Environmental Management Directorate

1

• Environmental Management Directorate
• EMS/OSH
• Management Review
• September 21, 2006

2
Purpose of Meeting

• ISO 14001, OHSAS 18001, and Integrated Assessment
  Program Self Evaluation requires a Senior
  Management review of the EMS Program and
  environmental performance
• Review performance of key system components
• Evaluate ISO 14001 EMS Program
• Adequacy does it meet requirements
  implemented appropriately
• Suitability- does it fit BNL operations
  systems
• Effectiveness- is it achieving the desired
  results
• Expected Outcome
• Identify areas where focused improvement
  initiatives are needed

3
Inputs to Management Review

• a) results of internal audits and evaluations of
  compliance with legal requirements and with other
  requirements to which the organization
  subscribes
• b) communication(s) from external interested
  parties, including complaints
• c) the environmental performance of the
  organization
• d) the extent to which objectives and targets
  have been met
• e) status of corrective and preventive actions
• f) follow-up actions from previous management
  reviews
• g) changing circumstances, including developments
  in legal and other requirements related to its
  environmental aspects and
• h) recommendations for improvement.

4
EMS Assessments

• Internal by EWMSD
• Noteworthy Practice (1)
• Control of Documents (revision of documents)
• Opportunity for improvement (3)
• Control of Documents (SBMS document embedded in
  Procedures did not have rev date)
• Management review (2), incorporating feedback
  into objectives and targets, and communicating
  issues raised during Management review
  (documentation)

5
EMS Assessments

• External by NSF
• Noteworthy Practice (3)
• Corrective and Preventive Action Condition
  Reporting/Corrective Action Process
• Communication use of Lessons Learned in weekly
  EHS communications activities
• Operational Controls in work-specific
  procedures and work permitting/documentation

6
Regulatory Compliance Assessments External
Audits

• Multi Topic Environmental Monitoring Self
  Assessment (EWMSD)
• ERP was not included in this assessment, due to
  the scope (ESRs, Universal and Industrial Waste,
  and QA/QC of sampling) not fitting with ERP being
  in a planning phase for much of 2006.

7
Assessments

• Exit Readiness Evaluation of Cold Neutron
  Facility performed.
• Tier 1s

8
Management Review Questions

• Have we adequately addressed internal audits and
  evaluations of compliance?
• Do you have any comments on internal audits and
  evaluation of compliance?
• Does this meet our needs?
• Any other comments/suggestions?
• This satisfies the requirement for section 4.6(a)
  of ISO 14001 (2004)

9
Stakeholder Concerns Issues and Actions Siva
Kumar
10
Stakeholder
11
Stakeholder Concerns Issues and
ActionsRegulatory Interactions

• Excellent communications and constructive working
  relationship with regulatory agencies
• EPA
• NYSDEC
• NYSDOH
• Interactions with Suffolk County Department of
  Health Services affected by anticipated change in
  personnel

12
Stakeholder Concerns Issues and
ActionsRegulatory Accomplishments

• HFBR Core Team discussions proved efficient and
  effective
• Seven meetings dealt with design, operation,
  characterization and alternative remedies
• Agency management reviews coupled with projected
  personnel changes proved challenging
• Conceptual agreement on modified set of
  alternatives and preferred alternative in sight

13
Stakeholder Concerns Issues and
ActionsRegulatory Accomplishments (contd)

• Five-Year Review Report approved
• Nearing agreement on g-2 Feasibility Study and
  UST/BLIP/g-2 Proposed Remedial Action Plan
• BGRR remedy implementation under way
• Regulatory review of graphite pile remedial
  design/remedial action plan in progress
• Remedial design/remedial action plan for
  biological shield and engineered cap to follow

14
Community Outreach Involvement and
Communications

• Jeanne DAscoli
• Community Relations, Manager
• 2006

15

• October 2005 Representatives from Department of
  Energy, regulatory agencies, elected officials,
  and the community joined to celebrate the
  completion of high-priority environmental
  restoration work at and near the BNL site

16
Stakeholders Most Interested in HFBR

• High Flux Beam Reactor
• Of great interest to many internal
• and external stakeholders
• Management
• Community Advisory Council
• Elected and government officials
• Brookhaven Executive
• Roundtable
• Opportunities for input from stakeholders
  included
• Presentations
• Through panel discussions
• Tours
• Meetings
• Concerns identified through extensive questions
  raised

