# Presentation: 411390

## BNL Environmental Management System Project 

- S. L. K. Briggs
**Presentation to management reps on EMS, 5/24/01**

## Meeting Agenda

**Purpose: Exchange information on BNL EMS Implementation process**
- Revisions to EMS Subject Areas
- Environmental Assessments
- Community Involvement Manual for Managers
- Prep for Registration Audit
- Desk Audit Results
- Onsite Readiness Review results
- Followup on Labwide EMS Audit Issues
- EMS Program 2001 Status
- Other Issues & Announcements
- Records Inventory Status and open issues
- PEP Status
- Sitewide Liquid Effluent Audit complete
- Q&A
- Next Meetings

## EMS Subject Area Revisions

- _Approved/Issued:_
- Liquid Effluents
- E-ALARA authorization criteria for radiological liquid effluents
- Administrative Limits 10K pCi, critique step added if > 5K; See revised flowchart
- _Drafting Stage:_
- Storage and Transfer of Hazardous Materials – to include management of outdoor work and storage areas (wrt Stormwater discharges)
- Drinking water - backflow testing requirements for secondary backflow systems

## EMS Subject Area Revisions

- Environmental Assessments in Final Revision:
- to be presented to SBMS Steering Committee 6/3/01
- Need EMS Rep review & approval, via email
- Changes:
- Remove annual audit cycle (although one “E type audit” must be done annually)
- EMS audit frequency based on importance & past performance
- Compliance audits frequency based on 3 year cycle to assess all compliance areas
- Management Review required annually, based on IAP requirement
- Integrate with new IAP, NC CA/PA, and ATS Subject Areas: highlights include
- Incorporate E audit schedule into IAP
- Provide flexibility in use of checklists
- provided new & revised checklists
- can also use standard/regulations

## EMS Subject Area Revisions

- Changes continued:
- Remove requirement for an audit plan (although audit planning is required, use graded approach to determine need for a plan)
- Added requirement for a closing meeting/debrief for E audits
- Utilize existing reviews/inspections to assess compliance (PEP, Tier 1)
- Clarified text:
- Audit can be conducted by one person
- Checklists if used, must be complete
- All 17 ISO requirements must be audited on periodic cycle
- Notifications on noncompliances
- Optional documents to review during compliance audits

## EMS Subject Area Revisions

- Changes continued:
- Documentation clarifications:
- Topics to include
- Provide assessment reports to mgmt for incorporation into self evaluation
- Mgmt Rep maintains copies of audit reports
- Equivalent training acceptable
- Management Review –
- Ensure sr mgmt attendance
- Assessment summary with emphasis on Corrective action to prevent recurrence
- Review Occurrence & spills /performance trends
- Brief sr mgmt
- Review steps 2 & 5
- Definitions of categories of findings (noncompliance, observation, etc)

## Have any inquiries on environmental policy been received? No
Is an objective/target required for each aspect? No, but an objective to maintain compliance (for all regulated aspects) is
Who is Mgmt System Steward in each Dept/Div? –sic
How are views of interested parties considered in CO/O/PM? Created in partnership with DOE with input from CAC, BER, Community Involvement Program
How are underlying objectives/PMs determined? DOE/BNL SME counterparts develop draft; sr mgmt approves
How does IAP identify/prioritize improvement initiatives? Audits, peer reviewsCorrective Actions; Self Evaluation recommendations for improvements & new goals
How will site meet challenge of maintaining EMS? BSA is committed to mgmt system philosophy; embedded in Lab’s operating systems, procedures & R2A2
How will continued funding be ensured? Project funding has been transferred to core program funding.

*Is an objective/target required for each aspect?** No, but an objective to maintain compliance (for all regulated aspects) is*
*Who is Mgmt System Steward in each Dept/Div?** –sic*
*How are views of interested parties considered in CO/O/PM?** Created in partnership with DOE with input from CAC, BER, Community Involvement Program*
*How are underlying objectives/PMs determined?** DOE/BNL SME counterparts develop draft; sr mgmt approves*
*How does IAP identify/prioritize improvement initiatives?** Audits, peer reviews****Corrective Actions; Self Evaluation**** recommendations for improvements & new goals*
*How will site meet challenge of maintaining EMS?** BSA is committed to mgmt system philosophy; embedded in Lab’s operating systems, procedures & R2A2*
*How will continued funding be ensured?** Project funding has been transferred to core program funding.*

