THE OFFICES OF ENERGY RESEARCH AND DEFENSE PROGRAMS APPROACH TO WASTE MANAGEMENT RE-ENGINEERING

Arnold M. Edelman and John A. Marchetti
Offices of Energy Research and Defense Programs
U.S. Department of Energy
Washington, D.C. 20585

ABSTRACT

The Office of Environmental Management (EM), through it's Re-Engineering of Waste Management will change the way waste is managed within the Department of Energy. The Offices of Energy Research (ER) and Defense Programs (DP) are working together to assure a "smooth" transition of waste management responsibility and accountability back to their respective organizations. With early planning combined with open communication among headquarters, field, and site offices, a smooth transition will evolve and provide the foundation for a more cost effective, efficient, and less bureaucratic waste management program for the Department.

Both ER and DP have established Waste Management Transition Working Groups to help define how a true "environmental efficient" goal, that will incorporate pollution prevention, waste minimization and waste management will be achieved.

This paper discusses the current approaches being undertaken by ER and DP and describes the issues, barriers, and potential options for resolution.

BACKGROUND

Effective October 1, 1997, the responsibility for the funding and management of the Waste Management Program at Fermi and the Stanford Linear Accelerator Center (SLAG) will reside with ER; and the Kansas City Plant and the DP portion of Savannah River will reside with DP. This is the first step in the anticipated transfer of all waste management activities for newly generated wastes at our sites. During FY 98, an assessment of these programs will be conducted to determine if additional facilities will be transferred in FY 99 and beyond. The future transfers are dependent on demonstrating that both ER and DP can manage and conduct waste management in an cost-effective manner and reduce or eliminate wastes that we generate through incorporating pollution prevention principles in our activities.

ER AND DP'S APPROACH TO RE-ENGINEERING

In October 1996, both ER and DP began the planning process for the return of waste management by establishing Waste Management Transition Working Groups. These working groups were established to prepare both ER and DP for the transition and eventual full implementation of a waste management program. Though these Working Groups were separately chartered by each office to focus on ER and DP specific issues, their activities are

being integrated through sharing of documents, participating in meetings, and developing consistent approaches to waste management by ER and DP. As a first step, the groups identified internal programmatic issues, developed management options, and obtained resolution of the identified issues. In addition, the Working Groups have been assigned the task to develop for each program (ER and DP) a Transition/Implementation Plan (Strategic Plan). The Plan will address what needs to be done to develop a Corporate, integrated approach to waste management.

Specifically the work groups are to:

1. Develop a Transition/Implementation Plan (Plan) for each program (ER and DP) including a proposed policy for waste management and waste reduction/pollution prevention;
2. Coordinate the development of the Plans with Headquarters Programs, the Office of Environmental Management, Operations/Site/Area Offices and affected laboratories;
3. Develop options for single-purpose and multi-program facilities at the landlord and research program level;
4. Identify Headquarters and field programmatic and financial issues that will impact the transition/mplementation of the Waste Management program; and,
5. Integrate the results of the EM Work Groups and Pilot Programs into the development of the final plans.

GUIDING PRINCIPLES FOR WASTE MANAGEMENT

There are several principles that will drive the development and management of waste activities being managed by ER and DP. EM will continue to fund and manage legacy waste. Both ER. and DP will take the approach that waste management should be managed consistent with the approach used for the management of Environment, Safety and Health (ES&H). For ER this means few if any resources provided to the Operations Office. Annual planning, budget and reporting efforts for waste management will be incorporated into program planning, budgeting and reporting framework and cycle. There will be full transfer of programmatic responsibility for all activities associated with newly-generated waste to include the management and funding for on-site treatment, storage and disposal (TSD) facilities for newly-generated waste, and the base Waste Management program at our sites.

In addition, the following principles will apply:

• Waste management will become an integral part of the laboratory research or production facility program.
• Activities, from the design and planning stages throughout operations and shut-down, are to be conducted in a manner aimed at eliminating pollution and managing wastes cost effectively.
• Program managers will be held responsible for the wastes their programs generate and each laboratory will be held responsible and accountable for the overall management of their waste management programs.
• Resources for waste management, research, and mission programs will be kept separate and over time integrated into the programs budgets.
• DOE will eliminate or reduce to the maximum practicable extent, pollution that results from its operations and its release into the environment. Waste will be minimized, when feasible, through the selection of non-polluting technologies and use of alternative less hazardous materials.
• Waste that has been generated will be managed in compliance with applicable, Federal, State and local requirements in a cost effective manner to minimize current year spending, future liability, and environmental impact.
• On a site level, the Work Smart Process will be applied to identify the appropriate requirements governing waste management activities.
• Headquarters Programs, through working with appropriate Laboratory and Field elements, will estimate, budget for, and fund waste management activities at their sites. Shortfalls in funding will be covered at the facility by the program responsible for causing the shortfall.
• Full cost recovery for waste management, if practical and appropriate, is the goal. Generators, regardless of size will be responsible for paying for their costs related to waste management.
• At Landlord multi-program sites, the Landlord will recover the full cost of capacities and services provided, as practicable.
• Sites will track and recover waste management costs at the lowest level they determine is cost-effective. (This may imply de minimis quantities/types of waste for which the generator will not be charged.)
• Organizations will continually focus on reducing the volume of wastes they generate by encouraging the active participation of employees to reduce, reuse, and recycle, as appropriate.
• To the extent practical, sites should maximize the utilization of commercial recycle and TSD capacities.
• Headquarters ER and DP will develop expected levels of performance.
• Resource savings resulting from waste reduction/pollution prevention can be used to fund additional research, mission activities, or waste reduction/pollution prevention activities.