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Concerns of the Most Interested Stakeholders

• Noted concerns regarding the decommissioning and
  dismantlement of the HFBR ranged from
• Worker and employee safety
• Transportation risks
• Control rod segmentation and consequences
• Terrorist threat/ structural integrity, natural
  phenomena
• Timing of decommissioning and dismantlement
• Why 75 years
• Maintenance of buildings over 75 years
• Funding availability in 75 years

18
Additional Stakeholders Interest in the HFBR
Stack

• Conducted additional outreach to targeted
  stakeholders on potential interest in stack
  demolition.
• Phone calls to 40 organizations and individuals,
  including those with air, sea and historic
  interests
• Thirteen wanted to be kept informed about the
  project and to be notified when public meetings
  will be held

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Additional Stakeholders Civics, Media

• Civic Associations
• In April 2006, letters were sent to local civic
  associations informing them of the
  decommissioning process.
• Manorville and East Yaphank were given
  presentations
• Media
• Keeping the NY Times, Newsday, and local papers
  informed inviting them to public meetings

20
Waste Transportation Outreach Plan

• Waste Transportation Communications, Outreach and
  Involvement Plan drafted
• Agencies and points of contact identified
• Relationships are expected to be maintained by
  staff

21
Stakeholder Survey

• Peconic River
• Attempted to contact thirteen stakeholders five
  provided feedback
• Four expressed continued interest/ concerns
• All wanted to receive continual updates,
  preferably by direct mail
• Four want better follow up from Laboratory
• Groundwater
• Attempted to contact thirty-four stakeholders
  ten provided feedback
• All participants expressed continued interest/
  concerns
• All wanted to receive continual updates
  preferably by direct mail

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Outcomes

• Community Advisory Council continues to serve as
  advisors to the Director regarding environmental
  issues and concerns
• Good relationships with elected officials are
  being maintained through regular contact
• Federal, State and Local
• Surveys require need for follow-up actions
• Will act on requests to keep stakeholders briefed
  on stack
• Developing a proposal for a newsletter to be
  issued twice a year to inform stakeholders of
  status of environmental projects

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Management Review Questions

• Have we adequately addressed communications?
• Do you have any comments on communications?
• Does this meet our needs?
• Any other comments/suggestions?
• This satisfies the requirement for section 4.6(b)
  of ISO 14001 (2004)

24
Environmental Performance

• Spills
• No Spills in 2006!! ??
• (8 in 2005, 7 in FY 04, 4 in FY 03, 8 in FY02)

25
Environmental Performance

• Waste Minimization
• Conducted Value Engineering Study with DOE to
  develop strategies for reactor DD
• Extensive characterization of BGRR pile
• Removed RCRA hazardous components from BGRR pile
  to minimize potential for generating mixed waste
  during pile removal
• Developed plan for removing materials prohibited
  from LLRW packages from HFBR

26
Environmental Performance

• Recycling
• Recycled 620 cubic yards of concrete and brick
  for reuse on site as roadbed material
• Recycled 30 tons of metal from demolition
  projects
• Land Reclamation
• Began the reclamation of 2 acres of land space
  by demolishing HFBR BOP buildings

27
Management Review Questions

• Have we adequately addressed our environmental
  performance?
• Do you have any comments on our environmental
  performance?
• Does this meet our needs?
• Any other comments/suggestions?
• This satisfies the requirement for section 4.6(c)
  of ISO 14001 (2004)

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Objectives and Targets

• Draft Appendix L-1 (of the draft DOE/BSA
  contract) identifies the ERP objectives and
  performance measures
• Performance Goal 9 - Deliver best-in-class
  performance in completing the Brookhaven
  Environmental Management Completion Project
  (BEMCP)
• Complete the BEMCP including Brookhaven Graphite
  Research Reactor (BGRR) pile and biological
  shield removal, and the High Flux Beam Reactor
  (HFBR) decommissioning project.
• Complete BEMCP tasks in accordance with the
  DOE-approved Performance Baseline.
• This is a multi-year performance goal for the
  period FY06 through FY11 or beyond.
• Contract modifications currently being
  revisited-will effect objectives and targets. As
  a result ALL objectives and targets are likely to
  be re-racked

