FY02 ASA Presentation Manage NIH Environmental Compliance and Pollution Control Activities

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FY02 ASA Presentation Manage NIH Environmental
Compliance and Pollution Control Activities

• Prepared by
• Jim Carscadden
• Valerie Nottingham
• Terry Leland
• Ed Pfister
• Mark Miller
• Swati Damle
• Ed Rau
• Office of Research Services
• National Institutes of Health
• 18 November 2002

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Environmental Compliance and Pollution Control
Responsibilities

• Construction project review for compliance with
  environmental regulations and NIH standards
• Coordinates permits serving as the NIH Point of
  Contact for regulatory issues
• Develops regulatory reports as necessary to
  respond to routine permit requirements and
  address new requirements
• Investigate reports of Environmental Releases
  -report to appropriate entity as needed
• Work with DES Project Officers on construction
  issues
• Manage NEPA Compliance - review all major
  actions which could impact the environment
• Manage the Underground Storage Tank Program
• Provide guidance to laboratory staff on waste
  management procedures including sanitary sewer
  wastes and
• Promote Pollution Prevention and Waste
  Minimization Initiatives.

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Service Group Block Diagram

• Our Service Groups five discrete services cover
  approximately 55 percent of the work of the NIH
  Environmental Protection Branch (EPB) for FY02.
• All responsibilities and activities can be placed
  under one of two essential groupings, as shown
  below.

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Discrete Services

• Manage NIH Environmental Compliance and Pollution
  Control Activities (five discrete services)
• DS 1 Manage Permit Acquisition
• DS 2 Manage Permit Compliance
• DS 3 Respond to Environmental Emergencies
• DS 4 Manage NEPA (National Environmental Policy
  Act) Process
• DS 5 Conduct Photographic Equipment Silver
  Recover Unit Inspection and Consultation

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Customer Perspective
- Customer Value Proposition - Customer
Segmentation - Customer Satisfaction
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Customer Value Proposition

• Provide professional guidance from highly trained
  scientific personnel to assist the NIH in meeting
  and/or exceeding all necessary environmental
  standards such that the NIH can continue to be an
  important leader in responsible environmental
  management.

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Customer Segmentation

• The Pollution Control Section and the
  Environmental Compliance Team have the NIH as
  their primary customer.
• Majority of services outlined herein are provided
  to NIH in concert with those services provided by
  DES.
• Some Pollution Prevention services are provided
  by EPB directly on behalf of NIH.
• Customer population for Discrete Service 1
  (Permit Acquisition) and Discrete Service 2
  (Permit Compliance) are the same

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Customer SegmentationDS 1 Permit Acquisition -
Environmental Permits
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Customer SegmentationDS 1 Permit Acquisition -
Environmental Permits
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Customer SegmentationDS 2 Permit Compliance -
Clean Air Act Emission Sources
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Customer SegmentationDS 2 Permit Compliance
Clean Air Act Emission Sources
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Customer Segmentation DS 4 NEPA Reviews

• NEPA Reviews are required for any major federal
  action.
• We conduct 10 to 30 reviews per year.
• Most reviews are for building construction.
• Results of reviews are
• No Further Action
• Categorical Exclusion
• Environmental Action
• Environmental Impact Statement

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Customer Segmentation DS 4 NEPA Reviews
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Customer Segmentation DS 5 Silver Recover Unit
Consultation

• NIH has more than 24 research institutes/centers
  which may have laboratories.
• Institutes/centers vary widely in the number of
  laboratories they include.
• Any laboratory at NIH could have photographic
  equipment.
• It is not possible to accurately predict which
  labs have photographic equipment and therefore
  should be aware of the importance of silver
  recovery.
• Continual surveys of the entire campus are
  required to accurately maintain baseline data.

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Customer Segmentation DS 5 Silver Recover Unit
Consultation

• Silver Recovery Units are required on all photo
  processing equipment to capture silver
  discharges. Required by the NIH Wastewater
  discharge permit as well as by Hazardous Waste
  Generation regulations.
• Due to continuous changes in locations of
  laboratories and research, customer segmentation
  fluctuates annually. Any laboratory in any
  Institute could acquire or remove photo
  processing equipment at any time.
• Due to personnel changes, employees responsible
  for the darkroom changes frequently.
• All Institute laboratories must be surveyed
  annually maintain accurate documentation and
  ensure compliance.

