Environmental Management SystemEnvironmental Management SystemCommunication Success at Savannah RiverCommunication Success at Savannah River

Presentation to N.C. Division of Pollution Prevention and Environmental Assistance

Environmental Management Systems Development Course for Government Agencies

David L. Lester, CM, REMLead Technical Specialist

Environmental Protection DepartmentWestinghouse Savannah River Company

Aiken, South Carolina 20809

2

Savannah River Site (SRS) History

Savannah River Site (SRS) History

• SRS was established in 1950

• Includes portions of Aiken, Barnwell and Allendale counties

• The land cost $19 million and includes 310 square miles

• Ellenton, Dunbarton and other towns werehome to 6000 peoplewho had to relocate

3

SRS History (cont.)SRS History (cont.)

• Construction began February 1951Five reactors; two separations areas; a heavy water plant; a fuel fabrication plant; and administrative facilities

• <10% land used for production

• All operations cloaked in secrecy

4

Cold War Missions and Programs

Cold War Missions and Programs

Primary mission of SRS was to produce

plutonium and tritium for nuclear weapons

5

Production Process

6

Post-Cold War Missions and Programs

Post-Cold War Missions and Programs

• National Defense– replacement tritium

facility• Nuclear Materials

Management– separation facilities– spent nuclear fuel

• Environmental Management

– waste management– environmental

remediation

7

SRS Natural Features

4,000 acres of ponds and reservoirs300 miles of streams35,000 acres of bottomland hardwood530 acres of streams and waterways5,800 acres of swamp forest40,000 ccf of timber harvested annually44 amphibian, 59 reptile, 255 bird, 54 animal species, 45 fish species, 1,322 species of floraSome endangered/threatened species are residents

– Southern Bald Eagle, red-cockaded woodpecker, smooth purple coneflower, Bachman’s sparrow, American alligator, shortnose sturgeon, bog spice bush

8

Regulated Activities

@ 675 environmental permits in effect3 public drinking water systems– 13,000 people

34 NPDES outfalls - 5,700 parametersannually150 stormwater outfalls - 1,200 parameters annually30 wastewater treatment plants28,000 Material Safety Data Sheets managed235,000,000 pounds of chemical inventory14,000 chemicals and chemical products used83 line items on the EPCRA Tier II inventory

9

Waste Management

@ 270 hazardous waste accumulationareas1.2M pounds of hazardous waste shipped annually16 RCRA permitted treatment facilities1M gallons of stored RCRA waste36M gallons of stored liquid high-level waste in 49 carbon steel underground storage tanks2M pounds of vitrified waste at Defense Waste Processing Facility477 waste units (1/3 closed)

10

EMS Implementation at SRS

AssumptionsProcess General Description and Timeline DiscussionIntegration with Department of Energy Safety Management Program -- We bring ISO 14001 into OperationsTeamingResultsLessons Learned

– Identify Risks

Questions

11

Operating Assumptions and “Givens”

Assumptions– Site policy and commitment to comply with regulations is

strong, therefore maintaining good regulatory relationships– Regulations will continue to evolve and increase in complexity

and WSRC has ability to negotiate compliance schedules– Site Operations will be consistent with forecast at beginning of

fiscal year (including Environmental Restoration projects)– No dramatic change in number of permitted discharge points,

chemical usage, and permitted waste streams– No dramatic change in frequency or extent of regulatory

audits– No major unplanned spills or other accidental releases with

offsite consequences

12

Implementation of ISO 14001 at SRS

Benchmark Team represented entire site (1997)– Key Decision - Implement site wide versus individual

organizations– Key Decision - Evolution versus revolution

Gap Analysis and Gap Closure Plan (1998)– Gap closure continued through implementation phase

Implementation Team - Management commitment of resources

– Key Decision - Third party certification or self-declare conformance?

Registrar “selection” (1998)Completed self-declaration and independent audit (1998)

– Key Decision - Identify cost benefits for independent certification

13

ISMSISMS

OSHA Process Safety Mgmt (PSM)

Enhanced Work Planning (EWP)

Voluntary Protection Program

(VPP)

EPA Risk Mgmt Plan (RMP)

Environmental Management

System(ISO 14001)

Chemical Manufacturers

Association (CMA) Responsible Care θ

Individual Safe Behaviors

14

A management system that integrates “Safety” to A management system that integrates “Safety” to encompassencompass

the publicthe publicall employeesall employeesthe environment, includingthe environment, including

waste minimizationwaste minimizationpollution prevention pollution prevention

at the worker, organization, and corporate level.at the worker, organization, and corporate level.

What is the DOE Integrated Safety Management System (ISMS)?

15

Procedures

Personnel

Plant

Communication of ESH Programs into Work at SRS

ESHPrograms

Covering 20Functional Areas

Site S/RID

e.g.. EnvironmentalProtection & Waste

Management

S/RID

Integrated Procedure Management SystemDevelop/Implement Controls

Conduct ofOperations

Conduct ofMaintenance &

Engineering

Conduct ofTraining

Get Work Done SafelyPerform Work

Feedback &Improvement

Contractor RequirementsDefine Scope of Work

WSRCPrograms

Each ProgramAddressed by One (or More)

Site Level Manuals

e.g. 3Q EnvironmentalCompliance,

1S Waste AcceptanceCriteria,

1Q Quality Assurance

16

Communications within EPD -Regulatory Compliance

EPD SMEs Review,Comment, Negotiate,

Influence, Interpret Requirements,

Provide Guidance,Assess Program

Effectiveness

EPD and Matrixed Environmental Groups DevelopSite Policy (EMC)

