Using EMS to Ensure Environmental Compliance into the Future

1

• Using EMS to Ensure Environmental Compliance into
  the Future

Thomas Seguljic, P.E. HRP Associates, Inc. 100
Saratoga Village Blvd Malta, NY
12020 518-899-3011 tom.seguljic_at_hrpassociates.com
2
Overview

• What is an EMS?
• Why Develop an EMS?
• Status of EMS at Colleges/ Universities
• Incentives For an EMS
• How To Develop an EMS

3
What is an EMS?

• An Environmental Management System (EMS) is a
  systematic approach that allows an organization
  to manage its environmental process and
  performance by
• Identifying environmental impacts
• Establishing priorities and setting performance
  improvement goals
• Providing operating procedures to
  initiate/complete tasks
• Continuously monitoring and measuring success

4
What is an EMS? (cont.)

• The EMS is made successful through a continual
  cycle of
• Planning
• Implementing
• Reviewing
• Improving the processes/actions that to meet its
  environmental goals

US EPA Environmental Management Systems Website
5
What is an EMS? (cont.)
POLICY
PLANNING
IMPLEMENTING
CHECKING
REVIEWING
6
Why Develop an EMS?

• Centralize authority coordinating environmental
  practices and improve communication
• Improve environmental performance/reduce costs
• Enhance image with public/regulators
• Reduce/mitigate risks
• Attract new students/employees
• Improve employee awareness of environmental
  issues/responsibilities
• Qualify for recognition/incentive programs such
  as the EPA Performance Track Program

7
Why Develop an EMS? (cont.)

• Historically colleges/universities received
  little attention
• EPA holds educational institutions to same
  standards as industry
• EPA identified high rate of non-compliance at
  colleges/ universities
• Significant releases noted

8
Why Develop an EMS? (cont.)

• Typical multimedia violations
• EPCRA - Community Right To Know reports not filed
• SPCC
• SPCC plans
• Significant oil spills into surface waters
• Air - Small boilers not permitted
• TSCA - PCB not properly managed
• UST - upgrade requirements not completed
• RCRA
• Improper hazardous waste determinations
• Open, unlabeled and/or undated containers
• Incompatible chemical storage in publicly
  accessible areas
• Generation of toxic chemicals and medical wastes
  that are improperly disposed by researchers
  (e.g., poured down drains

9
Status of EMS at Colleges/ Universities

• Based on questionnaire of 108 colleges/universitie
  s that have EMS

10
What is the EMS Goal?
11
What is Used as a Performance Indicator?
12
Federal Incentives

• Performance Track Eligibility
• Open to all facilities
• Must have EMS in place
• Must have record of compliance with applicable
  laws during current and preceding year
• Must commit to 2-4 quantitative goals (i.e.
  reduce waste by 80, reduce emissions)

13
Federal Incentives (cont.)

• Incentives
• Reduced MACT reporting frequency
• Local/National recognition through letters to
  elected officials, trade journal articles, press
  releases, case studies, P-Track News, member
  listings on this website, and Performance Track
  Awards
• Expedited NPDES review
• More favorable terms for Clean Water Revolving
  Funds
• Extended accumulation (LQG up to 180 day vs 90)
• Low priority routine inspections

14
NYSDEC EMS Incentives

• CP-34/Using EMS - NYSDEC will promote the
  voluntary developmental use of EMS
• Provides recognition
• DEC priority assistance

15
How to Develop an EMS

• Getting Started
• Externally Validated EMS (ISO 14000) vs.
  Non-Validated EMS
• Fenceline Determination
• Cover environmental or both environmental/ health
  and safety
• Only environmental regulation
• C/U only or outside impacts

16
How to Develop an EMS

• Document Management
• Level of Detail
• How long will documents be maintained, by whom,
  and where
• System Type
• Paper vs. Electronic
• One Dimension task only
• Two Dimension- task with reminders/document
  management
• Three Dimension tasks with reminders/Documents/C
  ompletes reports

17
Select an Environmental Management Representative
(EMR)

• EMR has the responsibility and authority for
  implementing and maintaining the EMS
• EMR qualifications include
• Authority
• Good communication skills
• Strong leadership skills
• Broad knowledge of organization operations
• Time to fulfill this role

18
Select EMS Team(s)

• Use employees from various levels and functions
  (Cross-Functional Team)

• EMS team member qualifications
• Respected by employees/top management
• Strong operational knowledge
• Good communication and listening skills

19
Develop Objectives and Goals

• EMS Goals
• Compliance No violations
• Waste Reduction
• Energy Reduction
• Cut Green House Gas Emissions
• Use Less Toxic Materials

20
Conducting a Gap Analysis

• Baseline assessment to determine overall
  conformance with EMS requirements
• Typical EMS elements in-place
• Legal and other requirements
• Monitoring and measurement procedures
• Standard operating procedures
• Environmental, health safety training programs
• Emergency response procedures
• Operational controls

21
How to Develop an EMS (cont.)

• EMS Components
• Environmental Policy
• What does the organization want to achieve

22
UMass Lowell Environmental Policy Ride the Crest

• C - Continuous Improvement
• R - Reduce, Reuse, Recycle
• E - Environmental Compliance
• S - Stewardship
• T - Training and Education

23
Aspects and Impacts

• Aspects
• Identify activities which interact with the
  environment
• Impacts
• Any positive or negative changes to the
  environment due to activities

24
Examples of Aspects and Impacts

• Environmental Aspects
• Pouring chemicals down the drain
• Improper disposal of recyclable materials (i.e.
  cans, paper, etc.)
• Leaving computers and lights on when not in use

• Environmental
• Impacts
• Contaminating city water supply
• Increase solid waste taken to landfills
• Increased energy use and greenhouse gas emissions

25
Objectives and Targets

• Objective
• The goal that C/U has set out to achieve
• Should be quantifiable if possible
• Target
• Supports the achievement of the objective
• Should be a measurable criterion

26
Examples of Objectives and Targets

• Objectives
• Start recycling drink bottles
• Turn off lights and computers when not in use
• Maintain compliance with all applicable
  environmental regulations

• Targets
• Recycle 20 pounds per month
• Reduce office energy use by 100 kWhs per month
• No violations

27
How to Develop an EMS (cont.)

• Implementation and Operation
• Establish Procedures and Responsibilities to
  Achieve Targets
• Training
• Documentation and Document Control
• Checking/Corrective Action
• On-going EMS evaluation including Compliance
  review
• Conformances, Corrective and Preventive Actions
  (on-going fixes to system)

28
Reality Check

• Most C/U facilities are developing EMS with
  compliance as goal
• EMS vs EMIS

29
Comparison

• EMS
• Top down support
• Policy
• Goals and objectives
• Plan/Do/Check/Act
• Environmental improvement

• EMIS
• Bottom level action
• Applicable requirements
• Do and document
• Compliance as bottom line
• Daily/Weekly/Monthly

30
Technology Choices

• Local hardware
• Software
• Generic (DB)
• Package
• Support requirements
• Personnel
• Back-ups
• Development

• External hardware
• Solution oriented software
• External support
• External development

31
Requirements for Success

• Resource commitment
• Personnel, capital and/or operating costs
• Project management thinking
• System development
• User training
• Outsourcing