ML062920265

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Email: (PA) FW Waste Minimization Plan
ML062920265
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 10/03/2006
From: Dewald L
Entergy Nuclear Vermont Yankee
To: Emch R, Miller D
Argonne National Lab (ANL), NRC/NRR/ADRO/DLR
References
%dam200612, TAC MD2297 EN-EV-104, Rev 0
Download: ML062920265 (33)


Text

[ Ri6h6d Er-ch - FW: Waste Minimi za ion Plan Page 1 ]

I Richard Emch - FW: Waste Minimiz ion Plan Page 1 From:

"DeWald, Lynn" <ldewald@entergy.com>

To:

<rle@nrc.gov>, <david.s.miller@anl.gov>

Date:

10/03/2006 11:21:00 AM

Subject:

FW: Waste Minimization Plan Here are the waste minimization plan and procedure. I need to make one contact for the cooling tower study report and then that will follow.

Lynn From: BUCKLEY, RICKY N Sent: Tuesday, October 03, 2006 11:16 AM To: DeWald, Lynn

Subject:

Waste Minimization Plan

Lynn, Please forward to Rich.

Rick Buckley, CHMM, REM Sr. Project Manager Entergy Nuclear 601-368-5372 (Office) 601-927-5132 (Cellular) 601-368-5799 (Fax) rbuckle@entergy.com This e-mail and any attachments thereto are intended only for the use by the addressee(s) named herein and contain proprietary and confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution, or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify me by telephone and permanently delete the original and any copy of any e-mail and any printout thereof.

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Subject:

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Created By:

FW: Waste Minimization Plan 10/03/2006 11:20:12 AM "DeWald, Lynn" <ldewald@entergy.com>

Idewald@entergy.com Recipients nrc.gov OWGWPO02.HQGWDO01 RLE (Richard Emch) anl.gov david.s.miller Post Office OWGWPO02.HQGWDO01 Route nrc.gov anl.gov Files Size MESSAGE 1031 TEXT.htm 6173 EN-EV-104 (Waste Minimization).pdf ENWMP_REV. 0.pdf 55585 Mime.822 431375 Date & Time 10/03/2006 11:20:12 AM 251910 Options Expiration Date:

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Title:

Waste Minlmlzation Procedure Owner:

Rick N. Buckley I Corporate Environmental Chairman (Print Name / Title)

Approved:

F wK o

agg2p 12/09104 (Procedure Owner Signature) i (Date)

EN Common 12114104 ANO PNPS ENN Effeive ECH RBS Effective ENS Date GGNS VY Date Exception IPEC W3 JAF WPO Basis Statement The procedure provides waste minimization expectations for management of wastes generated at the Entergy Nuclear sites.

Procedures Affected By This Revision NMM Procedures EV-104 (Waste Minimization) and ENN-EV-014 (Waste Minimization) superseded by this procedure.

Process Applicability Exclusion (ENN-LI-1 00) I Proarammatic Exclusion (ENS-LI-lOl)

AlI Sites: 0 Specific Sites: ANO [] GGNS 0] IPEC0 JAF 10 PNPSZ RBS 0 W [] W3 0

TABLE OF CONTENTS Section Title Page 1.0 PURPOSE..............................................................................

3

2.0 REFERENCES

3 3.0 DEFINITIONS....................................

3 4.0 RESPONSIBILITIES..............................................................

4 5.0 DETAILS................................................................................

5 6.0 INTERFACES......................................................................

6 7.0 RECORDS......................................

6 8.0 OBUGATION AND REGULATORY COMMITMENT CROSS-REFERENCES.............................

6 9.0 ATTACHMENTS.....................................................................

6 ATTACHMENT 9.1WASTE MINIMIZATION TECHNIQUES (TYPICAL)......... 7

1.0 PURPOSE

[1]

Ensure that the Entergy Nuclear sites follow the intent of the national policy of the United States that, wherever feasible, generation of wastes, including hazardous, mixed hazardous/radioactive, nonhazardous and/or low-level radioactive wastes (LLRW), are to be reduced or eliminated as expeditiously as possible.

[2]

Ensure that wastes nevertheless generated are treated, stored or disposed of so as to minimize present and future threat to human health and environment.