Programs and Procedures

Environmental Lawsand Regulations,

Permits, Consent OrdersDOE Orders

EPD SMEs ProvideField Support,

Training, Advise, Write Reports, Assist in

Evaluating Upsets,Assessments, Develop

Improvements, Lessons Learned

EMC and FacilityManagement

Develop ExecutionStrategy

17

Environmental Communications outside EPD -ECA Operational Support

EPD and Matrixed Environmental Groups DevelopSite Policy (EMC)

Programs and Procedures

Field EnvironmentalCompliance Authorities

Work with OperatingPersonnel to Include

Program Requirementsin Facility

Procedures

Facility ManagementInclude Specific

Environmental Requirementsin All Their Operations

Field EnvironmentalCompliance Authorities

Assist Operating Personnelwith Implementation,

Assess Implementation,Provide Input for Site

Reports

EMC and FacilityManagement

Develop ExecutionStrategy

18

Teaming = Synergy

Planning and preparation for normal or recurrent activities– Participate in strategic planning and activity execution

Project TeamsPermit Application DevelopmentEnhanced Work PlanningTechnical Support and Assessment of Program ImplementationWaste ManagementTraining

– Bring global vision of environmental requirements to Operations personnel

Fill gaps between procedures and their intentUse expertise to influence right decisions

– Enhance environmental hazard awareness in the performance of JobHazard Analyses, work planning

– Senior management involved at budget/planning stage

19

Teaming = Synergy

Help integrate Environmental Management System requirements into the operating culture

– For SRS, this meant extending application of principles and functions of ISM to activities that involve environmental protection, i.e.,

Enhanced work planningProcedure DevelopmentManagement ToursOperator Rounds

– Applicability of different requirements to an operationDifferent Laws/Requirements depending on situationAppropriate Response actions

20

Teaming = Synergy

Hazard Analysis for unstructured activities– Help analyze hazards when “out of the box” -

Identify options and risks– Understand politics and commitments

Guidance when situation not covered by proceduresRationale to do the environmental protection “right thing”

21

Teaming = Synergy

Help integrate Environmental Management System requirements into the operating culture (Continued)

– Normal operations that could challenge the environmental protection envelope

– Improve the application of pollution prevention, waste minimization, and energy efficiency techniques within work activities

Assist in development of workplace culture that promotes the concept of confirmed readiness to perform work and readily stops work if conditions changeHelp develop clearly defined work instructions through interactions with operations and maintenance personnel

22

Success Keys

Communication that is both timely and complete– Acquire full understanding of each situation before acting

Spend time in field with affected organizations– Provide solution options, not hurdles– Include options and their risks so an informed decision can be

reachedKeep discussions professional

– Eliminate hidden agendas– All one team with one purpose

“Win-Win” is the only solution that makes everyone happyOperations really wants to do the right thing

Listen and respond to the urgency– Don’t assume

23

Benchmarking Environmental Management System at SRS

First major site in DOE Complex to achieve and maintain independent certification against ISO 14001 international standard

– SRS’s program has been used to benchmark other organizations

Brookhaven National LaboratoryNASAPublic Works Authority of CharlestonCanadian Government

Independent certification stopped in Fiscal Year 2002– Lack of progress indentifing real cost benefits– Continue to self-declare and maintain programs

(required by E. O 13148)

24

Lessons Learned

Quality of EMS “manual”Manager’s familiarity and use of EMS manualOver emphasize objectives and targets throughout organization“Limit” aspects to significant impact - define significantUse every means possible to publicize policyClearly delineate EMS audit results - widely publicizeFormalize Management Review process (procedure, schedule, etc.)Involve “communicators”Pre-audit records (training, qualifications, calibration, logbooks)Pre-audit performance indicators and tracking systemsOver emphasize “management system” audit, not compliance auditCommunicate, communicate, communicate, with management, employees, subcontractors

25

Go “Out of the Box” to Identify Potential Risks

Operating Risks– Facility Shutdowns– Loss of water service (sewer, drinking, wastewater, etc.)– Loss of waste disposal capacity (landfill, LLW, etc.)– Ventilation system shutdown– Loss of ability to store material from DOE sites

Financial Risks– Fines and Penalties (unallowable costs)– Projects slower and costlier– Potential loss of new missions– Increased cost through loss of self-permitting for domestic and

sanitary sewers– Loss of Fee potential

26

More Risks

Environmental Damage/Public Health Risks– Non-availability of emergency response,

monitoring, and investigations

Customer/Public Relations Risks– New Missions jeopardized by poor compliance

record– Loss of Fee for violations and fines; unhappy

customers– Public Perception, political support at risk

27

Concluding Thoughts and Suggestions

Communication– Talk the walk and walk the talk

Best way for individual worker to think environmental protection is for them to see it practiced daily by their supervisors

– Stress more positives, but don’t downplay negativesInvolvement– Actively use environmental professionals in other

programs– Supervision needs to value the effort needed,

managers set the example

28

Concluding Thoughts and Suggestions

Training/Education– Part of Continuing Training -- often and strong– Drills and practice exercises must reinforce your EMS– “Cross walk” EMS concepts into other training arenas

(maintenance, CONOPs, waste certification, safety, emergency preparedness)

Commitment– Give your people the tools they need to succeed

Self-Declare or Not?– Business Basis

– Regulator Exercise of “enforcement discretion”

29

Coincidence or Not ?

If,A B C D E F G H I J K L M N O P Q R S T U V W X Y Z

Equals,1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

Then,

K + N + O + W + L + E + D + G + E11 + 14 + 15 + 23 + 12 + 5 + 4 + 7 + 5 = 96%

H + A + R + D + W + O + R + K8 + 1 + 18 + 4 + 23 + 15 + 18 + 11 = 98%

Both are important, but the total falls just short of 100%

But,A + T + T + I + T + U + D + E

1 + 20 + 20 + 9 + 20 + 21 + 4 + 5 = 100%

30