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Targets
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Financial Investments

• All the work performed by ERP is related to a BNL
  Significant Environmental Aspect.
• Financial obligations are documented in the ERP
  baselines for BGRR and HFBR.
• ERP Funded Interdisciplinary staff includes
• Environmental Compliance Representative/EMS
  representative
• ESH Coordinator
• Training Coordinator
• Corrective Actions Manager/Condition Reporting
  System Owner
• Quality Assurance Program Manager
• Safety and Industrial Hygiene Manager/OHSAS
  Representative
• RCD Personnel (6)

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Management Review Questions

• Have we adequately addressed our objectives and
  targets?
• Do you have any comments on ERP objectives and
  targets?
• Does this meet our needs?
• Any other comments/suggestions?
• This satisfies the requirement for section 4.6
  (d) of ISO 14001 (2004)

32
Corrective and Preventative Actions

• ERP OPM 2.2, Corrective Action Program and
  Condition Reporting System
• 41 Condition Reports Total, (12 E, 18 OSH-Rad)
• NO INJURIES!!!
• 92.5 Corrective Action, 7.5 Preventive Action
• 48 Closed (55 E, 56 OSH closed)
• 52 in process
• Most resulted in causal analysis
• Staff trained in causal analysis (5 Whys and
  Barrier Analysis)

33
Corrective and Preventative Actions

• ORPS
• 2 ORPS incidents in 2006
• 1)EM--BHSO-BNL-BNL-2006-0012
• HFBR Dumpster alarms BNL Radiation Truck Monitor
  
• 2)EM--BHSO-BNL-HFBR-2005-0001
• Violation of High Flux Beam Reactor DOE Safety
  Evaluation Report
• Resulted in root cause analysis, and
  operational/procedural changes.

34
Management Review Questions

• Have we adequately addressed corrective/preventive
  actions?
• Do you have any comments on corrective/preventive
  actions?
• Does this meet our needs?
• Any other comments/suggestions?
• This satisfies the requirement for section 4.6(e)
  of ISO 14001 (2004)

35
Follow up actions(Management Review)

• EMS
• NONE, Although need to close out condition report
  by documenting management review with formal ROD
• OHSAS
• NONE, Although need to implement plans to address
  internal audit findings and prepare for
  registration audit

36
Follow up action(from ESHQ Management Review)

• EWMSD goal to improve communication between ERP
  and EWMSD
• Les, ESHQ wants your feedback. Has it improved?

37
Other Follow up Actions(last years commitments)

• Restructure EMS to include entire remaining scope
  of work
• Enhance Condition Reporting process
• Thoroughly review applicability of SBMS
  procedures and include in contracts
• Stay focused on completing ERP mission SAFELY!
• Waste minimization/P2
• Continued strong, visible management support for
  EMS

38
Management Review Questions

• Have we adequately addressed follow up actions?
• Do you have any comments on follow up actions?
• Does this meet our needs?
• Any other comments/suggestions?
• This satisfies the requirement for section 4.6(f)
  of ISO 14001 (2004)

39
Changing Circumstances

• New BNL ORPS SBMS Subject Area
• Reissuing baseline (changing DOE requirements)
• Contractual issues

40
Management Review Questions

• Have we adequately addressed changing
  circumstances?
• Do you have any comments on changing
  circumstances?
• Does this meet our needs?
• Any other comments/suggestions?
• This satisfies the requirement for section 4.6(g)
  of ISO 14001 (2004)

41
Recommendations for improvement

• Revise ERP OPM 2.2, Corrective Action Program and
  Condition Reporting System to align with new BNL
  ORPS SBMS requirements
• Improve recordkeeping and documentation by
  implementing a log book system for Legal
  Requirement Review, ORPS, Lessons Learned, and
  Condition Reporting
• Complete EMS and OHSAS web pages
• Improve integration of management systems (EMS,
  OHSAS, ISM)
• Clear line of sight metrics (TBD) for ESH
  performance
• Implement the Safety Observation Program to
  provide leading indicators of ESH performance.