2.0 REFERENCES

[1]

Resource Conservation and Recovery Act (RCRA) of 1976 as amended Section 3001 Section 3002(b) 3.0 DEFINITIONS

[1]

Hazardous Waste - is any material listed as such In Title 40 CFR 261, Subpart D, or that possesses any of the hazard characteristics of ignitability, corrosivity, reactivity or toxicity as defined in Title 40 CFR 261, Subpart C, or that Is contaminated by or mixed with any of the previously mentioned materials, or that is listed as a hazardous waste in applicable state regulations.

[2]

Low-Level Radioactive Waste - radioactive material that is not high-level radioactive waste, spent nuclear fuel, or byproduct material as defined in section 1 le.(2) of the Atomic Energy Act of 1954.

[3]

Mixed Waste - waste that satisfies the definition of low-level radioactive waste, and contains a hazardous waste that either:

Is listed as a hazardous waste in 40CFR261, Subpart D, or Causes low-level radioactive waste to exhibit any of the characteristics identified in 40CFR261, Subpart C.

[4]

Nonhazardous Wastes - any material which is excluded as a hazardous waste or has been proven to be nonhazardous either through analytical testing or process knowledge.

[5]

Radwaste Management Pro-gram - program developed for the safe, efficient and cost effective management of radioactive waste from the point of generation to its final disposition.

[6]

Recvclina - is use, reuse or reclamation of a waste, either on-site or off-site, after It has been generated.

[7]

Source Reduction - is reduction or elimination of waste at source, usually within a process. Source reduction measures include process modifications, feedstock substitutions, Improvements in feedstock purity, housekeeping and management practices, Increases in efficiency of machinery, and recycling within a process.

Source reduction implies any action that reduces toxicity or amount of waste exiting a process.

[8]

Waste Generation - is act or process of producing hazardous, mixed hazardous/

radioactive, nonhazardous and/or low-level radioactive waste (LLRW).

[9j Waste Management - Is systematic control of the collection, storage, transportation, processing, treatment, recovery and disposal of hazardous, mixed hazardous/radioactive, nonhazardous, and/or tow-level radioactive waste.

[10]

Waste Minimization - is reduction, to extent feasible, of hazardous, mixed hazardous/radioactive, nonhazardous, and low-level radioactive waste that Is generated or subsequently treated, stored, or disposed of. It includes any source reduction or recycling activity undertaken by a generator that results in: (1) reduction of total volume or quantity of waste; (2) reduction of toxicity of waste; or (3) both, as long as reduction is consistent with goal of minimizing present and future threats to human health and environment.

4.0 RESPONSIBILITIES

[1]

EN Vice Presidents are responsible for ensuring that necessary documents are established and implemented to comply with the Intent of this procedure.

[2]

EN Environmental Focus Group is responsible for (a)

The maintenance and Interpretation of this procedure and must approve any deviations from provisions of this procedure.

(b)

Sharing waste minimization and industry "best practices" which may be used companywide to foster resource sharing.

(c)

Evaluation of new waste processing, recycling and minimization technologies and implementation of nonhazardous products.

(31 EN Personnel are responsible for incorporating waste minimization practices, to the extent practicable, Into those site activities that generate wastes.

5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS None 5.2 WASTE MINIMIZATION PRACTICES

[1]

Departments who generate and manage waste at the EN sites are to utilize waste minimization practices such as those recommended In Attachment 9.1 to ensure that:

(a)

Hazardous, mixed hazardous/radioactive, nonhazardous and/or low-level radioactive waste generation are minimized to the extent practicable.

(b)

The hierarchy for waste minimization and/or management is conducted as follows:

Source reduction - reduction or elimination of waste within a process Recycling - reuse or reclamation of waste Treatment - such as neutralization of acids or bases Disposal - last resort activity.

(c)

The selection of waste management technologies considers cost, time, and overall public health and safety.

(d)

Cost-effectiveness and environmental worthiness are evaluated with regard to long-term potential liabilities, as well as immediate cost considerations for wastes that cannot be eliminated or reduced through waste minimization techniques.

(e)

Waste minimization becomes an Integral part of each employee's responsibilities and the section or job which produces the waste accepts responsibility for incurring management costs, to the maximum extent practicable..

(f)

Adherence to regulations applicable to hazardous, mixed hazardous/

radioactive, nonhazardous and/or low level radioactive waste generation and disposal are regarded as a minimum acceptable level of performance.

5.3 WASTE MINIMIZATION IMPLEMENTATION

[1]

To ensure that the intent of this procedure is Implemented, the EN sites are to establish management practices that incorporates those elements discussed in Section 5.2 above and to Include the additional elements, as a minimum:

Development of a waste minimization plan which includes those elements required by the Environmental Protection Agency.

