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 SystemEnvironmental Management SystemCommunication Success at Savannah RiverCommunication Success at Savannah River

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• 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 werehome to 6000 peoplewho had to relocate

Savannah River Site (SRS) History

Savannah River Site (SRS) History

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• 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.)SRS History (cont.)

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Primary mission of SRS was to produce

plutonium and tritium for nuclear weapons

Cold War Missions and Programs

Cold War Missions and Programs

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Production Process

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Post-Cold War Missions and Programs

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

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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

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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

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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)

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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

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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

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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

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ISMSISMS

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

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A management system that integrates “Safety” to A management system that integrates “Safety” to encompassencompass the publicthe public all employeesall employees the environment, includingthe environment, including

waste minimizationwaste minimization pollution prevention pollution prevention

at the worker, organization, and corporate at the worker, organization, and corporate level.level.

What is the DOE Integrated Safety Management System (ISMS)?

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Procedures

Personnel

Plant

WSRCPrograms

Each ProgramAddressed by One (or More)

Site Level Manuals

e.g. 3Q EnvironmentalCompliance,

1S Waste AcceptanceCriteria,

1Q Quality Assurance

Communication of ESH Programs into Work at SRS

ESHPrograms

Covering 20Functional Areas

Site S/RID

e.g.. EnvironmentalProtection & Waste

Management

Contractor RequirementsDefine Scope of Work

S/RID

Integrated Procedure Management SystemDevelop/Implement Controls

Conduct ofOperations

Conduct ofMaintenance &

Engineering

Conduct ofTraining

Get Work Done SafelyPerform Work

Feedback &Improvement

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Communications within EPD - Regulatory Compliance

Environmental Laws

and Regulations,

Permits, Consent Orders

DOE OrdersEPD 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

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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

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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

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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

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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”

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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

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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

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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)

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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

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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

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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

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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

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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

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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%

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