Title:
EMS as a Compliance Vehicle – An Example: NPDES
Compliance
Facility:
Los Alamos National Laboratory, Los Alamos (LANL), NM 87545
Point of contact:
Dennis L. Hjeresen, LANL Phone: 505 665-7251 E-mail:
dlh@lanl.gov
Brief description of the Best Practice
LANL actively seeks to integrate all aspects of
environmental compliance through its ISO
14001:2004-registered Environmental Management System (EMS).
This Best Practice specifically describes how EMS
mechanisms were used to implement new requirements of LANL’s
National Pollutant Discharge Elimination System
(NPDES) permit.
LANL currently has 15 EPA NPDES permitted outfalls
that historically have discharged approximately 154 million
gallons per year of treated effluent from key sanitary
waste, computing, high-energy physics and research and
development facilities.
While these discharges are permitted under the Clean
Water Act (NPDES), a new permit issued in August 2008
carries rigorous new enforceable limits on metals and whole
effluent toxicity beginning in August 2010 and PCB’s in
August 2012 with an extremely low discharge limit (0.00064
ug/l).
Hydraulic pressure from these discharges contributes to the
migration of legacy contaminants downstream.
Finally, DOE Order 430.2b
Departmental Energy,
Renewable Energy and Transportation Management and the
LANL EMS call for water conservation.
An institutional response to these requirements was
implemented through the LANL EMS.
A
cross-laboratory team developed a business and engineering
plan to address all discharges and prioritize requirements.
The plan coupled sustainability requirements that
stress water conservation and provided a strong business
case for the required investment.
The plan was vetted during extensive discussions with
facility owners and walk-downs of facilities were conducted
to develop appropriate engineering options.
The engineering plan developed five parallel
projects that are implementing both interim and long-term
solutions that will reroute and recycle 85% of the effluent,
reduce water consumption enough to meet 16% of all NNSA’s
water savings goals and, ultimately close 12 of the 15
outfalls. The
remaining outfalls will not discharge routinely but will
maintain emergency discharge status if needed.
Why the best practice was used:
The LANL EMS serves an integrating function between
pollution prevention, environmental sustainability goals,
institutional business goals, compliance requirements and
mission performance.
Without an institutional approach, each facility
owner would had to have treated the wastewater locally and
been subject to new requirements as early as 2013.
By taking a system-wide view of the LANL water and
waste water system, the institution arrived at a permanent
solution that saved money while achieving DOE sustainability
goals.
What are the benefits of the best practice
LANL was faced with serious NPDES compliance
deadlines of August 2010 (pH/toxicity/metals) and August
2012 (PCB’s) and fines of $25k per day per violation and
Water Quality Standards fines of $10k per day.
Based on sampling results, if the new permit limits
were in effect, LANL would have had approximately 80
exceedances of the new permit conditions in FY09.
Key mission facilities would be out of compliance and
subject to an increased EPA focus on enforcement possibly
resulting in shutdown.
In addition to financial exposure under 33 USC1319(d), it was determined
that compliance fines will be unallowable costs under the
contract.
Further, regulatory fines and penalties compound existing
citizen’s lawsuits on ground and surface water contamination
and permit negotiations/appeals.
It is likely that non-compliance would instigate a
new compliance order from EPA with associated legal costs.
Finally, engineering analysis of alternative point
source treatment at each outfall demonstrated that a
separate approach would be more expensive than an integrated
strategy.
What problems/issues were associated with the Best
Practice
A key problem was raising institutional awareness of
the overall problem.
This is where the LANL EMS was particularly useful.
Since the LANL EMS is organized at the Division and
Directorate level, it allowed each organization with an
NPDES outfall to identify directly with the potential
impacts on their mission operations.
Several parallel steps were taken to bring management
focus on the problem.
First, based on the business case, achieving Zero
Liquid Discharge by 2012 was approved by senior management
as one of 5 Lab-wide Environmental Objectives in the EMS.
This allowed each of the involved organizations to
meet a lab-wide objective by participating in the process.
Next, the project became one of the Laboratory
Director’s Improvement Goals.
Importantly, the DOE/NNSA Site Office included the
project as a performance measures for contract award fee.
Finally, the project was integrated into the LANL
Site-wide Environmental Impact Statement (SWEIS) Mitigation
Action Plan.
Collectively, these steps raised awareness and kept
management attention on the completion of the project.
How the success of the Best Practice was measured
DOE Orders 430.2b and 450.1
Environmental Protection Program require energy and
water conservation.
Historically, LANL has discharged ~154 M GPY via 15
outfalls.
Engineering calculations show that SERF saves ~110 M GPY
(~4400 households).
To track project progress two methods are used.
First, project execution milestones are Performance
Based Incentives in the LANL contract with DOE.
Results are reported monthly to DOE.
Second, project milestones are included as a key
element of LANL’s Executable Plan for energy and water
conservation required under DOE Order 430.2b.
Operational energy savings from these operations will
also be factored into the Executable Plan.
Results are reported to the Site Office and DOE HQ
quarterly.
Description of process experience using the Best
Practice:
After making a business case for an integrated
approach through the EMS, project implementation began with
the objective to reduce or eliminate discharges to achieve
compliance. The
effort was organized into five projects based on geographic
proximity. The
strategy was to centralize treatment by routing to existing
and expandable facilities:
-
The Sanitary Effluent Reclamation Facility (SERF) for
industrial waste water
-
The Sanitary Wastewater Sewer Facility (SWWS) for
sanitary waste water
-
The Radioactive Liquid Waste Treatment Facility (RLWTF)
for radioactive liquid wastes
The overall project hinged on SERF expansion to
triple capacity.
Several facilities will close their outfalls by routing
their discharge water to one of the three treatment
facilities. In
turn, the SWWS will route its final effluent to SERF for
recycle and reuse.
SERF treatment is the only viable approach to PCB
compliance given large volumes.
Compliance sampling has confirmed that the SERF
process is effective in removing PCB’s to levels below the
extremely low limit (0.00064 ug/l) of the permit.
The SERF expansion is a major line item with costs
in excess of $13 M, which was approved in August 2009. All
five projects have been approved, equipment for storage and
treatment (where necessary) has been procured and, as of May
2010, all projects are proceeding to construction in order
to meet the initial August 2010 deadline.
