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
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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.
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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
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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.
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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
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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
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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
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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.
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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
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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.
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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.
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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.
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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
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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.
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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