Methods to Inform employees who Influence waste generation of the need for minimizing waste through training and recognition.

Methods to track waste generation and associated costs, to the maximum extent practicable.

Methods of evaluating effectiveness of waste minimization efforts through periodic assessments (i.e., tracking of waste generation and preparation of reports).

Methods to allocate associated waste costs to responsible department, where practicable.

Clear assignment of employee and management responsibilities for activities associated with segregation, collection, preparation, processing, packaging, transportation and disposal of waste.

Establishment of goals by which to measure performance.

6.0 INTERFACES None 7.0 RECORDS None 8.0 OBLIGATION AND REGULATORY COMMITMENT CROSS-REFERENCES Document Document Section NMM Procedure Section Site ApDlicability None mNone I

I-

-"I 9.0 ATTACHMENTS 9.1 WASTE MINIMIZATION TECHNIQUES (TYPICAL)

ATTAHMET 1

9O.1 r

WASTE MINIMIZATION TECHNIQUES (TYPICAL)

ATAHMENT91WAT INMZTONTCNIUS(TPCL WASTE MINIMIZATION TECHNIQUES I

I P.CYIN PRODUCT'CHANGES

- PRO(*= SUfTrUfTN

-PROoUCONSERVATION cHANGE IN PROUCT C*

11~rON SOURCECOM I

I I

USE AND REFUSE

- RETURN TO ORIGINAL PROCESS

- RAW MAITERAL SUBSTITUTE FOR ANOTHER PROCESS 1 I

RECLAMATION

- PROCESSED FOR RESOURCE RECOVERY

-PROCESSED AS A BY-PRODUCT 6

I I NPUT MATERL. CHANGE

-MATERIAL PURIFICATION

-MATERIAL SUBSTITUTION I

- PROCIESS CHA-MAGS

- EUIIMENT. PIPING, OR LAYOUT

- ADOTIONAL AUFTIwAON

-CHANGES IN OPERATIONAL SETTINGS

-I GOOD OPERATING PRACTICES

-PROCEDURALW)SURES

- LOSS PREVENTION

- NV24AGEMENT PRACTICES

-WASTE STREAM SEGREGATION

-MATERIAL HANDUNG IMR ENTS

- PRODUCTION SCHEDUUNG

- BEPLOYEE TRAINING ANP AWARENESS

ENTERGY NUCLEAR WASTE MINIMIZATION PLAN Approved By:

vir a

BucuGrp Environmental Focus Group 7-14-2006

/

Date ENWMP-(Rev. 0) - 1

ENWMP-(Rev. 0) -2

Table of Contents Section Description Page 1.0 Introduction 3

2.0 Policy 4

3.0 Facility Information 5

3.1 Facility Owners 5

3.2 Facility Operators 5

3.3 Facility EPA Identification Numbers 5

3.4 Responsible Facility Representative 6

4.0 Scope and Objectives 7

4.1 Scope 7

4.2 Objectives 7

5.0 Alternative Waste Reductions 8

5.1 Source Reduction 8

5.2 Solvent Recovery 8

5.3 Recycling 8

5.4 Hazardous Materials Substitution 9

5.5 Product Reuse/Alternative Use 9

5.6 Waste Segregation 10 5.7 Elimination of Waste Streams 10 5.8 Chemical Review Forms 11 5.9 Site Inspections 11 6.0 Equipment Waste Reduction Devices 12 7.0 Waste Minimization Training Program 13 8.0 Establishment of Performance Goals 14 9.0 Prior Waste Minimization Efforts 15 10.0 Waste Stream Analysis/Minimization Opportunities 16 11.0 Waste Minimization Reports 21 ENWMP-(Rev. 0) - 3

1.0 Introduction Entergy Nuclear's (EN) Waste Minimization Plan provides information and descriptions of activities to reduce, to the extent feasible, hazardous, hazardous/radioactive and nonhazardous wastes generated, treated, accumulated or disposed. This includes any source reduction that eliminates or reduces the generation of a waste at the source or recycling activity that uses, reuses or reclaims a material.

This Plan is to be used in conjunction with Entergy Nuclear's fleet Procedures EN-EV-104, "Waste Minimization", EN-EV-106, 'Waste Management Program" and EN-EV-112, "Chemical Control Program", and site-specific procedures to minimize waste generation to the maximum extent practicable.

