EMS / NEPA Integration at the Idaho National Laboratory
Bruce Angle & John Irving
Battelle Energy AllianceIdaho National Laboratory
Environmental Management System WorkshopMarch 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 20001995
NEPA
Proc
ess
INEEL
Conso
lidat
ion
Req. F
low D
own
ISM
S Im
plem
enta
tion
begi
ns
ISO
-140
01 S
tarte
d
Subject Matter BasedWork Activity Based
2005
ISO
140
01 R
egist
ered
Environmental Management System WorkshopMarch 8-9, 2005
Six
Surv
. Aud
its
2000 2005
New
INL
Contra
ct
ISO
Reg
.
Re-re
gistr
atio
n
Dec
ision
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
• 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)
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
The activity, or the operation has little discernible impact on local ecology, including air, water, soil, groundwater quality, and biological receptors. 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.)
The activity has short term or minor impacts to local ecology that are fully recoverable.
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.)
The activity has a major, long-term or permanent impact to local ecology. 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.
Not Significant Significant
or
or
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
4. Identify new environmental aspects.
5. Identify significant environmental aspects of new work activities and develop controls.
3. Identify new work activities with environmental requirements.
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 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. C
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
DOE Integrated SafetyManagement System
(ISMS)
Activity-BasedEnvironmental Compliance
SystemNew Work Activity
Identification and ChangeControl System
(NEPA)
VoluntaryProtection Program
(VPP)
Existing Systems
(i.e., Documents, Records,Training, Monitoring, etc.
ISO 14001Registration
ISO
INL’sEnvironmentalManagement
System
Benefits
983
840
316
156
00
100
200
300
400
500
600
700
800
900
1000
1997 1999 2000 2001 2002
Do
llar
s (0
00)
EnvironmentalEnforcement Penalties
(Original Assessed Penalty)
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