MANAGEMENT AND FINANCIAL ISSUES

As part of the work group process, several issues related to ER and DP management will need to be resolved, including both management and financial.

Management issues include: roles and responsibilities of Headquarters, Operation, Area and Site Offices, and Laboratories and Plants; management, oversight/review, compliance, guidance, etc.; identification of the necessary and sufficient waste management and pollution prevention programmatic functions; organizational structures to address programmatic functions (centralized/decentralized approach); FTE and resources requirements; scope of Program; transition from EM management to ER/DP management of all waste activities including facility management; integrating waste management and pollution prevention into the research and mission programs; measuring success through the development of contract performance measures and other metrics; need for contract modifications to address waste management; and Compliance Agreements/Coordination (e.g., Federal Facility Compliance Act agreements coordination, National Polychlorinated Byphenols Agreement, etc.).

Financial issues include: transfer of EM funding to ER and DP; options for budget allocations and tracking; budget process for identification and approval of waste management resource needs (validation, ranking, etc.) and decision making process to evaluate/approve these needs; allocation and shifting of funds across facilities/activities (a single pot of money vs. program pots of money); use of funds from other Cognizant Secretarial Officers and funds to other Cognizant Secretarial Officers; Generator Set-aside programs for pollution prevention; creating financial incentives for waste reduction; and dealing with shortfalls and future EM liabilities.

POTENTIAL ROLES/RESPONSIBILITIES

As part of the re-engineering process, ER and DP are reevaluating the roles and responsibilities for Headquarters, Operations Offices and Site/Area/Group Offices. Traditionally, ER has not provided resources to Operations Offices delegating only the oversight function to the Operations Office. Resources have been provided by Field management under this approach. ER does provide a limited amount of resources to the Site/Area/Group Offices for program management of ES&H and other activities. DP on the other hand provides resources directly to the Field who will manage their Waste Management program using their current approach to program management. ER will need to work with DP to resolve any conflicts or issues that arise as a result of differing management approaches. Irrespective of this key difference, current thinking on roles and responsibilities for Headquarters, Operations/Site Offices and Contractor organization, are outlined below.

Headquarters: provides strategic planning for waste management activities; develops policy, and provides guidance and assistance to Field elements; functions as an informed advocate and a demanding customer through ongoing and continuous interaction and communication with Field elements; provides analysis to shape policy and strategy and assists in the development of options; establishes performance expectations and measures Field performance; and recommends allocation of resources to management. Where resources are involved or needed, Headquarters will act as the advocate once agreement and understanding is reached with appropriate Field elements; and establish measurable site-specific performance expectations that reflect site conditions, the Work Smart Process (necessary and sufficient), DP/ER policy and guidance, and other factors.

Field Organizations (DP--Operations Offices; and DP/ER-- Area/Site Offices): provide day-to-day oversight of waste management operations at facilities; manage the performance of site contractors to achieve performance expectations; measure the performance of site and other contractors; make decisions affecting their site based on DP/ER policy and guidance; seek resolution, in coordination with Headquarters, of policy issues that arise in the field; consistent with the approach used for managing ES&H, interact with local, state and regional stakeholders, and with regulatory agencies in the Field; provide information to Headquarters on ongoing activities, and ensure Headquarters is informed of the progress and status of waste management technical and institutional activities; and establish measurable site-specific performance expectations that reflect site conditions, the Work Smart Process (necessary and sufficient), DP/ER policy and guidance, and other factors.

Site/Area Offices: take specific direction from the appropriate Operations Office or ER Headquarters Program; and responsible for providing direct contract administration, program management, and line management oversight of site contractors.

Contractors: manage waste, the generation of waste, and the operation of TSD facilities in accordance with policy and guidance, applicable laws and regulations, and contractual obligations; and establish measurable site-specific performance expectations that reflect site conditions, the Work Smart Process (necessary and sufficient), DP/ER policy and guidance, and other factors.

NEXT STEPS

Preparing ER and DP Facilities for Transfer of Waste Management Program Management

A critical element for the successful transfer of the Waste Management program from EM to ER and DP is laying the foundation for the management transfer of newly-generated waste between FY 98 and FY 00. The following facilities will be subject to this transfer: Argonne National Laboratory-East; Brookhaven National Laboratory; Princeton Plasma Physics Laboratory; Ames Laboratory; Oak Ridge National Laboratory; Oak Ridge Institute for Science and Education; Lawrence Berkeley National Laboratory; Pacific Northwest National Laboratory, Lawrence Livermore National Laboratory, Pantex, Los Alamos National Laboratory, and Sandia National Laboratories (CA, NM). Below is a description of key activities that must take place prior to the transfer of management responsibility to ER and DP.

1. Waste management requirements should be subject to the Work Smart Process;
2. Management functions and relationships among the Operations Office and Site/Area/Group Offices needs to be assessed and re-engineered, if required;
3. Facilities should develop a management approach that holds generators accountable and financially responsible for the wastes they generate. This may include the development of a charge-back or similar type of approach that requires the generators to pay the costs associated with management, treatment, storage and disposal of the waste they generate. Other alternatives should be considered based on the type of facility (multi-program, single purpose);
4. An identification of all outstanding financial liabilities related to the management of newly generated wastes to include: funding shortfalls from the previous FY; financial obligations to other Federal (e.g., EPA), state (Bi or Tri Party Agreements) or local governments; and an estimation of costs for upgrade or construction of waste management facilities intended for management of wastes generated on-site; and
5. A through review and understanding of Compliance Agreements and/or Agreements-in-Principle made by EM that will be binding on ER and DP.