EMS / NEPA Integration at the Idaho National Laboratory

Bruce Angle & John Irving

Battelle Energy AllianceIdaho National Laboratory

Environmental Management System WorkshopMarch 8-9, 2005

The INL …• Located in Eastern Idaho

• 890-square mile reservation

• Managed by Battelle Energy Alliance for the DOE

• Lies within the upper Snake River Plain sagebrush steppe ecosystem

• Several major facilities

• High mountain desert ecosystem known for its cultural and natural resources

• The major laboratory activities:

Nuclear energy research and engineering

National security technology development

Time Line

1990 20001995

NEPA

Proc

ess

INEEL

Conso

lidat

ion

Req. F

low D

own

ISM

S Im

plem

enta

tion

begi

ns

ISO

-140

01 S

tarte

d

Subject Matter BasedWork Activity Based

2005

ISO

140

01 R

egist

ered

Environmental Management System WorkshopMarch 8-9, 2005

Six

Surv

. Aud

its

2000 2005

New

INL

Contra

ct

ISO

Reg

.

Re-re

gistr

atio

n

Dec

ision

INL’s Perspective

• The NEPA Process at the INL is part of the INL’s Environmental Management System

• The EMS is fully integrated into INL’s Integrated Safety Management System

• EMS is patterned after ISO 14001 requirements

Status of INL’s EMS

• Meets EO 13148 & DOE Order 450.1

• Robust EMS, fully includes NEPA values

• Registered to ISO 14001, and has successfully passed five surveillance audits

• Management decision to ‘consolidate’ first, then seek ISO 14001 registration.

EMS and NEPA

EMS Elements• Environmental

Aspects

• Work ActivitiesSignificant Work Activity

• Potentially Significant Environmental Aspect

NEPA Values• Potential Impacts &

Issues

• Proposed Activities

• Significance Determination, (i.e., CX, EA (FONSI) or EIS (ROD)

Significance?

• Under INL’s EMS

– The company chooses what is significant and what it wants to influence through the selection of criteria and the setting of objectives and targets.

• Under NEPA

– Agencies generally determine potential significance through a ‘detailed statement’ or EIS, often relying on ‘thresholds of significance’ and considering the intensity & context of the impacts.

Significance Determination

The activity, or the operation has little discernible impact on local ecology, including air, water, soil, groundwater quality, and biological receptors. Little or no remedial action is required to address releases to the environment or other environmental damage. (A release to secondary containment in a building is not considered to be significant.)

The activity has short term or minor impacts to local ecology that are fully recoverable.

Remedial action is required to address releases to the environment or other environmental damage. (A release to secondary containment in a building is not considered to be significant.)

The activity has a major, long-term or permanent impact to local ecology. Long-term or major remedial action is required to address releases or other environmental damage. Release to the environment from these activities or sources are a major contributor to regional problems.

Not Significant Significant

or

or

Environmental Aspects

INL’s Environmental Checklist Combines EMS & NEPA Elements

Purpose of EC

1. Determine level of environmental review (such as environmental assessment or environmental impact statement. In other words, determine the potential for significant environmental impacts.

2. Flow down requirements (through instructions from MCP-3480) to the worker.

Purpose of EC

4. Identify new environmental aspects.

5. Identify significant environmental aspects of new work activities and develop controls.

3. Identify new work activities with environmental requirements.

Environmental Checklist / Sec. A

• Provide Descriptive Information

– Charge Number

– INL / ICP

– Project Title

– Performing Organization

– . . .

Environmental Checklist / Sec. B

• Project Description: Provide a Brief and accurate description of the project or activity on attached sheet.

– Brief and accurate

– Purpose & need

– Type of activity

– Location

– Beginning & ending dates

• Environmental Aspects / Potential Sources of Impact: Check the appropriate box and provide explanation for any aspect checked “Yes” on an attached sheet.

– Air Pollutants

– Asbestos Emissions

– Biological Hazards

– Chemical Use & Storage

– Contaminated Sites Disturbance

– Cultural/Historical . . .

Environmental Checklist / Sec. C

Environmental Checklist / Sec. D

• Work Activities and Environmental Checklist Submittal Determination: Select all of the applicable work activities.

– From MCP-3480

• Required to submit EC to Environmental Compliance?

• Not required to submit EC to Environmental Compliance?

Environmental Checklist / Sec. E

• Conditions: Are conditions required before starting project?

– APADs (Air Permitting)

– Cultural Resource Clearance

– Biological Resource Clearance

– Other approvals

Environmental Checklist / Sec. F

• Determine the Level of Environmental Review (or Documentation)

– Categorical exclusion

– Environmental assessment

– Environmental impact statement . . .

Work Control System

DOE Integrated SafetyManagement System

(ISMS)

Activity-BasedEnvironmental Compliance

SystemNew Work Activity

Identification and ChangeControl System

(NEPA)

VoluntaryProtection Program

(VPP)

Existing Systems

(i.e., Documents, Records,Training, Monitoring, etc.

ISO 14001Registration

ISO

INL’sEnvironmentalManagement

System

Benefits

983

840

316

156

00

100

200

300

400

500

600

700

800

900

1000

1997 1999 2000 2001 2002

Do

llar

s (0

00)

EnvironmentalEnforcement Penalties

(Original Assessed Penalty)

Tangible & Intangible Benefits of an EMS / NEPA Process• Tangible

– Environmental compliance

– Reduced fines & penalties

– Pollution prevention activities

– Integration with other systems such as NEPA

• Intangible

– Environmentally conscious workforce

– Environmental protection

– Continual improvement

Moving beyond compliance

The End

Contact:John IrvingJohn.Irving@inl.gov208.526.8745

Or

Bruce AngleBruce.Angle@inl.gov208.526.1841