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Customer Satisfaction

• The Environmental Compliance Team and the
  Pollution Control Section are regulatory groups.
• While customer satisfaction is important, it is
  not the driver for required environmental
  compliance or pollution control actions.
• Informal customer comments indicate that
  necessary and critical responsibilities for
  compliance may not be well understood or
  welcomed.

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Internal Business Process Perspective
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Internal Business Process Perspective

• DS 1 Manage Permit Acquisition
• DS 2 Manage Permit Compliance
• DS 3 Respond to Environmental Emergencies
• DS 4 Manage NEPA (National Environmental
  Protection Act) Process
• DS5 Conduct Photographic Equipment Silver
  Recover Unit Inspection and Consultation

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DS 1 Manage Permit Acquisition
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DS 4 Manage NEPA Process
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DS5 Conduct Photographic Equip-ment Silver
Recover Unit Inspection and Consultation
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Conclusions from Discrete Services Deployment
Flowcharts

• Our Service Group completed three deployment
  flowcharts for five discrete services.
• The process for permit compliance is extremely
  variable, therefore the process map for DS 2 was
  not drawn.
• The process of responding to emergencies (such as
  spills, underground leaks, etc.) is too variable
  to be captured in a simple flowchart, therefore
  the process map for DS 3 was not drawn.

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Conclusions from Discrete Services Deployment
Flowcharts

• Using our staffs scientific/engineering
  expertise, EPB designed and implemented the
  processes NIH has used for over 20 years to
  comply with the various environmental compliance
  and pollution control regulations and
  requirements.
• EPB does not have primary control of the time
  expended in connection with most of these
  processes that is, our activity time the
  amount of time EPB personnel are actively working
  on our part of the process is a small
  proportion of the total time expended in these
  activities.
• Therefore, we need to work cooperatively with all
  NIH requestors, but primarily DES, to continue to
  improve the various processes.

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Process Measures Tracked this Year

• DS 1 Permit Acquisition. Analysis of in-house
  vs. overall cycle and activity time for permit
  acquisition.
• DS 2 Permit Compliance. Monitor WSSC discharge
  vs. number of notices of violations Essentially
  this is a comparison of the number of monitoring
  events against the number of violation resulting
  from those events.
• DS 3 Emergency Response. Document emergency
  response time (baseline).
• DS 4 NEPA. Analysis of in-house vs. overall
  cycle and activity time for conducting NEPA
  reviews.
• DS 5 Silver Recovery. Assess effectiveness of
  pollution control education by documenting silver
  recovery interventions vs. silver recovery unit
  acquisitions.

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Process Measures General Findings

• This years process measures do not capture the
  breadth of required compliance actions. For
  example, for emergency response, the overall time
  necessary to ensure environmental compliance is
  more meaningful than the time to respond.
• That is, the time involved in working on the
  emergency and cleaning up the problem is what is
  important.
• Additionally, as noted earlier, we must work with
  those who have primary control over the processes
  in which we are involved.
• For example, there are several initiatives in
  place involving closer coordination and
  cooperation between EPB and DES.
• These initiatives will affect what is measured
  next year in this Service Group.

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Process Measures Specific Findings

• DS 1 (Permit Acquisition)
• Cycle time analysis not the best measure, even
  though it documents the distribution of duties
  and time required.
• Better measure would be to measure discrete
  elements and how they relate to the total so that
  ANY area of improvement can be identified.
• No useful data was collected in FY02.
• In FY02, we processed approximately 75 permits.
• Total acquisition time ranged from 2 months to 2
  years.

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Process Measures Specific Findings

• DS 2 (Permit Compliance)
• Monitoring of discharge and documentation of
  violations will continue.
• Total number of Notices of Violations by WSSC
  during FY02.
• All violations were pH violations.

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Process Measures Specific Findings

• DS 2 - Results of Source Investigation of 14 pH
  Excursions 1999-2002

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Process Measures Specific Findings

• DS 3 (Environmental Emergency Response)
• Response time not the best measure it is always
  either immediate or within minutes.
• Better measure is how long the different types of
  responses take.
• During the current year, we have handled many
  responses response time was minimal ranging from
  1 to 25 minutes.

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Process Measures Specific Findings

• DS 3 (Environmental Emergency Response)

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Process Measures Specific Findings

• DS 4 (NEPA Reviews)
• Cycle time analysis not the best measure.
• No useful data collected.
• Better measure is monitoring the percentage of
  projects that undergo NEPA review (beginning with
  the checklist), because more projects should be
  reviewed than are currently.