The Environmental Focus Group is responsible for:

  • Implementing site waste minimization programs relating to hazardous, hazardous/

radioactive and nonhazardous wastes.

  • Maintaining this Plan.
  • Assessing and evaluating waste streams for minimization opportunities.

ENWMP-(Rv. 0) - 4

2.0 Policy EN encourages innovative economical techniques and practices that effectively reduce the volume or quantity of wastes so long as these reductions minimize present and future threats to human health and the environment. EN will reuse or recycle waste materials, when economically practical, and ensure that unusable waste is disposed of in accordance with applicable state and federal regulations.

EN's environmental guidelines include the following:

" Environmental protection is every employee's responsibility. Environmental Protection is valued and displays our commitment and obligation as Entergy employees to serve as socially responsible corporate citizens in protecting the environment.

" Reducing and if

possible, eliminating the generation of hazardous, hazardous/radioactive and nonhazardous wastes and emissions at the source is a prime consideration in design and plant operations.

" Methods and new technologies which substitute nonhazardous materials or utilize other source reduction techniques will be given priority in assessing or modifying current or potential waste streams.

" Economical reuse and recycling of materials will continue to be the first consideration prior to classification and disposal as waste.

" EN will demonstrate its commitment to responsible corporate citizenship by complying with applicable state and federal regulations, promoting cooperation and coordination between departments, facilities, industry, government, and customers, and sharing the goal of minimal adverse impact to air, water and land through excellence in environmental control.

ENWMP-(Rev. 0) - 5

3.0 Facility Information 3.1 Facility Owners

" ANO:

Entergy Arkansas Little Rock, Arkansas

" GGNS:

System Energy Resources, Inc.

Jackson, Mississippi Southwest Mississippi Electric Power Association Hattiesburg, Mississippi

" IP2:

Entergy Nuclear Indian Point 2, LLC Buchanan, New York

" IP3:

Entergy Nuclear Indian Point 3, LLC Buchanan, New York

" JAF:

Entergy Nuclear FitzPatrick, LLC Lycoming, New York

" PNPS:

Entergy Nuclear Pilgrim Station, LLC Plymouth, Massachusetts

" RBS:

Entergy Gulf States Beaumont, Texas

" VY:

Entergy Nuclear Vermont Yankee, LLC Brattleboro, Vermont

" W3:

Entergy Louisiana, LLC New Orleans, Louisiana 3.2 Facility Operator

" Entergy Operations, Inc. (ANO, GGNS, RBS & W3)

" Entergy Nuclear Operations, Inc. (IP2, IP3, JAF, PNPS & VY) 3.3 Facility EPA Identification Numbers

  • ANO - ARD000632752
  • GGNS - MSD000644617 ENWMP-(Rev. 0) - 6

" IP2 - NYD991304411

" IP3 - NYD085503746

" JAF-NYD000765073

" PNPS -MAR000014167

" RBS - LAD070664818 VY - VTR000504167

" W3 - LAD000757450 3.4 Responsible Facility Representative

  • Site Vice Presidents, Operations ENWMP-(Rev. 0) - 7

4.0 Scope and Objectives 4.1 Scope EN's waste minimization efforts are primarily directed toward hazardous and hazardous/radioactive waste streams but nonhazardous waste streams are also minimized where feasible. Priorities of these efforts are as follows:

" First - Hazardous/Radioactive Waste Minimization.

" Second - Hazardous Waste Minimization.

" Third - Solid Waste Minimization.

" Fourth - Other Media Waste Minimization (see 40CFR261.4).

The hierarchy of waste minimization options is:

" First - Source Reduction.

" Second - Reuse/Sound Environmental Recycling.

" Third - Treatment to Reduce Volume and/or Toxicity.

" Fourth - Disposal.

Waste minimization activities, including evaluations and alternative product uses, are typically coordinated through Chemistry personnel Best management practices and techniques utilized at other facilities to foster and improve waste minimization efforts are shared among EN Environmental Focus Group members.

Any employee, after consulting with the site Chemistry group, may implement waste minimization ideas and actions if they prove to be practical and cost-effective.

4.2 Objectives EN's overall objective is to minimize hazardous and hazardous/radioactive waste generation to the maximum extent practicable, with nonhazardous waste generation minimized where feasible. Goals established by the EN Environmental Focus Group are as follows:

" Hazardous/Radioactive Waste: Minimize and eliminate its' generation by controlling chemical usage in radiological controlled areas through the chemical control program and other internal site programs.