42
Goals FY 07

• Nuclear grade program documentation
• Work on completing Reactor Projects SAFELY!
• Continued strong, visible management support for
  EMS, OHSAS and ISM
• Operate EVENT-free

43
Management Review Questions

• Have we adequately addressed improvement?
• Do you have any comments on improvement?
• Does this meet our needs?
• Any other comments/suggestions?
• This satisfies the requirement for section 4.6(h)
  of ISO 14001 (2004)

44

• Environmental Restoration ProjectsOccupational
  Safety and Health Management Review
• September 21, 2006

45
Agenda

• Review of OSH Performance
• Review of Facility and Job hazards and activities
  that can cause injuries and illnesses
• OSH improvements (additional controls) identified
  through risk assessments
• OSH Performance, Injury/illness rates, Tier I
  Performance
• Summary of OSH Assessments (external audits,
  internal audits, occurrence reports and
  corrective actions, non conformance reports and
  corrective actions)
• Costs
• OSH implementation and maintenance costs

46
Agenda (continued)

• FY 06 Objectives
• Effects of Foreseeable Changes to Legislation
• Management Discussion
• Identification of Improvement Actions
• Suitability of current ERP Policy

47
Job and Facility Risk Assessments

• Summary
• 37 JRAs completed for ERP
• 9 FRAs completed for ERP
• Eight JRAs and Nine FRAs as defined in the
  priority tables have been completed to date and
  are posted on the ERP OHSAS website. In
  addition, 29 Work Package specific JRAs have been
  completed during the work planning process.

48
Facility and Job Hazards

• List of Hazards Identified through Risk
  Assessment Process

49
OSH Improvements

• Additional controls that resulted from the risk
  assessment process and worker feedback.

50
OSH Improvements

• (Continued)

51
Noted Weakness

• Noted weakness with the Risk Assessment Process
• Activities such as administrative staff
  performing archiving activities (material
  handling) due not perform pre-activity briefings
  of review JRAs or perform tailgates prior to
  performing lifting activities.
• Status New training matrix for
  administrative personnel that includes back
  safety/lifting.

52
Summary OSH Performance

• FY 06 ERP Summary OSH Performance
• Lost Work Day Cases 0 (Last occurrence back
  injury in August of 2004)
• BNL Traffic Violations 2 (turn signal use and
  cell phone use)
• Personnel Contamination Incidents 0
• First Aid Cases 2
• Occupational Injuries 1 (shoulder strain from
  moving boxes)

53
OSH Performance ERP and Site Total Recordable
Cases (TRC) (FY 03 FY 06)

• In FY03, there was 1 Recordable case
• In FY041 case
• In FY05 there was 1 case
• In FY061 case

54
OSH PerformanceERP and Site DART Cases (FY 03
FY 06)

• In FY 03, there was 1 DART case.
• In FY04, there was 1 DART case.
• There were no DART cases for FY05 and FY06 YTD.

55
OSH Performance Tier I Inspections

• All ERP Tier Is are performed as scheduled.
• All Tier I findings were addressed within 30 days
  or placed on FATS for continued tracking.
• Typical deficiencies include general housekeeping
  and radiological postings.
• Improvements are continual as facilities have
  reduced activity or are decommissioned.

56
BNL Tier I InspectionsTop Seven Categories
57
External OHSAS Audit NSF Desk Audit

• NSF Desk Audit Completed No ERP Action Items
• External Audit To Be Conducted for Phase 3
  Organizations (includes ERP) on October 12th
  13th, 2006.

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Internal Audit

• Internal Audit Conducted August 16-21, 2006
• Findings
• Based on interviews with workers, employees are
  not fully aware of the BNL ESSH Policy. In
  addition, training on OHSAS should be reinforced.
  Status Policy cards will be distributed to all
  employees. OHSAS Factsheets will be used as
  training tools prior to registration audit.
• Organizational Chart and OHSAS Plan do not
  adequately identify specific personnel including
  the OHSAS 18001 Division Representative and the
  BNL OSH Management Representative. Status The
  organizational chart has been updated to include
  OHSAS contacts, contact list has been posted on
  website, and OHSAS factsheets will be used as
  training tools.
• R2A2s have not been updated for all staff.
  Status R2A2s for every employee will be revised
  when the SBMS subject area template has been
  corrected.

