Implementing an EMS that Integrates P2/Sustainability

Concepts

EFCOG Environmental Management Systems WorkshopImplementation, Lessons Learned, and

Best Practices

March 8, 2005

Sara Cornwell, Strata-GJan Jackson, BWXT Y-12

Wayne McMahon, 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 – Protect the Environment, – Prevent Pollution, – Comply with requirements, and – Continually 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 MediumPositive

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 HighPositive

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

OperationInputs / Outputs

Aspect Category

*

Aspect Description(Key Contaminants / Emissions / Wastes / Materials Consumed)

SRID /

Legal

Likelihood

Reg. Severity

Env. Severity

Total Score

Sig. (Y)es / No

RatingNotes &

Rationale

Steam Boilers Coal, Fuels NRM

Nonrenewable resource consumption (coal, natural gas, and

diesel fuel) Y H L H -51,000 YHigh qty nonR, TRI

reportable

Steam BoilersBottom 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 BoilersReturn

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

Example for Steam Plant

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.