" Hazardous Waste: Consistently attain small quantity generator status as defined by the EPA and if feasible conditionally exempt small quantity generator status.

ENWMP-(Rev. 0) - 8

  • Nonhazardous Waste: Minimize generation where feasible.

ENWMP-(Rev. 0) - 9

5.0 Alternative Waste Reductions 5.1 Source Reduction The following are source reduction activities currently occurring within EN:

" RBS: Fax cover sheets have been reduced and replaced by fax.labels.

" EN Sites: Only the amount of chemical to be used for a particular job is allowed.

" EN Sites: Excess paints are utilized in additional areas of the plant when unused paints remain.

" EN Sites: Amount of chemicals maintained in the Warehouse is minimized by optimizing the Min/Max inventories.

5.2 Solvent Recovery The following are recovery/reuse activities currently occurring within EN:

  • RBS & W3: Solvent recovery distillation units are utilized to recover usable solvents from paint wastes. These units reduce paint waste quantities shipped off-site for disposal and the amount of solvent purchased. Estimated recovery of reusable solvents is approximately 65%.

The following are recovery/reuse activities that are no longer occurring within EN:

  • GGNS: Previously utilized a solvent recovery distillation unit. However, the quantities of waste paint solvent currently generated does not economically warrant its' use.

Therefore, the unit has been decommissioned.

5.3 Recycling The following are materials currently being recycled within EN:

  • EN Sites: Cathode ray tubes, circuit boards, fluorescent lights, freon, lead-acid and nickel-cadmium batteries & scrap metals.
  • ENS Sites: Industrial lubricants, greases, automotive crankcase, gear & lube oils, electrohydraulic fluids, laser copier & printer toner cartridges, paper & used oil filters.
  • GGNS: Used tires.
  • JAF: Used oil & SACON blocks.

ENWMP-(Rev. 0) - 10

e PNPS: Plastic soda bottles.

e RBS: Photographic waste & film containing silver, oily debris & ethylene glycol.

5.4 Hazardous Materials Substitution The following are hazardous materials substitution activities currently occurring within EN:

" EN Sites: Water-based epoxy paints have been approved for plant use in an effort to reduce VOC content and hazardous waste generation. In addition, water-based epoxy paints have been approved for radiological use companywide to help reduce the potential for mixed hazardous/radioactive waste generation.

" EN Sites: Fluorescent lamps high in mercury content are being phased out with low-mercury content fluorescent lights that are nonhazardous.

" ANO: Electron has been utilized in place of mineral spirits during turbine outages and throughout the plant. In addition, SD/20 is being used as an alternative degreaser to ZEP aerosol, which contains trichloroethane.

" GGNS: EPA 2000 is utilized routinely instead of mineral spirits in outage work activities and GFC2000 is used by Security in cleaning firearms. In addition, high flash point stoddard solvent used in parts washers in the maintenance and automotive areas has been replaced with citra solv and GFC2000.

" RBS: Varsol was replaced by EPA 2000, a citric-based nonhazardous solvent, for parts cleaning activities. In addition, EPA 2000 is also used for specific work projects during outage activities.

" ANO & W3: Citra solv, which is a nonhazardous citric-based material, is utilized in parts washers and other cleaning applications.

5.5 Product ReuselAlternative Use EN routinely initiates efforts to minimize hazardous/nonhazardous wastes by finding applications for usable products. Interface with product users and help in locating alternative uses have resulted in some use of products that had previously been discarded.

For example, various solvents recovered through the distillation units can be utilized by painters in cleaning and paint preparation activities, and unused materials destined for disposal are surplused when feasible.

When feasible and practicable, Investment Recovery is also utilized to find alternative applications for certain products.

ENWMP-(Rev. 0) - 11

5.6 Waste Segregation The following waste materials are currently being segregated at all EN sites:

" Lead-acid and nickel-cadmium batteries are stored in specific areas and shipped to a smelter for recycling.

" PCB capacitors are stored in designated areas and disposed of at a TSCA approved facility.

" Lead wastes (i.e., tech-sil penetrants, paint) are segregated from other waste materials.

" Metals are collected in designated receptacles and sold for scrap.

" Solvents are segregated, when possible, to prevent mixing with other wastes.

