Audit Report 

U.S. Department of Energy 

Office of Inspector General 

Office of Audit Services 

The Department’s Pollution Prevention 

Program 

DOE/IG-0680 March 2005 


REPORT ON THE DEPARTMENT'S POLLUTION PREVENTION 

PROGRAM 

TABLE OF 

CONTENTS 

Pollution Prevention

Details of Finding.............................................................1 

Recommendations ..........................................................5 

Comments.......................................................................6 

Appendices

 1. Objective, Scope, and Methodology ..........................8 

2. Pollution Prevention Proposals ................................10 

3. Prior Reports............................................................11 

4. Management Comments..........................................12 
POLLUTION PREVENTION 

 

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Page 1 Details of Finding 

Pollution Prevention The Department of Energy (Department) has not 

Activities maintained a completely effective pollution prevention 

program. In some cases, sites did not systematically 

research cost-effective opportunities to reduce waste 

generation or to increase recycling/reuse of materials. 

Additionally, sites did not always implement identified 

cost-effective measures to reduce pollution. 

Opportunity Assessments

Although required by Department Order 450.1, 

Environmental Protection Program, two of the four sites 

visited during our review were not conducting operational 

assessments to identify opportunities to reduce waste 

generation or to increase recycling/reuse of materials. 

Current policy requires sites to continually conduct 

operational assessments to identify opportunities for source 

reduction, material segregation, recycle/reuse, and to 

implement those opportunities determined to be feasible 

and cost-effective. We noted, however, that at the Hanford 

Site, the Richland Operations Office (Richland) had not 

ensured that their major contractors reviewed and assessed 

their operations for opportunities to prevent pollution in 

Fiscal Years (FY) 2003 and 2004. We also noted that, 

although required by contract language, the Office of River 

Protection contractors had never performed such 

opportunity assessments. Prior to FY 2002, Richland 

contractors performed yearly assessments of their activities. 

One of the major Richland contractors had, however, 

recently completed a value engineering study to identify 

more efficient mixed low-level waste disposal methods, its 

first review of a waste stream since FY 2001.

Richland and the Office of River Protection's decreased 

emphasis on identifying new opportunities to prevent 

pollution may have contributed to a decrease in cost 

savings from pollution prevention activities at the Hanford 

Site. Specifically, these sites reported average annual cost 

savings/avoidance of over $70 million from these activities 

in FYs 2000 and 2001. However, in FYs 2002 and 2003, 

the sites reported an average of $32 million in cost 

savings/avoidance, or an average decrease of nearly $40 

million per year. Hanford Site officials indicated that the 

reduction of efforts and lack of support, as well as the fact 

that past efforts had already implemented the most 
 

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Page 2 Details of Finding 

promising opportunities, were contributing to the decrease 

in annual cost savings/avoidance. 

Project Implementation

Although the Los Alamos National Laboratory (Los 

Alamos) and the Sandia National Laboratories (Sandia) had 

successfully implemented certain pollution prevention 

proposals, they had not acted on a number of proposals that 

they determined to be feasible and cost-effective on a 

life-cycle basis. Based on a review of 20 judgmentally 

selected proposals, we found the sites had not implemented 

9 proposals that represented potential life-cycle cost 

savings of over $5.5 million. Additional information is 

presented in Appendix 2 regarding the proposals we 

reviewed. Some of the more significant proposals that the 

sites did not take advantage of include: 

• Los Alamos had not implemented an opportunity, 

which had been proposed multiple times since 

FY 2001, to use lead-free bullets at its major 

outdoor firing range. While lead-free bullets cost 

more than lead alternatives, they are 

environmentally friendly and do not require a firing 

range remediation every 25 years. As a result, the 

purchase of such bullets could save Los Alamos 

$97,100 each year, about $2.4 million over the 

life-cycle of the project. According to Los Alamos 

officials, they had not implemented the proposal 

because of funding limitations and concerns about 

the availability of all necessary calibers of lead-free 

bullets. However, we noted that other Federal 

training facilities such as the Federal Law 

Enforcement Training Center are successfully using 

lead-free ammunition. 

• During 2003, Los Alamos also identified but did not 

take advantage of an opportunity to potentially 

reduce water consumption and chemical usage 

through the testing and design of silica seed crystal 

filters at a cost of $60,000. The filters would reduce 

the formation of silica scale in Los Alamos cooling 

towers enabling them to operate at higher levels of 

concentration. By increasing the level of 

concentration in the cooling towers, Los Alamos 
 

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Page 3 Details of Finding 

estimated that the filters would save over $501,000 

per year in costs attributed to the use and disposal of 

nearly 41 million gallons of water and treatment 

chemicals required to control corrosion and silica 

scale formation. Los Alamos officials said that the 

project was one of several similar projects that had 

not been implemented due to insufficient funding. 

