other
applications.  For  example,  expired HPLC grade acetone would still be suitable
for cleaning glassware.  Acids that are no longer suitable for making reagents
could be used for cleaning or neutralizing basic solutions prior to disposal.

      Chemicals that have been used and  are considered waste by a laboratory at
SNL may still have value through reuse or reclamation.  Dilute acids with known
contaminants could  be used in other processes where the contaminants would not
effect process quality.   Exotic  chemicals  used  at  SNL could  be reclaimed at a
centralized reclamation area.   The value  of  these  exotic  chemicals,  or exotic
contaminants,  may  offset  the cost  of  reclamation  through  reuse  or  resale.
Development of a reclamation  operation would proceed slowly with initial efforts
focusing on easily  reclaimed, extremely expensive chemicals that are currently
disposed as hazardous waste.                                    !

Charqeback System

      SNL,  as  part of  its  pollution  prevention  program,   has  developed  a
chargeback system for waste  generation.   The  system currently  requires  the
payment  of  $11.00/kg of  hazardous waste  disposed.   Funds  collected  from  a
laboratory  are available  to  the lab  to be  used  for   pollution  prevention
activities.    These activities could  include library research,  or laboratory
projects aimed at  reduction of waste generation.   By design, the money collected
from a lab must be reinvested in that organization.   Funds  collected  via the
chargeback  system  also  will  be  used  to  fund  the  corresponding  MinNet
Representative position.

      The chargeback system could  be made even more  effective  if funds were also
used for  site-wide projects.   While laboratory  specific projects benefit  a
particular  lab,   and,  ideally,  analogous operations,    site-wide  pollution
prevention projects usually produce a larger benefit by positively affecting more
operations.   The flexibility of being able to fund both specific and site-wide
pollution prevention initiatives  could  increase  the cost-effectiveness  of the
chargeback system.

Education

      Perhaps the  most  important  key to  reducing  waste  at  SNL  is  educating
laboratory personnel to  be conscious  of  both  the amounts of waste they generate
and potential ways to reduce those amounts.  Pollution prevention concepts could

                                      17

-------
be emphasized  by "MinNet champions" who  specialize  in specific areas.   SNL,
through its pollution prevention awareness plan,  is addressing this area.  Still,
a researcher may not consider  his  or her waste  contributions a problem.   When
multiplied by the number of researchers at SNL however, the cumulative amounts
are large.  Completion  of process waste [assessments (PWAs) for SNL laboratories
would call attention to the types and amounts of wastes generated by individual
labs,  but may not  be  cost-effective  in  all  situations.   Alternatives  to  a
comprehensive  PWA  program  could  be explored.    Continued dissemination  of
pollution  prevention  initiatives  and  findings  throughout  SNL and  DOE  could
reinforce the global need for pollution prevention.
                                       18

-------
FEASIBILITY

      The nature  of waste  igeneration at  SNL presents  certain obstacles  to
pollution prevention initiatives.  The number of laboratories and the nature of
laboratory work result in a large number of small  quantity wasteistreams being
generated.   Conducting  quantitative analysis of the  feasibility  of pollution
prevention opportunities may not be cost effective, given the small amounts of
waste generated by individual labs.

      The need for generation of reproducible  lab results and the strong reliance
on standard  methods  hinder  implementation  of pollution prevention initiatives
that could call into question a researcher's findings.  The complexity of federal
and  state hazardous  waste ! regulations  also  makes  scientists  reluctant  to
implement many pollution prevention activities.  The  feasibility  of'pollution
prevention  opportunities discussed   in  this  report,  therefore,  is  largely
dependant on the  attitude and  confidence  of SNL's researchers.   If,  through
education and training, the importance  of pollution prevention is elevated to the
level of other crucial  scientific  principles,  significant reductions  in waste
generation within SNL's labs can be achieved.

      Many of the pollution prevention  opportunities discussed in this report are
feasible  and  readily   implementable   through  researcher  and  administration
initiatives. Tables  2 and 3 present qualitative ratings of pollution prevention
options for  6L projects and site-wide,  respectively.    Each option was subjected
to eight criteria and rated  (see appendix A for criteria definitions).  Options
affording the greatest  benefit or least detrimental effect for a criterion were
assigned a "5" for that criterion.  Options affording the  least benefit, or most
detrimental   effect were  assigned a "1".   The ratings  were  summed  and  a total
score given  for each option.  While the totals indicate that implementation of
certain options would  be more  feasible  than others,  the range; of totals  is
sufficiently narrow to require SNL discretion in prioritizing the  options.
                            i
      Given   DOE's  stated commitment  to  pollution  prevention, proposals  that
include  waste minimization components should be favored over similar research
that does not address waste  generation. Submission of  these types of proposals
would require researchers tO|invest  additional  time in proposal preparation.  The
increased chances of DOE funding the proposal  (due to its pollution  prevention
aspects)  and the  potential  savings  in  disposal   cost,  however;,   justify the
increased  effort.    Building  pollution  prevention   into  research  proposals
consequently is one of the most feasible initiatives.