**Desk Audit Results**

## How will site handle turnover of key EMS personnel? A challenge as training programs are subcontracted and costly.  Offsite, required reading and/or equivalent training provided to newcomers
Suggestions made to rotate assignment of EMS Rep & team members.  Thoughts?
Ideas for additional/advanced training?  Advanced Implementation techniques, “Leadership by Example”, others?
How have external communication efforts changed since registration? They haven’t; strategic communications program continues the program established in ’98.  New focus is on scientific achievements (for balance), new GW Contingency Plan (notifications of unexpected monitoring results), Community Involvement, and assistance to Univ & DOE sites on ISO 14001.
How have internal communication efforts changed since registration?  Continue bulletin, Monday Memo, ECRs, and SBMS channels; reduced frequency of EMS meeting to monthly, and Sr Mgmt Status Updates meetings to triennially.  Sr Mgmt Status Updates expanded to include other environmental initiatives.
Although Subject area & agenda conflict, were aspects reviewed/revised during Mgmt Review?   Aspects are reviewed and revised through work planning protocols (ESR, PAF, permits), but are evaluated at Mgmt Review to be sure complete, and that new facility specific aspects are incorporated in Lab list.

*Suggestions made to rotate assignment of EMS Rep & team members.  Thoughts?*
*Ideas for additional/advanced training?  Advanced Implementation techniques, “Leadership by Example”, others?*
*How have external communication efforts changed since registration?** They haven’t; strategic communications program continues the program established in ’98.  New focus is on scientific achievements (for balance), new GW Contingency Plan (notifications of unexpected monitoring results), Community Involvement, and assistance to Univ & DOE sites on ISO 14001.*
*How have internal communication efforts changed since registration?**  Continue bulletin, Monday Memo, ECRs, and SBMS channels; reduced frequency of EMS meeting to monthly, and Sr Mgmt Status Updates meetings to triennially.  Sr Mgmt Status Updates expanded to include other environmental initiatives.*
*Although Subject area & agenda conflict, were aspects reviewed/revised during Mgmt Review?**   Aspects are reviewed and revised through work planning protocols (ESR, PAF, permits), but are evaluated at Mgmt Review to be sure complete, and that new facility specific aspects are incorporated in Lab list.*

**Desk Audit Results**

## When were aspects last revised?  What prompted revision?  What operational changes prompted review of list?  Obtain objective evidence review occurred.
Emphasize periodic review processes, plus channels for getting information on ad hoc basis (experimental review committees, new project starts, work permits, etc)
When were objectives/targets last revised?  What prompted revision?  Were FY01 CO/O/PM evaluated when establishing facility objectives?  Obtain objective evidence review occurred.
Flowdown of labwide CO/O/PM; incorporation of facility specific goals/objectives (from management review, planning retreats, etc); reference Environmental Priorities document
What recommendations from last year’s Management Review were made?  What has been implemented?
Demonstrate that these items were tracked and give status.
In cases where objectives are same for each EMP, verify the actions planned are specific to operations listed.  Review specific EMP/action plans.
Apply to those who have generic format: the actions/tasks, responsibilities, timelines must be specific and applicable to the activity and/or aspect

*Emphasize periodic review processes, plus channels for getting information on ad hoc basis (experimental review committees, new project starts, work permits, etc)*
*When were objectives/targets last revised?  What prompted revision?  Were FY01 CO/O/PM evaluated when establishing facility objectives?  Obtain objective evidence review occurred.*
*Flowdown of labwide CO/O/PM; incorporation of facility specific goals/objectives (from management review, planning retreats, etc); reference Environmental Priorities document*
*What recommendations from last year’s Management Review were made?  What has been implemented?*
*Demonstrate that these items were tracked and give status.*
*In cases where objectives are same for each EMP, verify the actions planned are specific to operations listed.  Review specific EMP/action plans.*
*Apply to those who have generic format: the actions/tasks, responsibilities, timelines must be specific and applicable to the activity and/or aspect*

**Desk Audit Results**

## Noteworthy Practices:
FO developed concise table in their SAP to identify & track E objectives
ESD developed Environmental Priorities document to describe CO/O/PM in laymen’s terms and give guidance on facilities role in achieving them
CAD developed useful EMS audit checklist
ESD performed impressive self evaluation of their Mgmt System using Baldrige Criteria
Minor Nonconformances:
IAP subject area did not include requirements for reporting labwide audits
Self Assessment Plan/audit report did not demonstrate that a complete audit was performed
Observation
Waste generation reports provided inconsistent information and makes tracking of performance measures difficult
Using allocation reports and waste generation reports, but each serves different purpose
Do Reps have adequate reports to track progress on E objectives?