• In April and May of 2003, Sandia identified but did 

not implement five feasible opportunities to 

minimize waste. These initiatives were estimated to 

generate life-cycle cost savings of about $216,000 

and required an initial capital investment of less 

than $54,000. These opportunities to minimize 

waste included: (1) purchasing a wood chipper for 

mulching green waste for reuse on-site that would 

reduce life-cycle disposal costs by more than 

$50,000 over a ten-year period; and (2) installing 

paint shop equipment to reduce the life-cycle costs 

of solvent disposal by approximately $26,000. 

According to Sandia officials, these opportunities 

were not implemented due to limited funding or a 

lack of facility interest. 

Managerial Focus Pollution prevention managers at all of the sites we visited 

did not believe that they had adequate program support to 

maintain an effective pollution prevention program. 

Additionally, the Department did not hold managers 

accountable for identifying and implementing costeffective opportunities. 

Program Support

Program offices and the National Nuclear Security 

Administration (NNSA) had not fully supported pollution 

prevention activities since they were made responsible for 

directly funding the program in FY 2003. In August 2002, 

the Office of Environment, Safety and Health 

(Environment, Safety and Health) became responsible for 

policy development and individual program elements were 

required to fund pollution prevention activities. Prior to 

that date, the Office of Environmental Management 

(Environmental Management) had lead responsibility for 

pollution prevention and provided centralized funding to 

other programs to implement promising projects. After this 
 

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Page 4 Details of Finding 

realignment, all the sites we visited told us that support, 

including funding, direction and/or perceived importance of 

the program was not adequate to continue activities at the 

most successful levels. For example, Hanford Site 

pollution prevention officials told us that since FY 2003, 

the site had cut its staff from approximately seven staff 

members to one member, and had limited efforts, for the 

most part, to monitoring ongoing recycling activities and 

reporting waste generation data. Other than at NNSA sites, 

we were unable to determine the level of funding provided 

for prevention activities because most program offices did 

not budget or track funding. 

Problems with program direction and emphasis also existed 

in the organization formerly responsible for its overall 

administration and funding – Environmental Management. 

We noted Environmental Management did not assign 

responsibility for coordinating the program's pollution 

prevention activities across its sites and contractors until 

about two years after responsibility for the Departmentwide program was transferred to Environment, Safety and 

Health. Recently, Environmental Management assigned 

responsibility for program coordination and emphasized to 

site managers' their responsibility to conduct pollution 

prevention activities consistent with Departmental 

requirements. 

Although site pollution prevention managers told us that 

they did not have adequate funding for their activities, we 

noted that Los Alamos had implemented an innovative 

funding strategy to supplement their program by charging a 

fee to waste generators, based on the quantity and type of 

waste generated. Los Alamos invested the waste generator 

fee in prevention activities. In FY 2004, this generator fee 

provided approximately $600,000 which funded eleven 

pollution prevention projects. 

Accountability

The organizations included in our review had not 

established performance measures for their pollution 

prevention programs. Furthermore, three of the four sites 

included in our review did not have performance measures
 

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Page 5 Recommendations 

for pollution prevention activities (Los Alamos was the 

only site with pollution prevention performance measures 

at the time of our review). As a result, managers had not 

been held accountable for implementing an effective 

program. 

Opportunities for The Department is missing opportunities to reduce costs 

Savings and minimize waste generation across the complex. Based 

on our review of selected proposals, we identified potential 

life-cycle cost savings of over $5.5 million from 9 

proposals that the sites determined to be feasible and costeffective but were not implemented. Additionally, cost 

savings at one Environmental Management site have been 

reduced an average of nearly $40 million dollars each year 

since FY 2002. Without renewed emphasis on the 

pollution prevention program, the Department may 

continue to miss opportunities to cost-effectively reduce 

waste streams.

RECOMMENDATIONS We recommend that the Administrator, National Nuclear 

Security Administration and the Assistant Secretary for 

Environmental Management, in conjunction with the 

Assistant Secretary for Environment, Safety and Health: 

1. Ensure that sites implement the pollution 

prevention provisions of DOE Order 450.1, by: 

 

 (a) Conducting operational assessments of 

site operations to identify opportunities 

for pollution prevention projects and 

implementing those deemed costeffective using life-cycle assessment 

concepts and practices; and, 

(b) Employing innovative strategies, such 

as waste generator's fees, to fund costeffective pollution prevention programs. 

