# Presentation: 442664

## BNL Environmental Management System Project 

- S. L. K. Briggs
**Presentation to management reps on EMS, 10/18/01**

## Meeting Agenda

**Purpose: Exchange information on BNL Environmental Issues**
- Registration Audit
- FY02 Critical Outcomes & Environmental Priorities
- FY02 Environmental Assessment Plans
- Recent Assessment Results
- SBMS Updates
- Other Issues & Announcements
- Next Meetings

## Sitewide ISO 14001 Registration Certificate Issued

- Final approval of certification granted by NSF Review Board on 7/10/01
- Congratulatory letters received from NSF, Senator LaValle, others

***BNL achieved its goal to obtain ISO Registration before 9/30/01 and achieved “Outstanding” rating on last EMS contract performance measure***

## Site-wide ISO 14001 Registration Audit:Next Steps

- Celebrate and recognize efforts of EMS Teams
- 11/8/01, Brookhaven South, 4:00pm
- Environmental Awards
- Implement Corrective Action Plans as assigned
- ATS #549
- Continue efforts to maintain, streamline, reap benefits, and continually improve the BNL EMS Program
- Lab-level FY02 Objectives/Targets for EMS Improvements
- See FY 02 Environmental Priorities
- Also, Quality related processes [NCR & CA/PA]
- Dept-level FY02 Objectives/Targets for EMS Improvements
- to be identified, based on Environmental Priorities & dept needs

## FY02 Environmental Priorities

**Six Major Areas**
- EMS
- Compliance
- Pollution Prevention
- Communication
- Groundwater Protection
- Natural and Cultural Resources

## EMS

**Maintain ISO 14001 registration and seek opportunities to improve and integrate the EMS*******
**Department Role**: Implement EMS program requirements, maintain strong management involvement and emphasis on continual improvement, and streamlining of Department/ Division EMS program elements.
**ESD Role**: Provide value-added technical services &
- support Department efforts.
** This is a “Supporting Assessment & Indicator” in the BSA/DOE Contract*

## Compliance

**Achieve full compliance with applicable environmental requirements**
- _Seven Recommended Areas for Goals_
- Consistently Meet All SPDES Permit Limits.
- Implement Corrective Actions to Achieve Article 12 Conformance.
- Improve Resource Conservation and Recovery Act (RCRA) and Radiological Waste Compliance.*
** This is a “Supporting Assessment & Indicator” in the BSA/DOE Contract*

## Compliance (continued)

- Meet Federal and State Air Program Requirements including Phase out of Ozone Depleting Substances (ODS).
- Schedule and Conduct Regulatory Compliance Assessments.*
- Complete remaining FRDP Operational Issues.
- Maintain Process Assessments and Close Assessment, Prevention, and Control (APC) Measures.
** This is a “Supporting Assessment & Indicator” in the BSA/DOE Contract*

## Pollution Prevention

- Reduce Routine Waste Streams.
- Reduce or Prevent Spills.* *
- Evaluate and Implement Pollution Prevention Measures*.
- Each listed Directorate shall submit at least two pollution prevention project proposals to the P2 Council and/or two success stories and/or lessons learned.
**This is an objective in the Critical Outcomes.*

## Communications

**Improve communications, trust, and relationship with stakeholders on environmental programs**** **
- Invite Environmental professionals to Department meetings to discuss environmental issues.** **

## Groundwater Protection

**Fully implement groundwater protection program**** **
**Maintain an inventory of potential groundwater contamination sources.**** **
**Implement and maintain operational and engineered controls to prevent groundwater contamination.**** **
**Include and implement groundwater protection provision in Facility Use Agreements.**** **
**Contribute resources to facility specific groundwater monitoring.**** **
**Implement Groundwater Contingency Plan Subject Area requirements for unexpected monitoring results.**

## Natural and Cultural Resources

**Ensure responsible stewardship of natural and historical resources onsite**** **
**Can impact natural and cultural resources. **
**Involved with the RHIC revegetation project. **

## Conclusion

- Adopt environmental goals and measures that are appropriate for your organizations.
- Request technical assistance from ESD and WMD.
- Continue to look for ways to streamline your EMS program.
- This should help put you on the right track with your EMS goals.

## EMS Program Tasks FY 2002

**Objectives & Targets**
- Update Objectives with 2002 Critical Outcomes & Environmental Priorities.
- Minimum objectives: pollution prevention & regulatory compliance; Consider community outreach & cleanup (legacy issues)
- Establish process-specific targets for your Dept/Div
- Present to management/staff and obtain concurrence, NOW.
- How will you demonstrate concurrence? through meeting notes, incorporation/reference within other formal organization documents or approval signature.
*Deliverable: Objective & Targets (on EMP forms)*
**Lessons Learned:**
- Be able to distinguish EMS-related objectives from other Dept objectives.

## EMS Program Tasks FY 2002

**EM Program Plans**
- Identify Action Plans to achieve Objectives.
-  (EMP “tasks”)  (targets) = Objectives
- Prioritize initiatives, seek management concurrence, allocate & assign resources for action plans.
- Communicate Action Plan to affected persons and ESD Manager.
- Suggest using ATS systems to track progress.
- Incorporate/link/reference other Dept/Div E improvement plans (ie., internal, ADS’).
- Make progress on actions
*Deliverable:  EMP Forms (or dept-specific action plan documents, aka Self Assessment Plan*)
**Lessons Learned:  *****Ensure that the EMP forms...***
- ...title reflects “aspect” or “activity” (whichever way you did it).
- ...program description describes P2 or compliance effort (not the activity/operation).
- ...include all actions needed to correct non-compliance issues

