# Presentation: 104357

## BNL Environmental Management System Project 

**S. L. K. Briggs**
- Presentation to management reps on EMS, 11/9/00

## Meeting Agenda

**Purpose:** Exchange information on BNL EMS Registration process
**Summary of Year 3 EMS Verification Audit **
**Environmental priorities for 2001**
**EMS Program 2001 **
**Other Issues & Announcements**
**Q&A**
**Next Meetings**

## Year 3 EMS Audit: General observations

**Employee awareness of policy not as high as previously seen**
- although employees were aware of important environmental impacts related to their work
**Management systems & reqmts were new and implementation not mature**
- some misunderstanding and rough edges, especially at points where there were handoffs and in areas that benefit from integration.
**High level of management involvement and support for EMS **
**EMS systems and subsystems were developed using a consensus process, resulting in buy-in by affected organizations.**
**Challenge to continue to promote EMS awareness and benefits and maintain visibility at current levels.**
**Visiting scientists were aware of what controls they needed to follow, their responsibilities, training, & who to call for assistance.**

## Year 3 EMS Audit: Minor Nonconformances

**Aspects:**
- A process assessment form incorrectly identified one of its significant aspects
- An aspects worksheet incorrectly identified an activity as a significant aspect
**Environmental Management Programs:**
- An EMP form had not been prepared for “legacy materials”
**EMS Documentation: **
- One organization EMS manual did not describe all 17 core elements nor describe their interaction
**Operational Control: **
- A documented procedure for controlling an operation that has a significant aspect was not developed.
- A form used to identify required environmental reviews did not reflect the need for a NEPA evaluation (yet the NEPA was conducted).
- Laboratory chemicals were found that had not been barcoded and entered into the Chemical Management Tracking System

## Year 3 EMS Audit: Minor Nonconformances

**Monitoring & Measurement:**
- No followup response was provided to notices that equipment was due for calibration (equipment had been removed from service however that information was not provided back to the group maintaining the database)
- One piece of air monitoring equipment was past its calibration due date but still in use.
**Nonconformance/Corrective Action: **
- A finding from a Tier I inspection had not been tracked to closure.
**Document Control: **
- An outdated version of a form was still in use in the field.
**EMS Audit:**
- Complete EMS Audits (covering all 17 elements) were not completed in 3 departments. (note: at the time the EMS Audit was conducted in these departments, select elements had not been developed, therefore could not be assessed)

## Year 3 EMS Audit: Opportunities for Improvement

**Aspects: **
- Experimental Safety reviews do not clearly identify the environmental aspects of the experiment (as compared to the process evaluations that clearly list the environmental aspects of the operations).
- An incorrect entry was noted on the Aspects spreadsheet
**Objectives & Targets: **
- The Environmental objectives are not clearly distinguished from other types of objectives
- EMP forms do not include targets, although the performance indicators can be modified for that purpose.
**Environmental Management Programs:**
- Title on form does not accurately reflect the description (form indicate analysis done “by aspect” as opposed to “by activity”
- One EMP form did not provide a complete description of the activities/processes that it covered.

## Year 3 EMS Audit: Opportunities for Improvement

**Operational Control:**
- The specific applicable SBMS subject areas that apply to an operation are not listed on the operational control form.
**EMS Audit: **
- Checklist does not include a description of the objective evidence reviewed or areas of conformance (only areas of nonconformance)
- One organization did not describe the factors used to determine the audit schedule.
**Observation:**
- EMS Awareness of Policy weak

## Followup Actions

**Develop Corrective Action Plans for Nonconformances and Opportunities for Improvement**
- Create “action reports” for ATS Assessment # 195
- Address immediate corrective action _and_ preventive actions
- Focus on solving “system” problems
- See Nonconformance Subject Area for guidance
- Submit to atsadmin@bnl.gov by 11/20/00
**Evaluate applicability of all NCR/OI to your system, and develop internal improvement plans**
**Follow up on desk audit issues**
**Suggest lab-level corrective actions (email to me)**
**EMS Audits of 3 organizations in progress; completion expected by 11/30/00**
**Report due to EPA/DOE/BNL by 12/30/00; letter of verification expected same time**

## FY 01 “E” Critical Outcome Performance Measures

**Achieve Labwide ISO 14001 registration **
**Meet all SPDES permit limits**
**Implement corrective actions to achieve Article 12 conformance**
**Improve RCRA & Rad Waste Compliance**
**Reduce Haz, Mixed and LLW below FY00 levels**
**Evaluate & implement Pollution Prevention Opportunities**
**Eliminate significant spills**
**Improve communications and trust**
**Implement Groundwater Protection Program**
**Enhance Natural & Cultural Resource Management Program**
**Facility-specific compliance or improvement initiatives**
***http://www.esh.bnl.gov/esd/Internal/Docs/Env_pri_FY01.doc***

## EMS Program Tasks 2001

**Program Maintenance Tasks**
- See Project Gantt Chart
- Progress reporting limited to documentation deliverables
**Cost Accounting**
- Continue to collect resource estimates (level of effort, hours)
- Use online IIMS to capture resources on monthly basis
*We are in a unique position and have a great opportunity to quantify & share this information with others*
**Integrate, Streamline, Quantify Value/Benefits**
- Ideas for paperwork to eliminate
- Suggestions on processes to streamline
- Value & Benefits to Quantify (cost savings, cost avoidance)

## Other Issues & Announcements

**Records Management Subject Area Revision**
- “strawman” records schedule – seeking input for 30 days
**Use/Misuse of Registration mark**
**EMS Performance Indicator Brainstorm Session**
- With J. Cascio & S. Afsah of IRG, Inc
- 11/27/00, 1:00- 4:00, 535 conference room
**Conservation Reserve Ceremony today**
**Radioactive Liquid Discharge policy presented to CAC/BER**
**New ESD Manager appointed as of 12/01/00: Lori Cunniff**
**Clarification on Labwide EMS Audit 1/01: **
- Satisfies registration requirement for Lab-wide EMS Audit
- Focus on Lab-level programs & requirements, not facility implementation
- Will review results of facility self-assessments and external assessments

## Next Meetings

**Next EMS Meeting **_**12/7/00**_** **
- ****** Note: 1st Thurs of Dec*******
- Time: 1:30 pm - 3:00 pm
- Location - 535 Conference Room
*NOTE: EMS Project Team Meetings *_*typically*_* held on 2nd Thursday of each month*
*CHANGED to monthly meetings*
**Quarterly Status meetings: frequency changed to 3x year; next one scheduled for 1/01**
**Topics:**
- EMS Implementation: streamline, integrate, maintain