2. Develop and implement performance measures 

for pollution prevention activities that 

reemphasize the program and hold managers 

accountable for implementation.
 

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Page 6 Comments 

MANAGEMENT In separate responses from the responsible Departmental 

REACTION organizations, management generally concurred with the 

report's findings and recommendations. Management's 

comments are included in Appendix 4 and summarized 

below. 

The National Nuclear Security Administration (NNSA) 

generally agreed with our report and recommendations. 

NNSA acknowledged that our conclusions were similar to 

those reached during its FY 2004 site reviews and agreed to 

include our findings in a memorandum it plans to send to 

their site managers. NNSA sites also commented that 

several of the examples used in the report have now been 

identified for future implementation. 

The Office of Environmental Management (EM) agreed to 

implement the recommendations by providing additional 

guidance to their field managers on the need to conduct 

opportunity assessments, and developing and implementing 

performance measures for pollution prevention. EM stated 

that part of its mission is to find innovative solutions to 

clean up past contamination problems and, where possible, 

use waste minimizing approaches to cut the cleanup risk, 

schedule, and cost. In addition, they included an 

attachment from the Office of River Protection (ORP) 

emphasizing it has requirements in place directing its 

contractor to perform operational assessments. 

The Office of Environment, Safety and Health (EH) agreed 

to work, in conjunction with NNSA and EM officials, to 

implement the report's recommendations. However, EH 

raised the concern that our draft report did not recognize 

the Department's numerous pollution prevention successes. 

EH also noted that its office is not in a position to ensure 

that actions are undertaken at Departmental sites or to hold 

site managers accountable. However, they agreed to 

support NNSA and EM by monitoring site performance in 

implementing the pollution prevention provisions of DOE 

Order 450.1 and providing information that will assist in 

carrying out the report's recommendations. 
 

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Page 7 Comments 

AUDITOR COMMENTS Management's comments are generally responsive to our 

recommendations. Based on these comments, we have 

made several changes to the body of this report where 

necessary. With regard to ORP's comments related to 

operational assessments, we agree that such requirements 

had been established. We noted, however, that contractors 

had not actually performed the required assessments and 

ORP had not taken action to compel their completion. 
Appendix 1______________________________________

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Page 8 Objective, Scope, and Methodology 

OBJECTIVE To determine whether the Department and its contractors 

are maintaining an effective pollution prevention program. 

SCOPE The audit was performed between January 2004 and 

January 2005. We conducted work at Headquarters, 

Washington, D.C., and Germantown, MD; NNSA Service 

Center and Sandia National Laboratories (Sandia), 

Albuquerque, NM; Los Alamos National Laboratory (Los 

Alamos), Los Alamos, NM; and the Richland Operations 

Office and Office of River Protection at the Hanford Site, 

Richland, WA. 

METHODOLOGY To accomplish our audit objective, we: 

• Reviewed laws, regulations, contractual 

requirements, as well as, policies and procedures 

relevant to Departmental pollution prevention and 

waste minimization activities; 

• Reviewed site pollution prevention program plans 

and other site specific guidance where available; 

• Held discussions with Headquarters program 

officials regarding pollution prevention and waste 

minimization at the Department; 

• Held discussions with officials from the NNSA 

Service Center, Richland Operations Office, 

Office of River Protection, and contractor officials 

from Sandia, Los Alamos and the Hanford Site 

regarding pollution prevention and waste 

minimization at the individual sites; 

• Selected a judgmental sample of 20 recent 

pollution prevention opportunities documented at 

the Sandia and Los Alamos National Laboratories 

and conducted a review to determine whether 

cost-effective feasible opportunities were being 

implemented; 

• Reviewed Pollution Prevention Opportunity 

Assessments at other Departmental sites not 

visited during our audit;
Appendix 1 (continued)____________________________

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Page 9 Objective, Scope, and Methodology 

• Reviewed pollution prevention accomplishment 

reports for the years 2000-2003 at the Hanford 

Site to determine whether recent reductions in the 

pollution prevention program have reduced 

reported accomplishments; and, 

• Participated in the Department's first Pollution 

Prevention Televideo Conference. 

The audit was performed in accordance with generally 

accepted Government auditing standards for performance 

audits and included tests of internal controls and 

compliance with laws and regulations to the extent 

necessary to satisfy the audit objective. We did not identify 

any performance measures required by the Government 

Performance and Results Act of 1993 applicable to the 

Department’s pollution prevention program. Because our 

review was limited, it would not necessarily disclose all 

internal control deficiencies that may have existed at the 

time of our audit. We did not rely on computer processed 

data to accomplish our audit objective. 

