Transcript EMS / NEPA Integration at the INEEL

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
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
Time Line
1990
1995
2000
2005
Subject Matter Based
Work Activity Based
2000
2005
Environmental Management System Workshop
March 8-9, 2005
INL’s Perspective
• The NEPA Process at the INL is part of the
INL’s Environmental Management System
• The EMS is fully integrated into INL’s
Integrated Safety Management System
• EMS is patterned after ISO 14001
requirements
Status of INL’s 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.
EMS and NEPA
EMS Elements
• Environmental
Aspects
NEPA Values
• Potential Impacts &
Issues
• Work Activities
Significant Work
Activity
• Proposed Activities
• Potentially Significant
Environmental Aspect
• Significance
Determination, (i.e.,
CX, EA (FONSI) or EIS
(ROD)
Significance?
• Under INL’s 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.
Significance Determination
Not Significant
Significant
The activity, or the operation has
little discernible impact on local
ecology, including air, water, soil,
groundwater quality, and
biological receptors.
The activity has short term or
minor impacts to local ecology
or
that are fully recoverable.
The activity has a major, longterm or permanent impact to local
ecology.
Little or no remedial action is
required to address releases to
the environment or other
environmental damage. (A
release to secondary
containment in a building is not
considered to be significant.)
Remedial action is required to
address releases to the
environment or other
or
environmental damage. (A
release to secondary
containment in a building is not
considered to be significant.)
Long-term or major remedial
action is required to address
releases or other environmental
damage. Release to the
environment from these activities
or sources are a major
contributor to regional problems.
Environmental Aspects
INL’s Environmental Checklist
Combines EMS & NEPA Elements
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.
2. Flow down requirements
(through instructions from
MCP-3480) to the worker.
Purpose of EC
3. Identify new work
activities with
environmental
requirements.
4. Identify new
environmental aspects.
5. Identify significant
environmental aspects
of new work activities
and develop controls.
Environmental Checklist / Sec. A
• Provide Descriptive
Information
– Charge Number
– INL / ICP
– Project Title
– Performing Organization
– ...
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
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 . . .
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?
Environmental Checklist / Sec. E
• Conditions: Are conditions
required before starting
project?
– APADs (Air Permitting)
– Cultural Resource
Clearance
– Biological Resource
Clearance
– Other approvals
Environmental Checklist / Sec. F
• Determine the Level of
Environmental Review (or
Documentation)
– Categorical exclusion
– Environmental assessment
– Environmental impact
statement . . .
Work Control System
Activity-Based
Environmental Compliance
System
DOE Integrated Safety
Management System
(ISMS)
New Work Activity
Identification and Change
Control System
(NEPA)
INL’s
Environmental
Management
System
Existing Systems
ISO
(i.e., Documents, Records,
Training, Monitoring, etc.
ISO 14001
Registration
Voluntary
Protection Program
(VPP)
Benefits
1000
983
840
Dollars (000)
900
800
700
600
Environmental
Enforcement Penalties
(Original Assessed Penalty)
500
400
300
316
156
200
100
0
0
1997
1999
2000
2001
2002
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
The End
Contact:
John Irving
[email protected]
208.526.8745
Or
Bruce Angle
[email protected]
208.526.1841