# Presentation: 321920

## Implementing an EMS that Integrates P2/Sustainability Concepts

**2005 **
**Pollution Prevention **
**Workshop**
**May 2005**

- Jan Jackson, BWXT Y-12

## ISO 14001 provides the framework

- Initiated planning process in 2002 to implement an EMS based on the ISO 14001 standard
- Focus on continual improvement
- A complex-wide EMS that maximizes integration of P2 and sustainability principles.
- Integrating pollution prevention into EMS
- Policy,
- Planning,
- Implementation and Operations, and
- Checking and Corrective Action processes.

## P2 in Company Policy 

- Integrated ES&H Policy is the foundation
**P**rotect the Environment,
**P**revent Pollution,
**C**omply with requirements, and
**C**ontinually improve environmental management.
- Acronym ‘P2C2’ is used in EMS awareness programs, training, and flyers
- Pollution Prevention and Sustainability Policy affirms commitment to P2.
- Continually integrate sustainability principles in a safe, compliant, and cost-effective manner.
- Support continual improvement in environmental management.
- Re-enforces commitment to resource conservation, energy management, affirmative procurement, and pollution prevention
- Incorporated into General Employee Training for all employees, as well as EMS Implementation training, and training for EMS assessors.

## Brochure to Promote Awareness

## P2 in Planning and Implementation 

- Cross-functional / multi-organizational team approach to conduct the four environmental planning steps required by ISO 14001, and oversee ongoing EMS implementation
- Involves:
- Identifying environmental aspects and impacts of activities, products and services,
- Identifying legal and other requirements,
- Developing environmental objectives and targets, and
- Establishing action plans to achieve objectives and targets.
- Steps were conducted by EMS implementation teams
- complex-wide level, and
-  within individual facilities and organizations.
- Teams worked to
- identify environmental aspects and impacts,
- set quantitative objectives and targets and
- develop environmental programs or ‘action plans’ to achieve the objectives and targets.

## P2 in Planning and Implementation

- Aspect and impact identification procedure integrates pollution prevention and sustainability concepts
- Includes Identification of positive environmental aspects and impacts such as
- source reduction,
- recycling,
- use of renewable resources and bio‐based products,
- affirmative procurement, and
- energy conservation.
- Positive score to P2 and sustainability aspects of activities that conserve natural resources and prevent pollution.
- Negative score to the classic media-specific negative environmental aspects such as air emissions, liquid discharges and wastes.

## Positive Scoring

- Level of Positive impact due to P2 activities was captured by assigning  Environmental Severity scores
- Positive High / Medium / Low (Ph, Pm, Pl)
- Score was based on:
- Relative quantity of natural resource recycled / reduced / substituted / conserved
- Reductions in use / emissions / wasting of Hazardous, toxic and non-renewable materials were given higher scores than renewable / non-toxic materials.

## Environmental Severity Rating Criteria 

| Conservation of Natural Resources |  |  |
| --- | --- | --- |
| Pl | Low Positive | Aspect and related impacts are a benefit – Improve the environment and support conservation efforts. Impacts include:
Small levels of energy and/or non-hazardous/renewable natural resource conservation, OR 
Small quantity of non-hazardous/renewable materials recycled/reduced/reused or safe-substituted, (unless materials recycled/reduced/reused/ substituted are hazardous or nonrenewable, in which case this should be rated MEDIUM POSITIVE or higher),  OR 
No or negligible hazardous, toxic, or nonrenewable materials recycled/reduced/reused or safe-substituted, 
No or negligible reduction in toxic, hazardous, or nonrenewable pollutant sources or chemical use. |
| Pm | Medium
Positive | Aspect and related impacts are a benefit – Improve the environment and support conservation efforts. Impacts include:
Medium levels of energy and/or non-hazardous/renewable natural resource conservation, OR 
Medium quantity of non-hazardous/renewable materials recycled/reduced/reused or safe-substituted, 
Small quantity of hazardous/toxic, or nonrenewable materials recycled/reduced/reused or safe-substituted, 
Small reduction in toxic, hazardous, or nonrenewable pollutant sources, and/or chemical use (but does not ELIMINATE use of the toxic/hazardous substance). |
| Ph | High Positive | Aspect and related impacts are a benefit – Improve the environment and support conservation efforts. Impacts include:
High levels of energy and/or non-hazardous/renewable natural resource conservation, OR 
High quantity non-hazardous/renewable materials recycled/reduced/reused or safe-substituted, 
Medium quantity of hazardous/toxic, or nonrenewable materials recycled/reduced/reused or safe-substituted,
Medium reduction in toxic, hazardous, or nonrenewable pollutant sources, and/or chemical use (but may not ELIMINATE use of the toxic/hazardous substance). |
| Pv | Very High
Positive  | Aspect and related impacts are a benefit – Improve the environment and support conservation efforts. Impacts include:
VERY High levels of energy and/or non-hazardous/renewable natural resource conservation, OR 
VERY High quantity non-hazardous/renewable materials recycled/reduced/reused or safe-substituted, 
HIGH quantity of hazardous/toxic, or nonrenewable materials recycled/reduced/reused or safe-substituted,
HIGH reduction (i.e., complete ELIMINATION) of toxic/hazardous, or nonrenewable pollutant sources and/or chemical use.  
. |