" Used oils are segregated based upon test results and knowledge of oil contents.

5.7 Elimination of Waste Streams The following waste streams have been eliminated within EN:

EN Sites: Site records are processed electronically. This system, which requires no chemicals for processing, replaced the microfilm process, thereby, eliminating the associated hazardous waste stream.

GGNS: Changes to the microfilm process were made that eliminated the need for chromic acid, which had previously been used to soak and clean silver deposits from processor rollers. In addition, high flash point stoddard solvent used in parts washing activities was replaced with GFC2000 and citra solv, which are nonhazardous products.

PNPS: Fluorescent lighting ballasts containing PCBs have been replaced with non-PCB lighting ballasts.

GGNS & VYNPS: Transformers containing PCBs have either been retrofilled or removed from the site to eliminate this waste stream.

W3: Varsol, naphtha and other hazardous waste producing solvent cleaners have been eliminated and replaced with a nonhazardous citra solv product.

GGNS & RBS: Freon parts cleaning solution has been replaced with EPA2000, GFC2000 and citra solv, thereby eliminating the associated hazardous waste stream.

ENWMP-(Rev. 0) - 12

5.8 Chemical Review Forms Chemicals brought and used on-site are controlled through EN's chemical control program (Fleet Procedure EN-EV-112). Chemistry personnel evaluate chemicals for potential hazardous characteristics and make recommendations to the user concerning quantity, use and potential disposal The use of nonhazardous products is strongly encouraged to the extent possible. As part of the chemical control program, Purchasing is also utilized in evaluating the use of nonhazardous products, along with ensuring that only chemicals approved by Chemistry are allowed on-site.

5.9 Site Inspections Site inspections are performed to ensure that products do not have an expired shelf-life, are properly stored and not leaking, and that.empty containers are properly handled.

Products or waste materials found out of place are returned to owners for proper storage.

Any leaks or other problems are immediately repaired. If any deficiencies are identified during these inspections, a condition report is initiated in accordance with NMM Procedure EN-LI-102, "Corrective Action Process" to ensure that the deficiency is corrected.

Products found, that are not being used or those having an expired shelf-life, are evaluated for reuse or recycling, and as a last resort, disposal recommendations are made.

ENWMP-(Rev. 0) - 13

6.0 Equipment Waste Reduction Devices The following equipment is currently being utilized within EN in an effort to reduce waste generation and disposal volume companywide:

" EN Sites: Freon Recovery Systems (recovers freon for reuse) & garbage compactors.

  • W3: Hand Pump Spray Bottles (minimizes product loss).

" RBS & W3: Solvent Recovery Distillation Unit (recovers solvent for reuse).

Previous equipment that had been utilized to reduce waste but has since been discontinued is as follows:

  • GGNS: Snap-On Kleen Coolant Recycle System (recovers/recycles antifreeze).

ENWMP-(Rev. 0) - 14

7.0 Waste Minimization Training Program EN uses procedures, newsletters, awareness handbooks, posted signs and annual training to provide waste minimization guidance and practices to employees.

Training areas include hazardous, hazardous/radioactive and nonhazardous waste, chemical control and environmental awareness.

The actual training related to minimizing hazardous and nonhazardous waste is accomplished through two avenues as follows:

" Annual environmental awareness training

  • Section specific training conducted by Chemistry personnel.

Another avenue of training that occurs on a daily basis is each sites chemical control program (Fleet Procedure EN-EV-1 12). The chemical control program works in conjunction with Chemistry personnel by performing plant inspections and screening materials before their use on-site. This program provides information to plant personnel and includes the proper use, handling and disposal of materials, as well as stressing waste minimization importance. This program also encourages all employees to seek alternative materials that are less hazardous or nonhazardous and to minimize waste whenever possi'ble.

ENWMP-(Rev. 0) - 15

8.0 Establishment of Performance Goals EN's philosophy in regard to performance goals is as follows:

" Eliminate or minimize the generation of mixed hazardous/radioactive wastes through source reduction and EN's chemical control program.

Maintain hazardous waste generation quantities at less than 600 pounds per calendar month at each facility.

" Minimize nonhazardous waste generation to the extent practicable and feasible.

These goals may be more easily attained during non-outage years, when fewer personnel are at the EN sites and fewer maintenance projects occur. Outages are scheduled anywhere from approximately every 18 - 24 months. Therefore, outage activities may make the goal more challenging to achieve.