An exit conference was held with officials from the Offices 

of Environmental Management and Environment, Safety 

and Health on March 8, 2005. NNSA waived the exit 

conference.
Appendix 2______________________________________

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Page 10 Pollution Prevention Proposals 

POLLUTION PREVENTION PROPOSALS

Location Opportunity Description Waste Reduced 

Initial 

Cost of 

Project 

Life-Cycle 

Cost 

Savings 

1. Sandia Refillable 

Aerosol 

Containers 

Replace current aerosol cans for a 

number of cleaners, paints and 

adhesives with refillable spray 

bottles. 

Eliminates the solid and 

potentially hazardous 

waste stream generated 

by aerosol cans. 

$450 $6,329 

2. Sandia Wood Chipper Purchase of a new wood chipper to 

fully accommodate the green waste 

production on site. 

Approximately 660 cubic 

yards of green waste. 

$15,600 $50,129 

3. Sandia Solvent 

Distillation 

Unit/ Paint Gun 

Washer 

1. Install an on-site distillation unit 

that would recycle all solvents used 

in the Paint Shop. 2. Install a paint 

gun washer which provides closedloop cleaning and is more efficient 

than cleaning by hand. 

Reduce annual disposal 

costs for spent solvent by 

approximately 75%. 

$4,000 $26,211 

4. Sandia Parts Wash 

Rack 

Install a closed-loop, aqueous 

spray system to replace the current 

method of cleaning metal parts by 

hand in preparation for painting. 

Decreases the quantity of 

waste disposal by 85%. 

$33,095 $78,351 

5. Sandia Paint Shop 

Specification 

Modifications 

Reduce the types and colors of 

paint called for in the specifications 

from 75 to 25, and eliminate the 

requirement that contractors leave 

extra paint on site. 

Approximately 85% of the 

paint waste streams could 

be eliminated. 

$0 $55,000* 

6. Los 

Alamos 

Lead-Free 

Ammunition 

Replace traditional lead bullets with 

environmentally friendly lead-free 

bullets at the outdoor firing range. 

Eliminates 1000 KG of 

lead waste per year. 

$35,000 $2,427,500* 

7. Los 

Alamos 

Cooling Tower 

Sand Filter 

Install a "seed crystal" filter to 

remove silica from cooling tower 

systems to protect the heat transfer 

surfaces and allow operation at 

increased cycles of concentration. 

Eliminates nearly 41 

million gallons of water 

wasted and associated 

chemicals per year. 

$60,000 $2,506,130* 

8. Los 

Alamos 

Leaking 

Laboratory 

Faucets 

Replace leaking faucets with user 

friendly faucets which permit water 

to be completely shut off after use. 

Eliminates 1.1 million liters 

of clean water per year 

that is being treated as 

radioactive liquid waste. 

$2,500 $295,955* 

9. Los 

Alamos 

Equipment 

Room Shower 

Heads 

Replace current shower heads with 

low flow shower heads. 

Reduces discharge to 

Radioactive Liquid Waste 

Treatment Facility by 

341,262 liters per year. 

 

$1,500 $84,265* 

TOTALS: 

* OIG calculations based on information provided by site officials. 

$152,145 $5,529,870 
Appendix 3______________________________________

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Page 11 Prior Reports 

PRIOR REPORTS

• Department of Energy's Waste Minimization Program (DOE/IG-0298, 

September 6, 1991). The audit found that while waste minimization progress was 

being made, significant opportunities to eliminate waste still existed. Waste 

minimization opportunities were not being implemented because of limited use of 

incentives, minimal program guidance, and funding uncertainties. The report also 

noted that in generating excessive amounts of waste, the Department will continue 

to be exposed to acknowledged environmentally dangerous conditions that will 

require costly remedial actions. 

• The U.S. Department of Energy's Value Engineering Program (HQ-B-98-01, 

July 17, 1998). The audit found that the Department had not fully developed and 

implemented an effective value engineering program. Some value engineering 

savings were not always supported or not truly the result of the formal value 

engineering methodology and some field activities had not consistently computed 

and reported value engineering savings. The Department's success with value 

engineering was limited by inadequate policy and procedures and lack of annual 

plans, goals, and objectives. As a result, the intended value engineering goals of 

reducing costs, increasing productivity, streamlining operations, and improving 

quality may not have been achieved to the fullest extent possible. 
Appendix 4 

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Page 12 Management Comments 
Appendix 4 (continued) 

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Page 13 Management Comments 
Appendix 4 (continued) 

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Page 14 Management Comments 
Appendix 4 (continued) 

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Page 15 Management Comments 
Appendix 4 (continued) 

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Page 16 Management Comments 
IG Report No. DOE/IG-0680

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