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Presentation to N.C. Division of Pollution Prevention and Environmental AssistanceEnvironmental Management Systems Development Course for Government Agencies: 

Presentation to N.C. Division of Pollution Prevention and Environmental Assistance Environmental Management Systems Development Course for Government Agencies David L. Lester, CM, REM Lead Technical Specialist Environmental Protection Department Westinghouse Savannah River Company Aiken, South Carolina 20809 Environmental Management System Communication Success at Savannah River

Slide2: 

SRS was established in 1950 Includes portions of Aiken, Barnwell and Allendale counties The land cost $19 million and includes 310 square miles Ellenton, Dunbarton and other towns were home to 6000 people who had to relocate Savannah River Site (SRS) History

Slide3: 

Construction began February 1951 Five reactors; two separations areas; a heavy water plant; a fuel fabrication plant; and administrative facilities <10% land used for production All operations cloaked in secrecy SRS History (cont.)

Slide4: 

Primary mission of SRS was to produce plutonium and tritium for nuclear weapons Cold War Missions and Programs

Slide5: 

Production Process

Slide6: 

Post-Cold War Missions and Programs National Defense replacement tritium facility Nuclear Materials Management separation facilities spent nuclear fuel Environmental Management waste management environmental remediation

SRS Natural Features: 

SRS Natural Features 4,000 acres of ponds and reservoirs 300 miles of streams 35,000 acres of bottomland hardwood 530 acres of streams and waterways 5,800 acres of swamp forest 40,000 ccf of timber harvested annually 44 amphibian, 59 reptile, 255 bird, 54 animal species, 45 fish species, 1,322 species of flora Some endangered/threatened species are residents Southern Bald Eagle, red-cockaded woodpecker, smooth purple coneflower, Bachman’s sparrow, American alligator, shortnose sturgeon, bog spice bush

Regulated Activities: 

Regulated Activities @ 675 environmental permits in effect 3 public drinking water systems 13,000 people 34 NPDES outfalls - 5,700 parameters annually 150 stormwater outfalls - 1,200 parameters annually 30 wastewater treatment plants 28,000 Material Safety Data Sheets managed 235,000,000 pounds of chemical inventory 14,000 chemicals and chemical products used 83 line items on the EPCRA Tier II inventory

Waste Management: 

Waste Management @ 270 hazardous waste accumulation areas 1.2M pounds of hazardous waste shipped annually 16 RCRA permitted treatment facilities 1M gallons of stored RCRA waste 36M gallons of stored liquid high-level waste in 49 carbon steel underground storage tanks 2M pounds of vitrified waste at Defense Waste Processing Facility 477 waste units (1/3 closed)

EMS Implementation at SRS: 

EMS Implementation at SRS Assumptions Process General Description and Timeline Discussion Integration with Department of Energy Safety Management Program -- We bring ISO 14001 into Operations Teaming Results Lessons Learned Identify Risks Questions

Operating Assumptions and “Givens”: 

Operating Assumptions and “Givens” Assumptions Site policy and commitment to comply with regulations is strong, therefore maintaining good regulatory relationships Regulations will continue to evolve and increase in complexity and WSRC has ability to negotiate compliance schedules Site Operations will be consistent with forecast at beginning of fiscal year (including Environmental Restoration projects) No dramatic change in number of permitted discharge points, chemical usage, and permitted waste streams No dramatic change in frequency or extent of regulatory audits No major unplanned spills or other accidental releases with offsite consequences

Implementation of ISO 14001 at SRS: 

Implementation of ISO 14001 at SRS Benchmark Team represented entire site (1997) Key Decision - Implement site wide versus individual organizations Key Decision - Evolution versus revolution Gap Analysis and Gap Closure Plan (1998) Gap closure continued through implementation phase Implementation Team - Management commitment of resources Key Decision - Third party certification or self-declare conformance? Registrar “selection” (1998) Completed self-declaration and independent audit (1998) Key Decision - Identify cost benefits for independent certification

Slide13: 

ISMS OSHA Process Safety Mgmt (PSM) Enhanced Work Planning (EWP) Voluntary Protection Program (VPP) EPA Risk Mgmt Plan (RMP) Environmental Management System (ISO 14001) Chemical Manufacturers Association (CMA) Responsible Care  Individual Safe Behaviors

Slide14: 

A management system that integrates “Safety” to encompass the public all employees the environment, including waste minimization pollution prevention at the worker, organization, and corporate level. What is the DOE Integrated Safety Management System (ISMS)?

Communication of ESH Programs into Work at SRS: 

Procedures Personnel Plant WSRC Programs Each Program Addressed by One (or More) Site Level Manuals e.g. 3Q Environmental Compliance, 1S Waste Acceptance Criteria, 1Q Quality Assurance Communication of ESH Programs into Work at SRS ESH Programs Covering 20 Functional Areas Site S/RID e.g.. Environmental Protection & Waste Management Contractor Requirements Define Scope of Work S/RID Integrated Procedure Management System Develop/Implement Controls Conduct of Operations Conduct of Maintenance & Engineering Conduct of Training Get Work Done Safely Perform Work Feedback & Improvement

Communications within EPD - Regulatory Compliance: 

Communications within EPD - Regulatory Compliance Environmental Laws and Regulations, Permits, Consent Orders DOE Orders EPD SMEs Review, Comment, Negotiate, Influence, Interpret Requirements, Provide Guidance, Assess Program Effectiveness EPD and Matrixed Environmental Groups Develop Site Policy (EMC) Programs and Procedures EMC and Facility Management Develop Execution Strategy EPD SMEs Provide Field Support, Training, Advise, Write Reports, Assist in Evaluating Upsets, Assessments, Develop Improvements, Lessons Learned

