Integrating EMS / NEPA at the Idaho National Laboratory

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Integrating EMS / NEPA at the Idaho National
Laboratory

• John S. Irving

NAEP Workshop - Integrating NEPA into EMSs April
16, 2005
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The INL

• The INL, located in Eastern Idaho, consists of an
  890-square mile reservation managed by the DOE
  The INL lies within the upper Snake River Plain
  sagebrush steppe ecosystem. Eight major
  facilities are widely spread across this high
  mountain desert ecosystem know for its cultural
  and natural resources.
• The major laboratory activities include nuclear
  energy research, environmental restoration
  efforts, and engineering and national security
  technology development.

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Time Line
ISMS Implementation begins
ISO 14001 Registered
ISO-14001 Started
Req. Flow Down
INEEL Consolidation
NEPA Process
1990
2000
1995
2005
Subject Matter Based
Work Activity Based
Re-registration Decision
New INL Contract
Five Surv. Audits
ISO Reg.
2000
2005
Environmental Management System Workshop March
8-9, 2005
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INLs Perspective

• The NEPA Process at the INL is part of the Sites
  Environmental Management System
• The EMS is fully integrated into the Sites
  Integrated Safety Management System
• EMS is patterned after ISO 14001 requirements

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Status of INLs 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.

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INL Environmental Aspects

1. Air Pollutants
2. Asbestos Emissions
3. Biological Hazards
4. Chemical Use and Storage
5. Contaminated Sites Disturbance
6. Cultural/Historical Resource Disturbance
7. Discharge to Wastewater Systems or Groundwater
8. Drinking Water Contamination
9. Hazardous/Mixed Waste Generation and Management
10. Hazardous/Radioactive Material or Waste Handling
    and Transportation

1. Industrial Waste Generation and Management
2. Interaction with Wildlife/Habitat
3. Managing Property and Materials
4. PCB Contamination
5. Radioactive Materials Use and Storage
6. Radioactive Waste Generation and Management
7. Storage of Hazardous/Rad. Materials or Waste in
   Tanks
8. Surface Water and Storm Water Contamination
9. Use, Reuse and Recycling of Resources
10. Work within areas Subject to Flooding

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INL Environmental Significant Aspects

1. Air Pollutants
2. Asbestos Emissions
3. Biological Hazards
4. Chemical Use and Storage
5. Contaminated Sites Disturbance
6. Cultural/Historical Resource Disturbance
7. Discharge to Wastewater Systems or Groundwater
8. Drinking Water Contamination
9. Hazardous/Mixed Waste Generation and Management
10. Hazardous/Radioactive Material or Waste Handling
    and Transportation

1. Industrial Waste Generation and Management
2. Interaction with Wildlife/Habitat
3. Managing Property and Materials
4. PCB Contamination
5. Radioactive Materials Use and Storage
6. Radioactive Waste Generation and Management
7. Storage of Hazardous/Rad. Materials or Waste in
   Tanks
8. Surface Water and Storm Water Contamination
9. Use, Reuse and Recycling of Resources
10. Work within areas Subject to Flooding

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Environmental Aspects -- Process
INL environmental aspects and details of specific
hazards of each aspect
INL significant environmental aspects and
significance criteria
General work activities Activities with
environmental aspects and requirements
Positive work activities Activities with
positive impacts on the environment
Significant work activities Activities that have
the potential to significantly impact the
environment
Specific Hazard
Other Important factors
Calibration Procedures
Personnel / Worker
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General vs Specific Work Activities
Cultural/Historical Resource Dis..
General
Constructing or modifying drinking water systems
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General vs Specific Work Activities
Cultural/Historical Resource Dis..
Specific
Managing mixed waste in the tank farm
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(No Transcript)
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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.

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

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Purpose of EC

1. Identify new work activities with environmental
   requirements.

1. Identify new environmental aspects.

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

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Environmental Checklist / Sec. A

• Provide Descriptive Information
• Charge Number
• INL / ICP
• Project Title
• Performing Organization
• . . .

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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

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Environmental Checklist / Sec. C

• 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 . . .

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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?

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Environmental Checklist / Sec. E

• Conditions Are conditions required before
  starting project?
• APADs (Air Permitting)
• Cultural Resource Clearance
• Biological Resource Clearance
• Other approvals

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Environmental Checklist / Sec. F

• Determine the Level of Environmental Review (or
  Documentation)
• Categorical exclusion
• Environmental assessment
• Environmental impact statement . . .