      Closeout  of projects that  end prior  to scheduled completion  is  feasible
only if the  organization supplying the funding is  willing to "esprow"  closeout
costs up front.  Many of the mechanisms for funding  SNL  research projects do not
provide for the carry over of money between fiscal  years.  Consequently,

                                       19                        I

-------
implementation of this option must  ba  in  concert  with  DOE.   Implementation of
this  option  by  the researcher  should be  feasible,  as  long  as funding  is
available.                              !

      Site-wide pollution prevention opportunities offer the greatest potential
for waste reduction.   The site-wide  options identified  in  this report  are
technically feasible.   Many  of the options  are  already being  developed  and
implemented at SNL.   With the recommended modifications, implementation of these
options will be even more effective.   Although increased costs would be incurred,
the increase would be offset  by savings in  disposal  costs.   While researchers
would have to  modify procurement habits, and may have to spend  increased time in
tracking materials, the program may  assist researchers in preparing for future
projects by being aware of intra- and  inter-laboratory resources.
                                       20

-------
CROSSFEED TO OTHER DOE FACILITIES

       Many DOE  facilities'contain research  laboratories  and almost  all  use
chemicals in support of facility operations.  Both laboratory specific and site-
wide pollution prevention opportunities could be implemented at other locations.
As a  result of DOE's  proactive  stance on pollution  prevention,  successfully
implemented options at SNL would be quickly disseminated to other locations.
                                      21

-------
MEASUREMENT OF POLLUTION PREVENTION    ;

      The  success  of  implemented  pollution  prevention  options  for  research
projects may  not  be easily measured, since projects vary  widely  in scope and
waste generation.  Researchers would have  to estimate baseline waste generation
using previous records and  best judgement.  Waste quantities and types generated
during subsequent research could then be compared.  The effectiveness of site-
wide pollution prevention projects could  be better measured once SNL implements
the CMMS.
                                       22

-------
IMPLEMENTATION PLAN

      Implementation of pollution prevention opportunities identified by the PPOA
is>at the discretion of SNL. Many opportunities, such as controlling sample size
cou'ld  be   implemented  in  the  near  future.    Others,  such  as  centralized
distribution, will  require  additional planning and resources.  Implementation of
some  pollution  prevention  techniques will  not be  feasible  until  researchers
obtain a clearer understanding of waste regulations and policies.  Concerns with
"doing the  right thing"are often amplified in researchers and other professionals
used to relying on empirical data  to make  decisions.   Unless waste management
issues are clearly  documented,  researchers will be reluctant  to  deviate from
current waste management approaches.
                                      23

-------



I
8
LU
i
0.
to

"0
{5
„
CM
•t
uj
Q*
^^*
H-
tm
^.J
CD
oi
0
UU
cr>
p
0.
o
J»
0
UJ

UJ
ce
CU

0

H-
_I
_l
O
o.
UU
o
§
i
CM
UJ

OJ
O
t—
"8 -g
W M- Z*
OH-.;;
- *"
1_-
•2°
8> **
ra °
an °

§ **
'« §.
.2 I"
X """

"8"S
II
t- o
0 0.

g
*!^
"o g
co i
ro P
LU JJ
fr
B.H&
*AJ ^ ^*
g I 0
*^ O ft)
2""*
g g x
••" « ° b
3 S £ o
•g S .jj £
O. n* K


O o
^ i
z «


Dilution Prevention Option
Q.
O (MO
to to to


in in *»•


tn in in




in in in



in «- «-






«* •* to





in in •*




in to to





tn -» in


CO
g £*
YPE 1 PROJECTS
Designing pollution preventi
into proposals for research
activities
Build in funding for proper waste
management
Return of unused, contaminated sam|
to point of collection or SNL groui
h-
8


in


tn




to



-






CM





•*




CM





**


0
4*
tn
YPE 2 PROJECTS
Escrow a portion of available fund:
cover the cost of project closeout
i—
in
to


in


tn




•*



to






to





in




in





tn


I











































Contact other labs within SNL befo
ordering .chemicals in order to defr
their availability


(M
to


in


Vf




"*



to






to





**




•*





in


CU CO
U CO
Encourage chemical suppliers to ac
returned, unopened chemicals and i
refund or credit

S


in


Sf




•*



to






to





to




in





in


N
Exert tighter controls on sample s
sent to GL

in
to


**


in




in



to






-»