Environmental Communications outside EPD - ECA Operational Support: 

Environmental Communications outside EPD - ECA Operational Support EPD and Matrixed Environmental Groups Develop Site Policy (EMC) Programs and Procedures EMC and Facility Management Develop Execution Strategy Field Environmental Compliance Authorities Work with Operating Personnel to Include Program Requirements in Facility Procedures Facility Management Include Specific Environmental Requirements in All Their Operations Field Environmental Compliance Authorities Assist Operating Personnel with Implementation, Assess Implementation, Provide Input for Site Reports

Teaming = Synergy: 

Teaming = Synergy Planning and preparation for normal or recurrent activities Participate in strategic planning and activity execution Project Teams Permit Application Development Enhanced Work Planning Technical Support and Assessment of Program Implementation Waste Management Training Bring global vision of environmental requirements to Operations personnel Fill gaps between procedures and their intent Use expertise to influence right decisions Enhance environmental hazard awareness in the performance of Job Hazard Analyses, work planning Senior management involved at budget/planning stage

Teaming = Synergy: 

Teaming = Synergy Help integrate Environmental Management System requirements into the operating culture For SRS, this meant extending application of principles and functions of ISM to activities that involve environmental protection, i.e., Enhanced work planning Procedure Development Management Tours Operator Rounds Applicability of different requirements to an operation Different Laws/Requirements depending on situation Appropriate Response actions

Teaming = Synergy: 

Teaming = Synergy Hazard Analysis for unstructured activities Help analyze hazards when “out of the box” - Identify options and risks Understand politics and commitments Guidance when situation not covered by procedures Rationale to do the environmental protection “right thing”

Teaming = Synergy: 

Teaming = Synergy Help integrate Environmental Management System requirements into the operating culture (Continued) Normal operations that could challenge the environmental protection envelope Improve the application of pollution prevention, waste minimization, and energy efficiency techniques within work activities Assist in development of workplace culture that promotes the concept of confirmed readiness to perform work and readily stops work if conditions change Help develop clearly defined work instructions through interactions with operations and maintenance personnel

Success Keys: 

Success Keys Communication that is both timely and complete Acquire full understanding of each situation before acting Spend time in field with affected organizations Provide solution options, not hurdles Include options and their risks so an informed decision can be reached Keep discussions professional Eliminate hidden agendas All one team with one purpose “Win-Win” is the only solution that makes everyone happy Operations really wants to do the right thing Listen and respond to the urgency Don’t assume

Benchmarking Environmental Management System at SRS: 

Benchmarking Environmental Management System at SRS First major site in DOE Complex to achieve and maintain independent certification against ISO 14001 international standard SRS’s program has been used to benchmark other organizations Brookhaven National Laboratory NASA Public Works Authority of Charleston Canadian Government Independent certification stopped in Fiscal Year 2002 Lack of progress indentifing real cost benefits Continue to self-declare and maintain programs (required by E. O 13148)

Lessons Learned: 

Lessons Learned Quality of EMS “manual” Manager’s familiarity and use of EMS manual Over emphasize objectives and targets throughout organization “Limit” aspects to significant impact - define significant Use every means possible to publicize policy Clearly delineate EMS audit results - widely publicize Formalize Management Review process (procedure, schedule, etc.) Involve “communicators” Pre-audit records (training, qualifications, calibration, logbooks) Pre-audit performance indicators and tracking systems Over emphasize “management system” audit, not compliance audit Communicate, communicate, communicate, with management, employees, subcontractors

Go “Out of the Box” to Identify Potential Risks: 

Go “Out of the Box” to Identify Potential Risks Operating Risks Facility Shutdowns Loss of water service (sewer, drinking, wastewater, etc.) Loss of waste disposal capacity (landfill, LLW, etc.) Ventilation system shutdown Loss of ability to store material from DOE sites Financial Risks Fines and Penalties (unallowable costs) Projects slower and costlier Potential loss of new missions Increased cost through loss of self-permitting for domestic and sanitary sewers Loss of Fee potential

More Risks: 

More Risks Environmental Damage/Public Health Risks Non-availability of emergency response, monitoring, and investigations Customer/Public Relations Risks New Missions jeopardized by poor compliance record Loss of Fee for violations and fines; unhappy customers Public Perception, political support at risk

Concluding Thoughts and Suggestions: 

Concluding Thoughts and Suggestions Communication Talk the walk and walk the talk Best way for individual worker to think environmental protection is for them to see it practiced daily by their supervisors Stress more positives, but don’t downplay negatives Involvement Actively use environmental professionals in other programs Supervision needs to value the effort needed, managers set the example

Concluding Thoughts and Suggestions: 

Training/Education Part of Continuing Training -- often and strong Drills and practice exercises must reinforce your EMS “Cross walk” EMS concepts into other training arenas (maintenance, CONOPs, waste certification, safety, emergency preparedness) Commitment Give your people the tools they need to succeed Self-Declare or Not? Business Basis Regulator Exercise of “enforcement discretion” Concluding Thoughts and Suggestions

Slide29: 

Coincidence or Not ? If, A B C D E F G H I J K L M N O P Q R S T U V W X Y Z Equals, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Then, K + N + O + W + L + E + D + G + E 11 + 14 + 15 + 23 + 12 + 5 + 4 + 7 + 5 = 96% H + A + R + D + W + O + R + K 8 + 1 + 18 + 4 + 23 + 15 + 18 + 11 = 98% Both are important, but the total falls just short of 100% But, A + T + T + I + T + U + D + E 1 + 20 + 20 + 9 + 20 + 21 + 4 + 5 = 100%