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Workshop Exercises

• Wildland Fire Management at the Idaho National
  Engineering and Environmental Laboratory
  Environmental Assessment
• New Silt/Clay Source Development and Use at the
  Idaho National Engineering and Environmental
  Laboratory Environmental Assessment
• Materials Test Reactor Fuel Removal Project

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Wildland Fire Management at the Idaho National
Laboratory
Assignment?
STOP
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Comparing
EMS
NEPA

• Air pollutants
• Chemical use and storage
• Contaminated site disturbance
• Cultural/historical resource disturbance
• Industrial waste generation and management
• Interaction with wildlife/habitat
• Radioactive waste generation and management
• Surface water and storm water contamination
• Working within areas subject to flooding

• Fugitive dust
• Smoke plumes on vistas
• Downwind radioactive contamination and worker
• and public exposure radioactive and hazardous
• material
• Chemical releases
• Soil erosion
• Loss of sagebrush habitat
• Weed invasion
• Wildlife disturbance
• Loss of cultural resources, including historic
• resources

Aspects
Impacts

• Operating facilities, equipment, and processes
• Managing storm water discharges within the storm
• water corridor
• Performing activities with the potential for
  fugitive
• dust or fugitive emissions
• Conducting open burning
• Applying and storing pesticides
• Applying fertilizer
• Disturbing soils
• Purchasing goods services
• Procuring pesticides
• Reporting cleaning up spills releases

• Create a Wildland Fire Management Committee
• Manage fuel along improved and unimproved roads
• Maintain some unimproved roads as passable to
• 4x4 Wildland Fire equipment
• Provide defensible space around buildings,
• structures, and other sign. support equipment
• Use a staged response to wildland fire
• Use minimum impact suppression techniques in
• direct, indirect parallel wildland fire
  tactics
• Suppress and control dust
• Implement site restoration activities

Work Activities
Actions
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EMS and NEPA

• EMS Elements
• Environmental Aspects
• Work Activities
• Significant Work Activity and Potentially
  Significant Environmental Aspect

• NEPA Values
• Potential Impacts Issues
• Proposed Activities
• Significance Determination, (i.e., CX, EA (FONSI)
  or EIS (ROD)

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Significance?

• Under INLs 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.

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Comparing
EMS
NEPA

• Air pollutants
• Chemical use and storage
• Contaminated site disturbance
• Cultural/historical resource disturbance
• Industrial waste generation and management
• Interaction with wildlife/habitat
• Radioactive waste generation and management
• Surface water and storm water contamination
• Working within areas subject to flooding

• Fugitive dust
• Smoke plumes on vistas
• Downwind radioactive contamination and worker
• and public exposure radioactive and hazardous
• material
• Chemical releases
• Soil erosion
• Loss of sagebrush habitat
• Weed invasion
• Wildlife disturbance
• Loss of cultural resources, including historic
• resources

Aspects
Impacts
No Significant Work Activity
Finding of No Significant Impact

• Operating facilities, equipment, and processes
• Managing storm water discharges within the storm
• water corridor
• Performing activities with the potential for
  fugitive
• dust or fugitive emissions
• Conducting open burning
• Applying and storing pesticides
• Applying fertilizer
• Disturbing soils
• Purchasing goods services
• Procuring pesticides
• Reporting cleaning up spills releases

• Create a Wildland Fire Management Committee
• Manage fuel along improved and unimproved roads
• Maintain some unimproved roads as passable to
• 4x4 Wildland Fire equipment
• Provide defensible space around buildings,
• structures, and other sign. support equipment
• Use a staged response to wildland fire
• Use minimum impact suppression techniques in
• direct, indirect parallel wildland fire
  tactics
• Suppress and control dust
• Implement site restoration activities

Work Activities
Actions
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INLs Environmental Management System
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The End
Contact John Irving John.Irving_at_inl.gov 208.526.8
745 Or Bruce Angle Bruce.Angle_at_inl.gov 208.526.1
841
ftp//ftp.inel.gov
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Benefits
Environmental Enforcement Violations (Numbers
Amounts)
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Tangible Intangible Benefits

• Tangible
• Environmental compliance
• Reduced fines penalties
• Pollution prevention activities
• Intangible
• Environmentally conscious workforce
• Environmental protection
• Continual improvement

Moving beyond compliance
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Significance Determination