- FO developed concise table in their SAP to identify & track E objectives
- ESD developed Environmental Priorities document to describe CO/O/PM in laymen’s terms and give guidance on facilities role in achieving them
- CAD developed useful EMS audit checklist
- ESD performed impressive self evaluation of their Mgmt System using Baldrige Criteria
- Minor Nonconformances:
- IAP subject area did not include requirements for reporting labwide audits
- Self Assessment Plan/audit report did not demonstrate that a complete audit was performed
- Observation
- Waste generation reports provided inconsistent information and makes tracking of performance measures difficult
- Using allocation reports _and_ waste generation reports, but each serves different purpose
*Do Reps have adequate reports to track progress on E objectives?*

**Onsite Readiness Review Results**

## Registration Audit: 6/18 – 6/22/01
Schedule not available yet
Preparing Bulletin articles and Monday Memo articles 
P2; Environmental Policy commitments & what it means to you; Auditee Tips
Emphasis needed on Policy Commitments awareness and relationship to work

STATUS OF ATS ITEMS: To be verified in June by registrar. 
Additional Objective Evidence of Correction Action needed for:
CAD: 142.5.1, 142.6.1, 142.13.1
PO: 155.4.2 (see email 1/10/01); 195.18.1,
ESHQ: 195.12.1, 412.5 (no action plan)
CO: 412.4 (no action plan or description of actions)
Submit copies of objective evidence to ATS by 6/1/01
Overdue Item: ATS # 195.6.1, Chemistry

- Schedule not available yet
- Preparing Bulletin articles and Monday Memo articles
- P2; Environmental Policy commitments & what it means to you; Auditee Tips
- Emphasis needed on Policy Commitments awareness and relationship to work
- _STATUS OF ATS ITEMS:_ To be verified in June by registrar.
- Additional Objective Evidence of Correction Action needed for:
- CAD: 142.5.1, 142.6.1, 142.13.1
- PO: 155.4.2 (see email 1/10/01); 195.18.1,
- ESHQ: 195.12.1, 412.5 (no action plan)
- CO: 412.4 (no action plan or description of actions)
- Submit copies of objective evidence to ATS by 6/1/01
- Overdue Item: ATS # 195.6.1, Chemistry

**Preparation for Registration Audit**

## EMS Program Tasks 2001**

***Should be done: ***
- Review & revise Aspects spreadsheet.
- Establish FY 01 Objectives/Targets/Performance Measures & EM Programs (EMP form or equivalent)
- Verify adequacy of Operational Controls  (OCF or equivalent)

***Should be doing:***
-  Revising EMS Documents & verifying adequacy of document control
-  Tracking performance on Objectives/Targets & corrective actions
-  Reporting status & issues to management
-  Establishing EMS record series/schedules
-  Monitoring and implementing new/revised requirements

***Should be planning on doing:***
-  Training new employees, transfers, and visiting scientists
-  Communicating policy commitments to staff
-  Reinforcing use of Nonconformance/CA/PA systems
-  Scheduling EMS Audits & Management Reviews

***see slides from January and February meetings for more detail*

## Other Issues & Announcements

- Training for Guests/ Visitors
- Option to require Env Prot or provide via facility specific training
- Records Status
- All environmental records need to be checked off in the INFORM system before verification audit on 6/18/01.
- Please work with Records Rep to ensure completion and when verified, have Records Rep contact P. Flood by email.  Please also notify her if you did the inventory and found no e-records.
- EMS Reps need to verify that any E-records for their ALD have been inventoried.  In  addition, some Directorates have multiple records reps, please verify with all of them that the inventory has been completed, for example:
- DO encompasses Marburger, HR, diversity, legal, ITD, etc.,
- ESHQ includes Sheridan, OMC, OS, QA, etc.,
- EENS includes Energy Sciences & Technology, Nonproliferation and National Security, Research Operations Office, besides P. Paul (still acting?),
- FO includes Bebon, Plant Engineering, Central Shops.
- Review attachment for additional stragglers:
- RHIC/CAD Users Facility has no owner!!

## Next Meetings

- Next EMS Meeting  6/14/01
- Time: 1:30 pm - 3:00 pm
- Location - 535 Conference Room
*NOTE: EMS Project Team Meetings held on 2nd Thursday of each month*
*CHANGED to monthly meetings*
- Next EMS Meeting Topics:
- Preparation for Registration