**




in





in


CD
YPE 3 PROJECTS
Determine sample quantities needed
i—
«- o
to to


to in


•* in




in in



to «-






to cvi





•* •*




in ro





-* in


CO
•h
alternatives to sample analyses
Expand use of microanalytical tech
Retain or return to requester unus












































portions of samples







ti
H-
"S
(U
3
2
0
CD
»+-
CO
2
c
"C"
s-
1
CO
._
•g
a

*J
H-
2
n
£.
§
•£
1
O)
c
H-
'E
O>
'5
in
^
'5

1
£
Pollution prevention options
*

-------





*
o
UJ
"•3
O.
UJ
o
1-4

1


1— 1
• •
o
0-H

O

P
UJ
3>
Ul
an
o.

o
^
^

^i
o
Q.
U.
O

CO
M
!i

•
Ul
CO
4j
O
1—
1*1
^ (o 8
•-?
| f
z °

.- o
ll
XT ^^

•Q _>

Q> it—
CA C
O -M
£- O
u o.
g
°s
^ V
II

-
•Jox
111
rt O 01
£ ui a:


g g _>•
!C *' " °
3 S CO Q
^ > £j CO
0 2'-- ""
^ a. 3-

eo **
"*" in
TJ 2
Z E




10
g
o
2
3
a)
C/j
«- in

-* ro


in in



in in




sr in





ro ro




fO N»





ro in






•* in


v
Q. CO
— • CO (U
o •*-
CMHS
Provide a life cycling and contr
mechanism for chemical materials
Central Purchasing
Educate procurement personnel to
material substitution opportunit












































g
•M
£
c.
CO
Q
2


^


in



in




^j.





ro


i

-*





•j-






in


»
,O
4J
CO
. Determine usage. patterns of oper
that commonly use and dispose of
certain chemicals

ro
^


in



in




^.





to




*





si-






in


01
4-*
.E
Order specialty chemicals throug
site-wide stockroom '


^


in



in




,-





ro




in





ro






in





Identify other potential users
Checkout System
in
ro
in


in



in




.j.





^f




s*





^(.






^f


L.
O) •*-
C  5
en
Require employees retiring or le
the lab to report the status of
chemicals and samples present in
labs
o
ro
in


in



•*




._





ro




**





to






in


M-
t- > M-
o> a o
o _c
Chemical Exchange
Require supplying researcher to i
contents of an opened container 1
not been altered by the addition
contaminants or improper storage
•o
ro
-


in



in




in





10




-*





in






in


CO
CO
u
Explore ways to use expired chem
for other applications
Chargeback System

ro



in



in




in





*^




•*





in






in




•8
Use Chargeback money for site-wii
pollution prevention options






4-f
t)

H-
0)
0)
1
o
>
CO
**—
CO
ID
CU
I
'E
•*-•
CO
«•" •
1
8
H-
"S
_0)
JQ
2
§
to
H-
^
(A

D)
c
'x
•t-
c
._
CO
in
JC
4-*
'3
•rj
4->
* Pollution prevention options ra

-------
RESEARCH DEVELOPMENT AND DEMONSTRATION

      Given  the research  orientation of  the GL,  RD &  D opportunities  for
pollution prevention should be readily embraced.   Submission of type 1 research
project proposals that  investigate  pollution  prevention  techniques within the
researcher's area of interest would  be an excellent vehicle for addressing RD &
D needs.  DOE could  facilitate  this process  by designating a  pool  of research
money  to  fund   such proposals.    Proposals  for research  on  "traditional"
geochemistry  issues  should  include pollution  prevention  components.   These
proposals could  include research on the minimum  sample  quantities needed for
analyses.  Development and use of microanalytical  techniques also merit further
research. Subsequent  use of remaining unused samples should be investigated, both
from a technical and administrative perspective.

      RD &  D needs  for site-wide opportunities could  be  explored  through the
existing waste management organizations and the MinNet.  The viability of central
distribution and expanded chemical exchange should  be researched.  Potential uses
of  expired  chemicals  will  also require  research  and  demonstration  before
implementation.
                                      26

-------
RECOMMENDATIONS/CONCLUSIONS

      Sandia National Laboratories continues to expand  its pollution prevention
efforts.  Implementation of concepts identified during this WREAFS project would
further enhance SNL's pollution prevention program.  To that  end, EPA recommends
that DOE and SNL investigate the following topics:

      •     Research  Proposals  -  Build  pollution  prevention into  research
            projects  from  the  start.  Researchers should share their ideas in
            this area,  possibly through the MinNet.   An on-site compendium of
            pollution prevention ideas could be generated to assist researchers
            in this area.

      •     Central   Purchasing/Central  Distribution   -   Implementation  and
            refinement of these systems could result in significant reduction in
            waste generation.  When combined with  an expanded chemical exchange
            system, disposal  of expired chemicals could be virtually eliminated.

