EMS / NEPA Integration at the Idaho National Laboratory

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EMS / NEPA Integration at the Idaho National
Laboratory

• Bruce Angle John Irving
• Battelle Energy Alliance
• Idaho National Laboratory

Environmental Management System Workshop March
8-9, 2005
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The INL

• Located in Eastern Idaho
• 890-square mile reservation
• Managed by Battelle Energy Alliance for the DOE
• Lies within the upper Snake River Plain sagebrush
  steppe ecosystem
• Several major facilities
• High mountain desert ecosystem known for its
  cultural and natural resources
• The major laboratory activities
• Nuclear energy research and engineering
• National security technology development

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Time Line
ISMS Implementation begins
ISO 14001 Registered
ISO-14001 Started
Req. Flow Down
INEEL Consolidation
NEPA Process
1990
2000
1995
2005
Subject Matter Based
Work Activity Based
Re-registration Decision
New INL Contract
Six Surv. Audits
ISO Reg.
2000
2005
Environmental Management System Workshop March
8-9, 2005
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INLs Perspective

• The NEPA Process at the INL is part of the INLs
  Environmental Management System
• The EMS is fully integrated into INLs Integrated
  Safety Management System
• EMS is patterned after ISO 14001 requirements

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Status of INLs EMS

• Meets EO 13148 DOE Order 450.1
• Robust EMS, fully includes NEPA values
• Registered to ISO 14001, and has successfully
  passed five surveillance audits
• Management decision to consolidate first, then
  seek ISO 14001 registration.

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EMS and NEPA

• EMS Elements
• Environmental Aspects
• Work ActivitiesSignificant Work Activity
• Potentially Significant Environmental Aspect

• NEPA Values
• Potential Impacts Issues
• Proposed Activities
• Significance Determination, (i.e., CX, EA (FONSI)
  or EIS (ROD)

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Significance?

• Under INLs EMS
• The company chooses what is significant and what
  it wants to influence through the selection of
  criteria and the setting of objectives and
  targets.
• Under NEPA
• Agencies generally determine potential
  significance through a detailed statement or
  EIS, often relying on thresholds of
  significance and considering the intensity
  context of the impacts.

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Significance Determination
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Environmental Aspects
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INLs Environmental Checklist
Combines EMS NEPA Elements
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Purpose of EC

1. Determine level of environmental review (such as
   environmental assessment or environmental impact
   statement. In other words, determine the
   potential for significant environmental impacts.

1. Flow down requirements (through instructions from
   MCP-3480) to the worker.

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Purpose of EC

1. Identify new work activities with environmental
   requirements.

1. Identify new environmental aspects.

1. Identify significant environmental aspects of new
   work activities and develop controls.

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Environmental Checklist / Sec. A

• Provide Descriptive Information
• Charge Number
• INL / ICP
• Project Title
• Performing Organization
• . . .

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Environmental Checklist / Sec. B

• Project Description Provide a Brief and accurate
  description of the project or activity on
  attached sheet.
• Brief and accurate
• Purpose need
• Type of activity
• Location
• Beginning ending dates

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Environmental Checklist / Sec. C

• Environmental Aspects / Potential Sources of
  Impact Check the appropriate box and provide
  explanation for any aspect checked Yes on an
  attached sheet.
• Air Pollutants
• Asbestos Emissions
• Biological Hazards
• Chemical Use Storage
• Contaminated Sites Disturbance
• Cultural/Historical . . .

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Environmental Checklist / Sec. D

• Work Activities and Environmental Checklist
  Submittal Determination Select all of the
  applicable work activities.
• From MCP-3480
• Required to submit EC to Environmental
  Compliance?
• Not required to submit EC to Environmental
  Compliance?

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Environmental Checklist / Sec. E

• Conditions Are conditions required before
  starting project?
• APADs (Air Permitting)
• Cultural Resource Clearance
• Biological Resource Clearance
• Other approvals

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Environmental Checklist / Sec. F

• Determine the Level of Environmental Review (or
  Documentation)
• Categorical exclusion
• Environmental assessment
• Environmental impact statement . . .

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INLs Environmental Management System
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Benefits
Environmental Enforcement Penalties (Original
Assessed Penalty)
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Tangible Intangible Benefits of an EMS / NEPA
Process

• Tangible
• Environmental compliance
• Reduced fines penalties
• Pollution prevention activities
• Integration with other systems such as NEPA
• Intangible
• Environmentally conscious workforce
• Environmental protection
• Continual improvement

Moving beyond compliance
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The End
Contact John Irving John.Irving_at_inl.gov 208.526.8
745 Or Bruce Angle Bruce.Angle_at_inl.gov 208.526.1
841