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


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

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

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

SRS History (cont.)
  • Construction began February 1951
  • Five reactors two separations areas a heavy
    water plant a fuel fabrication plant and
    administrative facilities
  • lt10 land used for production
  • All operations cloaked in secrecy

Cold War Missions and Programs
Primary mission of SRS was to produce plutonium
and tritium for nuclear weapons
Production Process
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
  • 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, Bachmans sparrow,
    American alligator, shortnose sturgeon, bog spice

Regulated Activities
  • _at_ 675 environmental permits in effect
  • 3 public drinking water systems
  • 13,000 people
  • 34 NPDES outfalls - 5,700 parametersannually
  • 150 stormwater outfalls - 1,200 parameters
  • 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
  • _at_ 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
  • Assumptions
  • Process General Description and Timeline
  • Integration with Department of Energy Safety
    Management Program -- We bring ISO 14001 into
  • Teaming
  • Results
  • Lessons Learned
  • Identify Risks
  • Questions

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
  • 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
  • Implementation Team - Management commitment of
  • Key Decision - Third party certification or
    self-declare conformance?
  • Registrar selection (1998)
  • Completed self-declaration and independent audit
  • Key Decision - Identify cost benefits for
    independent certification

OSHA Process Safety Mgmt (PSM)
EPA Risk Mgmt Plan (RMP)
Environmental Management System (ISO 14001)
Enhanced Work Planning (EWP)
Chemical Manufacturers Association (CMA)
Responsible Care ?
Voluntary Protection Program (VPP)
Individual Safe Behaviors
What is the DOE Integrated Safety Management
System (ISMS)?
  • A management system that integrates Safety to
  • the public
  • all employees
  • the environment, including
  • waste minimization
  • pollution prevention
  • at the worker, organization, and corporate

Communication of ESH Programs into Work at SRS
Get Work Done Safely Perform Work
Integrated Procedure Management
System Develop/Implement Controls
Procedures Personnel Plant
Contractor Requirements Define Scope of Work
WSRC Programs Each Program Addressed by One (or
More) Site Level Manuals e.g. 3Q
Environmental Compliance, 1S Waste
Acceptance Criteria, 1Q Quality Assurance
ESH Programs Covering 20 Functional Areas Site
S/RID e.g.. Environmental Protection
Conduct of Operations
Conduct of Training
Conduct of Maintenance Engineering
Feedback Improvement
Communications within EPD - Regulatory Compliance
Environmental Laws and Regulations, Permits,
Consent Orders DOE Orders
EPD and Matrixed Environmental Groups
Develop Site Policy (EMC) Programs and Procedures
EPD SMEs Review, Comment, Negotiate, Influence,
Interpret Requirements, Provide Guidance, Assess
Program Effectiveness
EPD SMEs Provide Field Support, Training, Advise,
Write Reports, Assist in Evaluating
Upsets, Assessments, Develop Improvements,
Lessons Learned
EMC and Facility Management Develop
Execution Strategy
Environmental Communications outside EPD - ECA
Operational Support
Facility Management Include Specific Environmental
Requirements in All Their Operations
EPD and Matrixed Environmental Groups
Develop Site Policy (EMC) Programs and Procedures
Field Environmental Compliance Authorities Work
with Operating Personnel to Include Program
Requirements in Facility Procedures
Field Environmental Compliance Authorities Assist
Operating Personnel with Implementation, Assess
Implementation, Provide Input for Site Reports
EMC and Facility Management Develop
Execution Strategy
Teaming Synergy
  • Planning and preparation for normal or recurrent
  • Participate in strategic planning and activity
  • Project Teams
  • Permit Application Development
  • Enhanced Work Planning
  • Technical Support and Assessment of Program
  • 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

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
  • Different Laws/Requirements depending on
  • Appropriate Response actions

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
  • Help integrate Environmental Management System
    requirements into the operating culture
  • 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
  • Help develop clearly defined work instructions
    through interactions with operations and
    maintenance personnel

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
  • Dont assume

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

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

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

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 dont downplay
  • Involvement
  • Actively use environmental professionals in other
  • 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
  • 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

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