      •     Escrowed  Closeout   Money  - By  setting  aside  this  money  at  the
            beginning of a project,  potential  reuse,  proper characterization,
            and appropriate; management of chemicals can be maximized.

      •     Checkout  System  -  As with the  escrowed  closeout  money,  potential
            reuse,  proper characterization,   and appropriate management  of
            chemicals can  be built into the procedures for researchers leaving
            SNL employment.                                     ;

      •     Chargeback System - Modifications to the system that promote funding
            of site-wide projects would make the system more effective.

      The recommendation with  the largest  potential  for pollution  prevention
gains is to continue SNL's education and training efforts. Through these efforts
pollution  prevention   can  become  an  integral   part  of   research  design,
implementation, and conclusion.  As researchers modify their perceptions toward
waste generation, new concepts and approaches which extend beyond individual labs
will emerge and be assimilated  into site-wide pollution prevention efforts.
                                      27

-------
                                 REFERENCES

1.  American Chemical Society, Department  of  Government Relations and Science
    Policy,  Less  is Better - Laboratory Chemical  Management for Waste Reduction,
    1985.                                |

2.  Lambert, Steven J.,  "Isotopic and Mineralogical Indicators of Infiltration
    and Vertical  Fluid  Movement  in Unsaturated  Zones of  Semiarid  Terrain",
    Proposal submitted  to  U.S. Department  of Energy,  Office of  Basic Energy
    Sciences,  Geosciences Research, June 22, 1992.
                                        t
3.  Office of the Federal Register,  Code  of Federal  Regulations,  40 CFR 264.1
    (9)(6),  1991.

4.  Office of the Federal Register, Federal Register, vol.56, p.24456, May 30,
    1991.

5.  Sandia National Laboratories, Sandia National Laboratories Waste Minimization
    and Pollution Prevention Awareness Plan.  December 31, 1991.

6.  U.S.  Environmental   Protection Agency,  Guides  to  Pollution Prevention,
    Research and Educational Institutions, EPA/625/7-90/010, 1990.

7.  U.S. Environmental  Protection  Agency,  Guides  to Pollution Prevention, The
    Fabricated Metal  Products Industry, EPA/625/7-90/006, 1990.

8.  U.S. Environmental  Protection Agency,  Facility Pollution Prevention Guide,
    EPA/600/R-92/088, 1992.
                                       28

-------
                                   APPENDIX

    DEFINITIONS OF CRITERIA USED IN RATING OF POLLUTION PREVENTION OPTIONS
                                                                I
   The following criteria  and corresponding definitions were used in rating the
   pollution prevention options  identified  in  this report.   Results  of the
   qualitative  rating process are presented in Tables 2  and 3 within the report.

Media Impact

   This criterion  assesses  the potential  for reduced impact  to one  or  more
   environmental media  if this  option  is  implemented.    Higher ratings  are
   assigned to  options that effect the greatest  reduction  in  impact.   Options
   where impact to environmental  media are not significantly reduced are rated
   low under this criterion.
                           I                       '              !
Pollution Prevention Hierarchy Factor

   This factor  rates the  option  based upon  the type of pollution  prevention
   accomplished.   Source  reduction  is the highest  priority in: the  pollution
   prevention hierarchy and  is  consequently rated  high.   Recycling  options
   receive  a lower  rating.  Disposal is positioned at  the bottom of the hierarchy
   and,  therefore,  receives the lowest rating.

Potential Economic Recovery

   This criterion examines potential  economic  savings from implementation of the
   option.   Savings may be immediate,  when no  money is required to implement the
   option.   These options  are  rated  high.  Options with a "payback"  period may
   be  rated  high,  if  the  period  is  short,  or low  if  longer time frames  are
   required.

Ease of Implementation     ;

   If  the  option  is   readily  available,  or  requires  little  refinement  or
   modification prior to implementation,  it is assigned a high rating.   Options
   that require substantial planning and coordination prior to implementation are
   rated lower.
                                      29

-------
Crossfeed Potential

   This criterion rates an option for its ability to be used elsewhere within SNL
   and other  DOE  facilities.   Options with  the  greatest  potential   for  use
   elsewhere are rated high.

Mission Impact                         |
                                       i
   Any option that  disrupts or negative]y  impacts the mission of the GL or the
   entire SNL facility would  be rated low.  Options that do not impact, or even
   enhance,  the mission of these entities  are  rated high.

Material Control

   Options that increase  the  accountability  and management of  chemicals  and
   samples are rated high.  Also highly rated are options  that provide better
   management of wastes.


Increased Staff Required

   Options that do  not require increases in staff to  implement are rated higher
   than those initiatives where additional  staff must be obtained.  If additional
   research must be performed prior to implementation of an option, the rating
   also is lower.                       i
                                      30

-------