ENWMP-(Rev. 0) - 16

9.0 Prior Waste Minimization Efforts Sections 5.0 and 6.0 of this Plan lists and describes waste reduction efforts currently in place within EN.

ENWMP-(Rev. 0) - 17

10.0 Waste Stream AnalysislMinimization Opportunities Listed below is a summary of the hazardous, hazardous/radioactive and nonhazardous waste streams generated within EN. If an "X" is noted in a sites column, then the waste stream is either currently being generated or has the potential to be generated. These waste streams are periodically evaluated for minimization opportunities in accordance with Section 11.0 of this Plan.

  • Hazardous Waste Streams:

Waste Stream ANO GGNS IP2 1P3 JAF PNPS RBS VY W3 Aerosols x

x x

x x

Broken Fluorescent Lamps X

X X

X X

X X

X X

Intermittent Miscellaneous Wastes

  • X X

X X

X X

X XX Mercury X

X X

X

_X Off-Specification/Expired Chemicals X

X X

X X

X X

X X

Oil Lab Wastes X

X Kn o

X I

X Oil/Solvent Waste x

x so x

x Paint Wastes (Liquid & Solid)

X X

X X

X X

X X

X Photoerpeic Wa stes x

x mx

  • Intermittent miscellaneous wastes are those waste streams that may not fall into other waste categories..

ENWMP-(Rev. 0) - 18

Hazardous/Radioactive Waste Streams:

Waste Stream ANO GGNS IP2 IP3 JAF PNPS RBS VY W3 Intermittent Miscellaneous Wastes

  • X X

X X

X X

X X

X Oil/Solvent Waste X

X X

X X

X X

X X

Off-Specification Chemicals X

X X

X X

Paint Wastes (Liquid & Solid)

X X

X X

X X

X X

X

  • Intermittent miscellaneous wastes are those waste streams that may not fall into other waste categories.

ENWMP-(Rev. 0) - 19

Nonhazardous Waste Streams:

Waste Stream ANO GGNS IP2 IP3 JAF PNPS RBS VY W3 Activated Carbon X

X X

X X

X X

X X

Asbestos X

X X

X X

X X

X X

Empy onainrs(DumX XX Biomedical Wastes X

X X

CFron Debris X

X X

X X

X X

X X

Desiccant X

X X

X X

X X

X Electrohydraulic Fluid X

X X

X X

X Eetoisx xx x

x x

Empty Containers (Drums)

X X

X X

X x

x Ethylene Glycol X

X X

X X

X X

X X

Freon X

X "

X X

7 X X

X X

Garbage X

X X

X X

X X

X X

Grease x

I x

I x

I x

I x

I x

I x

I I

X ENWMP-(Rev. 0) - 20

e Nonhazardous Waste Streams: (continued)

Waste Stream ANO GGNS IP2 IP3 JAF PNPS RBS VY W3 Insulationx x

x x

Intermittent Miscellaneous Wastes

  • X X

X X

X X

X X

X Off-Specification/Expired Chemicals X

X X

X X

X X

X X

Oil Contaminated Liquids X

X X

X X

X X

X X

Oil Contaminated Solids X

X X

X X

X X

X X

  • Polychlorinated Biphenyl Wastes X

X x

l X

Resins X

X X

X X

X X

X X

Sandblasting Media X

X X

X X

l X

Scrap Metals X

X X

X X

X X

X X

Toner Cartridges X

X x

x X

Used/Waste Oil X

X X

X X

x X X

Used Oil Filters X

X x X X

  • Intermittent miscellaneous wastes are those waste streams that may not fall into other waste categories.

ENWMP-(Rev. 0) - 21

Nonhazardous Waste Streams: (continued)

Waste Stream Used Tires Wastewater/Wastewater Sludges ANO GGNS IP2 1P3 JAF PNPS RBS VY W3 x

x x

x xx Water-Based Paint Wastewater X

X Water Filters X

X ENWMP-(Rev. 0) - 22

11.0 Waste Minimization Reports The quarterly and annual environmental performance indicator report prepared by the Environmental Focus Group is utilized to measure waste minimization success and assess waste streams for further minimization opportunities. These reports are reviewed and discussed in detail by the Focus Group, with necessary strategies developed to address problem areas such as excess generation or costs. In order to ensure that each site is aware of their waste minimization performance as compared to fleet goals, the annual report is sent to all levels of management (site & corporate).

ENWMP-(Rev. 0) - 23