# Presentation: 456363

## EMS Fenceline

- Factors that will define the scope of each NAA location’s EMS
- Physical size of your location
- Research mission of your facility
- Self-supporting location versus tenant of a larger facility having its own EMS
- State and municipal agencies that have environmental regulatory oversight over your location

**Notes:**
Entire organization, or specific operating units or activities  (14001 Annex A)
EPA Region 8 is tackling their internal functions for their EMS pilot.  Will incorporate their programmatic functions later.
Fort Riley is building EMS around DECAM functions – Directorate of Environmental Compliance and Management.

## Step 1  

**Look at the Comprehensive Picture of Your Facility**
- Research Activities
- Facility Operations Activities
- Construction and Demolition Activities
**Within Your “Fenceline”, Identify and List Activities**
- Crop research
- Animal research
- Use hazardous chemicals
- Generate hazardous waste

## Characterizing Your Activities, Products, and Services

- Interviews with research and field staff (what are they doing, are they using hazardous materials, etc.)
- What are your location’s hazardous material purchases (review inventories)
- Hazardous waste records
- Records from emergency planning, accident reports, emergency incidents
- Water and energy consumption records

## STEP 2

- Determine if there are ***environmental aspects*** associated with each activity on your list
- An ***environmental aspect*** is the part of an activity, product, or service that interacts with the environment.  An aspect can be thought of as the actual or potential “cause” of an environmental impact.
- Aspects can be regulated or unregulated.

**Notes:**
Aspects include those for which there is a regulatory threshold.
Amounts released below the threshold should also be considered aspects, not just amounts which exceed a threshold.
Example:  even if you are a conditionally exempt hazardous waste generator, the hazardous waste you do generate is an aspect(s).

There may be no specific regulations covering a particular aspect.
	Non-hazardous solid waste
	Carbon dioxide releases
	Water and energy consumption

## Example 1 

**Activity, Product, or Service**
- Purchasing Hazardous Chemicals

**Environmental Aspects**
- Depletion of natural resources in the following ways:
- 	(a) Energy utilized in chemical manufacturing; and
- 	(b) Energy requirements for chemical storage (e.g., 	use of electricity for low-temperature 	refrigeration or ventilation
- Generation of hazardous waste by the following activities:
- 	(a) Duplicate purchasing of hazardous chemicals 	already on location inventory;
- 	(b) Large-scale purchasing of unusable quantities of 	chemical; and,
- 	(c) Chemical is not used, resulting in chemical 	entering hazardous waste stream due to 	expired use date.

## Example 2 

**Activity, Product, or Service**
- Facility Maintenance

**Environmental Aspects**
- Hazardous waste generation (spent fluorescent lamps, PCB containing lamp ballasts, spent solvents, paints)
- Generation of asbestos-containing waste
- Generation of universal waste (used oils, mercury-containing equipment)
- Ozone depletion (repair of older refrigeration equipment containing ozone depleting refrigerants)
- Generation of solid waste (excess furniture and equipment)
- Release of volatiles

## Example 3 

**Activity, Product, or Service**
- Vehicle maintenance

**Environmental Aspect**
- Hazardous waste generation
- Gasoline consumption
- Noise generation
- Electricity consumption
- Solid waste generation
- Water consumption
- Waste water generation
- Release of volatiles

## Example 4

**Activity, Product, or Service**
- Office work

**Environmental Aspect**
- Electricity consumption
- Water consumption
- Waste water generation
- Release of ozone depleting substances in air cooling units
- Solid waste generation
- Disposal of toxics from  computer toner, etc.

## Building an Aspects Register

- Assemble list of activities,    products, and services
- Characterize activities, products, and services
- List aspects
- Organize and rank aspects as appropriate

## Step 3

- A ***significant environmental aspect ***is an environmental aspect that has or can have a significant environmental impact.
- Significance could be tied to:
- Environmental concerns
- Natural resource concerns
- Regulatory or legal exposure
- Business or mission concerns
- Concerns of interested parties

##  Factors That May Play a Rolein Managing Aspects

- Size, severity and duration of environmental impact
- Ease of improvement
- Regulatory or Executive Order requirement
- Cost
- Mission impact
- Community impact
- Sustainability

## Determining Significant Aspects

- Potential factors
- severity
- probability/frequency
- risk (environmental/
- 	health/financial)
- Mission impact

- external concerns
- ability to control/
- 	improve
- duration
- regulatory concern

- Use reproducible methodology; e.g., rank using a formula containing factors the organization considers important

## Ranking Aspects to Determine Those That Should Be Managed Under My Location’s EMS

_**Severity**_
- 5   Catastrophic
- 4   High
- 3   Moderate
- 2   Low
- 1   Slight
- 0   Positive Impact

_**Regulatory Importance**_
- 5	     Current violation
- 4	     Non-compliance, past 3 yrs
- 3	     Non-compliance, past 5 yrs
- 2     In compliance
- 1     Below regulatory cut-off
- 0     Unregulated