## Scoring Matrix for Natural Resource Conservation and Consumption

| *Severity of  Impact(s) or Regulatory Performance (Tables 6 – 15) | Likelihood of Aspect Occurring (Table 5) |  |  |
| --- | --- | --- | --- |
|  | High (H) | Medium (M) | Low (L) |
| (Pv) Very High Positive | 100,000 | 10,000 | 1,000 |
| (Ph) High Positive | 10,000 | 1,000 | 500 |
| (Pm) Medium Positive | 1,000 | 500 | 50 |
| (Pl) Low Positive | 500 | 50 | 5 |
| (Ln) Low Negative | -500 | -50 | -5 |
| (Mn) Medium Negative | -5,000 | -500 | -50 |
| (Hn) High Negative | -50,000 | -5,000 | -500 |

## Scoring Matrix for ‘Negative’ Environmental Impacts

| *Severity of  Impact(s) or Regulatory Performance (Tables 6 – 15) | Likelihood of Occurrence (Table 5) |  |  |
| --- | --- | --- | --- |
|  | High (H) | Medium (M) | Low (L) |
| (V) Very High | -1 x 106 | -1 x 105 | -10,000 |
| (H) High | -1 x 105 | -10,000 | -1,000 |
| (M) Medium | -10,000 | -1,000 | -100 |
| (L) Low | -1,000 | -100 | -10 |
| (N) Neutral | -100 | -10 | 0 |
| (Z) Zero, N/A | 0 | 0 | 0 |
| (P) Positive | 5,000 | 1,000 | 100 |

## Example for Steam Plant

| Operation | Inputs / Outputs | Aspect Category* | Aspect Description(Key Contaminants / Emissions / Wastes / Materials Consumed) | SRID / Legal  | Likelihood | Reg. Severity  | Env. Severity  | Total Score | Sig. (Y)es / No | RatingNotes & Rationale              |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |

| Steam Boilers | Coal, Fuels | NRM | Nonrenewable resource consumption (coal, natural gas, and diesel fuel) | Y | H | L | H | -51,000 | Y | High qty nonR, TRI reportable |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Steam Boilers | Bottom Ash, Fly Ash | NRV | Resource conservation by beneficial reuse of ash for landfill fill material | Yi | H | Z | P | 10,000 | Y | High qty nonhaz reuse, EO 13101 |
| Steam Boilers | Return Condensate | NRV | Water conservation by use of return condensate for steam generation | Yi | H | Z | P | 10,000 | Y | High qty water consv, EO 13123 |
| Demineralizer | Water | NRV | Water conservation by using resin beds enhanced to reduce water use (by 40%) | Yi | H | Z | P | 10,000 | Y | EO for water conservation |

## Results 

- Heightened awareness on P2 and affirmative procurement issues.
- An incentive to conserve natural resources, conduct P2 projects and minimize negative environmental aspects and impacts of operations.
- Over 600 environmental aspects and impacts were identified for Y-12 activities conducted at 15 facilities and organizations.

## Objectives/Targets and Action Plans

- Promote continual improvement based on the significant environmental aspects and impacts.
- Include P2 Programmatic goals (i.e., an 80 percent reduction in mixed low level waste based on a 1993 baseline).
- Developed ‘action plans’.
- These EMS efforts resulted in the exemplary Pollution Prevention projects.

## Successes Due to Measurable P2 Goals

- 72 pollution prevention projects supported the EMS Objectives and Targets in FY 2004
- Resulted in a reduction of almost 21 million kilograms of waste and a total cost savings/avoidance of over $6.4 million dollars.