## FY02 Environmental Assessment Plans

- ESD Assessment Schedule
- [FY01: Liquid Effluents, NEPA]
- FY02: PCB, Air (CAA & NESHAPS)
-  BAO will be observing
- FY03: Storage/Transfer Haz Matls; Spill Response
- FY04: Drinking Water; TBD
- BHG Environmental Assessment Schedule
- FY02: Rad Waste Mgmt (Q1)
- FY02 BAO Observes BNL Audits: Design Review (Q1), Rad Inst & Calib (Q2), Exhaust Ventilation (Q4)

## FY02 Environmental Assessment Plans

- FY 02 Topics:
- Integrated Assessment Program
- Training & Qualifications
- Records
- Quality Management
- Human Resources

- May be asked to be a team member representing Depts
- Conducted in 1⁄2 day workshop setting
- Score maturity of management system in 3 areas:
- Approach/definition
- Deployment/Implementation
- Assessment, Improvement, Results

**Quality Assurance Program: Management System Evaluations **

## External Audits

- Anticipated FY02 Audits:
- NYS DEC RCRA
- CAA – Title V
- ISO 14001 Surveillance – spring
- NYS DEC Chemical Bulk Storage
- Major Petroleum Facility
- Sewage Treatment Plant
- Recent Audit Results:
- Cross Connection Control – Bob Lee
- Air – Jeff Williams

## Summary:Environmental Audit Requirements

- EMS Audit: frequency based on risk/importance of work activities, and past performance results
- _Guidance:_
- If work has high potential to impact, conduct audit annually; if not conduct biannually
- If previous audits identified nonconformances, conduct audit annually; if not conduct biannually
- Management Review: Annually
- Compliance Audits: covering all _applicable_ regulatory requirements on a 3 year cycle
- Use Tier 1 process, ESR/PEP, and topical assessments
- Take credit for ESD audits

## EMS Program Tasks FY 2002

**EMS Audits**
- Schedule FY 2002 environmental audits in Dept Self Assessment Plan
- Environmental Assessment Training for new team members?
- Perform the audits as scheduled & implement corrective actions
*Deliverable: Self Assessment Plan (due 12/31/01), Audit reports (cc: ESD manager) *
**Lessons Learned:**
- Establish audit schedules based on importance of activity and past performance results.
- Ensure audit checklist is either completed or enter N/A into individual boxes
- Document qualifications of audit team in audit report (*new emphasis amongst registrars*)

## Title V Permit Coming Your Way

**What is the Title V Permit?**
- 	- A single permit for all regulated emission sources
- 	- It identifies all applicable federal & state regulatory requirements
- 	- Contains terms and conditions to assure compliance w/requirements
**Why does BNL need a Title V Permit? **
- 	- BNL is considered a major source of air pollutants
- 	- The CSF has potential emissions of NOx more that 25 tons, SO2 and
- 	   TSP more than 100 tons
**Where is BNL in the Permit Process?**
- 	- Draft permit was released for public comment on 8/13/01
- 	- BNL submitted comments on 9/20/01
-      - NYSDEC expected to deliver final draft to EPA on or about 10/22
-      - EPA has 45 days to review & comment
- 	- After EPA comments are addressed permit issued for 5 years

## What’s in the Draft Title V Permit?

- 15 Emission Units covering more than 100 emission sources
- 23 Facility Level Conditions, Emission Unit Conditions &
-      State Only Enforceable Conditions
- A Condition for Semi-Annual Monitoring Reports
- A Requirement for an Annual Emission Statement
- A Requirement for an Annual Compliance Certification

**Notes:**
A. Units include emission sources subject to same or similar requirements.   CSF (3 Units), Lithographic Printing Operation, Paint Shop, Metal Parts Batch Cleaning.
Report shall include statements that all reporting or monitoring was done as required where an EU has a reporting Requirement Condition (upon request by Regulatory Agency) or a listing of any deviations from these requirements.)  for any reporting requirements listed in permit Reports will include   

## Title V Permit Compliance Assurance

- Determined through Regulatory Compliance Assessments per Environment Assessments SA
- Through Periodic Monitoring Reports
- Tools Available for Compliance Assurance
-      - FUA Link to Air Emission Sources
-      - Title V Regulatory Requirements & CA Database
-      - ECRs & SME

## Your Role in the Title V Permit

- Knowledge of Processes & Sources Included in the Title V Permit
- Work with ES&H Reps and ECRS to Keep Information on Emission Sources Current
- Be Familiar with Permit Conditions and Requirements
- Participate in CAA Regulatory Compliance Assessment

## EMS Subject Area Revisions

- Training - Revised
- Section 7, Instructor Qualification and Section 8, Record keeping was added to the subject area. The Course Evaluation Form, Instructor Evaluation Form, Instructor Qualification Form, and the Training Attendance Roster also were added.
- Department specific Training Plans no longer required
- Working with Chemicals - New
- Encompasses all components of the BNL Chemical Safety Program, ranging from initial work planning process to disposal.
- Details to be covered at TODAY’s  ESH Coordinators meeting

## Other Issues & Announcements

- Bush Administration supports EMS programs
- EPA emphasizes EMS
- ESD Moved to Bldg 120
- Consolidate Waste Management GIG and EMS Rep Meetings
- Complete FY01 Management Reviews by 12/31/01
- Brief management  ahead of time!
- Quantify performance data where possible (waste volumes/types)
- Be sure to address recommendations from previous mgmt review
- Cover compliance- data, results of external audits, status of improvements
- Quantify costs & benefits/value – cost savings/costs avoidance (use ECR expertise on ROI)

## Next Meetings

- Next EMS Meeting  12/13/01
- Time: 1:30 pm - 3:00 pm
- Location - 535 Conference Room
*NOTE: EMS Project Team Meetings held on 2nd Thursday of *_*EVERY OTHER*_* month*
*CHANGED to bi-monthly meetings*