59
Internal Audit Findings

• Findings (continued)
• ERP procedures need to be finalized and placed on
  web. Historical procedures need to be archived.
  Status In process
• JRAs and FRAs need to document worker involvement
  in development process. Status In progress
• It was observed that Consultation and
  Communication of Legal Requirements could be
  improved. Status In progress
• It was observed that a specific room has not been
  identified for records retention. Status In
  progress

60
Internal Audit Findings (continued)

• Contractors are not involved with the initial
  risk assessment process. Status Use similar
  procedure to Plant Engineering (approved
  organization) further discussion required.

61
OSH Costs and Resources

• Contributed resources for the OHSAS 18001 Phase 3
  Registration Effort
• Implementation of Additional Controls from the
  Risk assessment Process
• 37 JRAs
• Approx. 360 person-hours (managers, safety
  professionals and workers)
• 9 FRAs
• Approx. 80 person-hours
• Training
• Approx. 150 person-hours

• 50,000
• 10,000
• 36,000
• 8,000
• 15,000
• Total 119,000

62
ERP OSH Objectives and Targets FY06Objective
Event-Free Workplace

• Target Safety and Health Measures
• Zero OSHA lost work day cases (work related)
• Status Year to date Lost Work Day Cases 0
• Zero personnel contamination incidents
• Status Year to date personnel contamination
  incidents 0
• Zero BNL traffic violations
• Status Year to date traffic violations 2
• Zero first aid cases
• Status Year to date First Aid Cases 2
• Zero Events
• Status Year to date Events ? (Condition
  Reports38)

63
ERP OSH Objectives and Targets FY06 Objective
Injury-Free Workplace

• Conduct Tier I Safety Surveys and Disposition
  actions
• Disposition Tier I findings within 30 days and
  perform as scheduled
• Status All ERP Tier Is were performed as
  scheduled and findings dispositioned in 30 days.
• Achieve OHSAS 18001 registration according to BNL
  established target dates
• Status All JRAs and FRAs identified have been
  completed. Desk audit and internal audit
  completed with follow up required. NSF
  registration audit scheduled for October 12th and
  13th (All Phase 3 Organizations).

64
ERP OSH Objectives and Targets FY06

• Achieve OHSAS 18001 registration by meeting
  target dates for Phase 3 registration
• Status On schedule
• Accident and Injury Reduction
• Review high risk assessments for improvement
  potential
• Status On schedule
• Improve Operational Performance
• Close findings involving corrective actions
  within 30 days. Analyze performance if trends
  detected.
• Status Meeting 30 day corrective action or
  tracked on FATS.
• Communications Improvement
• Improve OHS awareness and obtain staff feedback
• Status Improved feedback is being documented

65
Effects of Foreseeable Changes to Legislation

• 10 CFR 851 Rule Worker Safety and Health
  Program Proposed Rule
• Rule provides DOE with enforcement mechanism
  similar to PAAA
• Rule pulls in consensus requirements and makes
  them mandatory (e.g. ANSI, ASTM etc.)
• Rule first published in 12/03 to codify existing
  practices in order to ensure worker safety and
  health

66
Effects of Foreseeable Changes to Legislation

• Must achieve compliance with Rule within 1 year
  of effective date (February 26, 2007)
• Subject to civil penalty of up to 70K per day
  per violation up to contract annual fee.
• Significant costs are expected by implementing
  851
• Initial implementation/administration 600K
• Facility upgrades to meet codes 50.7
  million
• Ongoing maintenance activities 1.1
  million
• Total estimated lab impact 52.4
  million

67
Management Review Decisions

• Is the OSH Management System effective in
  achieving policy commitment?
• Is the OSH Management System effective in
  achieving the objectives, targets and performance
  measures?
• Is the OSH Management System adequate in terms
  of
• Resource allocation?
• Information systems?
• Organizational issues staff expertise
  procedural requirements

68
Management Review Decisions

• Are the objectives, targets and performance
  measures suitable taking into account the
  following factors
• Injuries/illnesses?
• Current and future regulatory requirements?
• Business interests, technological capability?
• Internal organizational or process changes?
• Should additional objectives, targets or
  performance measures be established?
• Summary of improvement initiatives identified
• Track to closure all ERP Tier I Findings in FATS
• Add zero events as target.
• Implement STOP observation procedure as a leading
  indicator of HS performance for all staff levels

69
Management Review Decisions

• Suitability of current BNL ESSH Policy