## 5 New Recycling Initiatives

- Resulted in a reduction of ~6 million kilograms of waste and saved ~$825,000 in waste disposal cost avoidance.
- New waste streams recycled in FY 2004 included:
- Wood pallets and wood waste,
- nickel hydride batteries,
- PCB and non-PCB ballasts,
- PCB oil from demolition activities and routine operations, and
- asphalt from demolition activities that was recycled on-site for new road construction.

## Implemented the Y-12 PrYde Program

- Y-12 PrYde program - *“A place for everything and everything in its place”.  *

## Implemented the Y-12 PrYde Program

- Encompasses efforts associated with
- Good Housekeeping inspection and rating system,
- Clean Sweep Program site-clean-up efforts,
- Material Management Excessing processes to facilitate reuse of excess materials rather than disposal or purchase of virgin product, and
- Pollution Prevention program to facilitate recycle of removed materials and identify ways to prevent the problems before they occur.

## Successes

- resulted in reuse of 270 items within Y-12
- saved almost $34,000 based on the value of the items reused.
- 140 items valued at over $289,000 were transferred to DOE, other DOE contractors, and other government agencies.
- Waste disposal avoidance and the related cost avoidance were not estimated for these reused materials.

- Material Management Excessing utilized a ‘Swap List’ database system to post surplus materials available to potential users.

## Successes

- The Clean Sweep Program completed clean-up activities to remove 60 drums of oil,
- 5 loads of special industrial waste, and
- several tons of scrap metal and other recycled materials including over 1,803,000 kg of ‘suspect clean’ scrap metal
- established an ordering agreement with a Nuclear Regulatory Commission licensed company that enabled Y-12 to recycle the scrap metal (that had never been in a radiological control area) with only minimal costs for radiological  surveys.
- avoided almost $90,000 in disposal costs and an undetermined amount of radiological survey costs.

## Continued Improvement Beyond FY 2004

- Projects/activities begun in 2004 that will continue to benefit the environment include:
- Use of environmentally friendly pesticide substitute.
- Provision of janitorial staff with environmentally safe cleaning products added to the Y-12 procurement system

## Continued Improvement Beyond FY 2004

- Provision of janitorial staff with environmentally safe cleaning products added to the Y-12 procurement system
- are manufactured from soybean and corn esters and are totally environmentally safe, biodegradable and non-toxic.
- include cleaners for floors, showers, stainless steel, glass and other surfaces.
- Use of bio-based oil absorbent in place of clay (a non-renewable resource).
- made of cotton linters, a recycled material that is also a renewable resource.
- supports the Affirmative Procurement EMS Objectives and Target.

## P2 integrated into EMS Assessments

- A cross-functional team was trained to become the Y-12 EMS Assessment team,
- Focus on identifying areas of non‐conformance with ISO 14001 and providing recommendations that rely on P2 and sustainability principles to promote continual improvement
- EMS assessment checklists and questionnaires work to ensure:
- Employees are aware of: the P2 policy, the P2 objectives and targets that relate to their work (including affirmative procurement), and their EMS responsibilities;
- Controls and procedures are being used to minimize or eliminate wastes and emissions where possible;
- Monitoring processes are established to effectively track environmental performance and P2 objectives and targets; and
- Personnel are adequately trained on these procedures including P2, Affirmative Procurement and Recycling.

## P2 in EMS Assessments

- The Y-12 EMS Assessment program is an ongoing process with assessments scheduled for several facilities and organizations in the coming months.
- Two assessments completed (November 2004 and February 2005).
- Lead to recommendations for
- improvements in methods to track P2 progress,
- development of procedures to ensure consistent recycling at off-site Y-12 facilities, and
- reduce unnecessary purchases of virgin chemicals and disposal of useful surplus chemicals as waste.
- Identified new “positive aspects”.
- Energy efficient lighting
- Opportunity for glass and plastic recycle

## Conclusion

- Y-12 did not simply integrate pollution prevention (P2) into its EMS but placed P2 at the EMS’s core.
- This P2-driven implementation fully integrates P2/sustainability concepts into environmental planning procedures/operations.
- P2 concepts were incorporated into the core of the Environmental Policy and throughout EMS planning activities.
- Identification of significant environmental aspects/impacts was designed to give credit for positive impacts resulting from P2 activities.
- Measurable EMS objectives/targets were developed that incorporate Y-12’s P2 Program goals.