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Process Measures Specific Findings

• DS 5 (Silver Recovery Consultation)
• Successful Pollution control education
• Several hundred laboratory areas were surveyed
  for silver recovery units.
• Approximately 80 educational visits were
  completed with personnel responsible for these
  units.
• 11 darkrooms did not have silver recovery units
  attached to photoprocessing equipment.
• All 11 acquired and attached silver recovery
  units following visits.

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Process Measures Specific Findings

• DS 5 (Silver Recovery Consultation)

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Learning and Growth Perspective
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Conclusions from Turnover, Sick Leave, Awards,
EEO/ER/ADR Data

• Unclear what was taken into account in compiling
  this data.
• Compilation of data is not representative of the
  actual numbers of staff in Pollution Control
  Section and Environmental Compliance Team.
• Several questions were raised in regard to our
  Service Groups data
• Are data collected solely by HNAM numbers?
• How were Commissioned officers of the Public
  Health Service dealt with in regard to awards,
  etc.?

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Analysis of Readiness Conclusions Current
Required Skills and Abilities

• Managing NIHs environmental compliance and
  pollution control activities requires a broad
  range of knowledge, skills, and abilities,
  including
• Scientific/technical expertise in chemistry,
  biology, biochemistry, chemical engineering,
  construction engineering, civil engineering,
  toxicology, physics, laboratory science.
• Accurate and up-to-date information about
  environmental laws and regulations.
• Knowledge and capabilities in risk management,
  environmental management, storm water management
• Communication skills, including research,
  technical writing, and public speaking.

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Analysis of Readiness ConclusionsProjected
Required Skills and Abilities

• EPB has these skills in the breadth and depth
  required to effectively meet todays workload
• Trends and events that will affect our ability to
  continue to support our mission include
• NIH Master Plan requirements over the next few
  years, which reflect significant growth for NIH
• Increasingly stringent regulations from federal,
  state, and county environmental agencies
• Decommissioning emerging as a critical issue
  in view of the extensive NIH construction and
  renovation activities
• These trends will not likely change the required
  skills and abilities described earlier

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Analysis of Readiness ConclusionsMeeting Our
Mission Requirements Through Hiring, Contracting,
and Training

• Environmental compliance and pollution control
  activities are managed for a wide range of NIH
  locations, not just the Bethesda campus
• Baltimore
• Fishers Lane
• Navy Medical Center buildings
• Poolesville
• Rocky Mountain Labs
• Puerto Rico
• NIHs Master Plan calls for extensive growth in
  FY04 requiring current skills and abilities.

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Analysis of Readiness Conclusions Meeting Our
Mission Requirements Through Hiring, Contracting,
and Training

• Will need at least two to three FTEs (full-time
  equivalents) in order to keep up with the
  projected growth at NIH and the increasing
  regulatory requirements and constraints.
• The focus of the growing workload will likely
  fluctuate even as it rises we will use
  contractors to deal with both fluctuations and
  shortfalls as well as with staff hiring.

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Analysis of Readiness Conclusions Projected
Tools and Material Requirements

• EPB needs a sound and dependable environmental
  management system to monitor and track compliance
  and control activities.
• We are engaged in researching such systems.
• 3-month demonstration project will begin later
  this month.
• Beyond this system, we need to keep current on
  the advancements in environmental science and
  technology

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Financial Perspective
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Unit Cost Measures

• Cost of NIH environmental compliance Priceless!
• Because of the number of variables involved in
  any environmental action it is not meaningful to
  try and break out unit costs.

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Conclusions and Recommendations
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Conclusions from FY02 ASA

• The environmental compliance and pollution
  control Service Group at NIH will always have
  opportunities for improving the effectiveness and
  efficiency of its activities.
• Most of these opportunities can only be
  accomplished through our working in close
  cooperation and coordination with other
  organizational units in NIH.
• A close look at emerging trends that will affect
  us in the future shows increased activity in the
  area of decommissioning.
• NIH guidelines will be issued to comply with ever
  stricter Federal and state regulations.

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Recommendations

• Delete environmental emergency response as a
  Discrete Service
• Coordinate with OBSF and make decision by
  December 2002
• Add Manage Decommissioning Activities as a new
  Discrete Service
• Coordinate with OBSF and make decision by
  December 2002
• Implement an Environmental Management System by
  end of FY03
• Pilot/demonstration project will be up and
  running this year
• Results of pilot will determine acquisition
  schedule
• Retain management of NEPA activities within EPB
  to continue the most efficient use of all NIH
  technical and scientific expertise.