EMS / NEPA Integration at the Idaho National Laboratory Bruce Angle & John Irving Battelle Energy Alliance Idaho National Laboratory Environmental Management System Workshop March 8-9, 2005

The INL … Located in Eastern Idaho 890-square mile reservation Managed by Battelle Energy Alliance for the DOE Lies within the upper Snake River Plain sagebrush steppe ecosystem Several major facilities High mountain desert ecosystem known for its cultural and natural resources The major laboratory activities: Nuclear energy research and engineering National security technology development

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

INL’s Perspective The NEPA Process at the INL is part of the INL’s Environmental Management System The EMS is fully integrated into INL’s Integrated Safety Management System EMS is patterned after ISO requirements

Status of INL’s EMS Meets EO & DOE Order 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 registration.

EMS and NEPA EMS Elements Environmental Aspects Work Activities Significant Work Activity Potentially Significant Environmental Aspect NEPA Values Potential Impacts & Issues Proposed Activities Significance Determination, (i.e., CX, EA (FONSI) or EIS (ROD)

Significance? Under INL’s 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.

Significance Determination The activity, or the operation has little discernible impact on local ecology, including air, water, soil, groundwater quality, and biological receptors. Little or no remedial action is required to address releases to the environment or other environmental damage. (A release to secondary containment in a building is not considered to be significant.) The activity has short term or minor impacts to local ecology that are fully recoverable. Remedial action is required to address releases to the environment or other environmental damage. (A release to secondary containment in a building is not considered to be significant.) The activity has a major, long- term or permanent impact to local ecology. Long-term or major remedial action is required to address releases or other environmental damage. Release to the environment from these activities or sources are a major contributor to regional problems. Not SignificantSignificant or

Environmental Aspects

INL’s Environmental Checklist Combines EMS & NEPA Elements

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

Purpose of EC 4.Identify new environmental aspects. 5.Identify significant environmental aspects of new work activities and develop controls. 3.Identify new work activities with environmental requirements.

Environmental Checklist / Sec. A Provide Descriptive Information –Charge Number –INL / ICP –Project Title –Performing Organization –...

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

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... Environmental Checklist / Sec. C

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?

Environmental Checklist / Sec. E Conditions: Are conditions required before starting project? –APADs (Air Permitting) –Cultural Resource Clearance –Biological Resource Clearance –Other approvals

Environmental Checklist / Sec. F Determine the Level of Environmental Review (or Documentation) –Categorical exclusion –Environmental assessment –Environmental impact statement...

Work Control System DOE Integrated Safety Management System (ISMS) Activity-Based Environmental Compliance System New Work Activity Identification and Change Control System (NEPA) Voluntary Protection Program (VPP) Existing Systems (i.e., Documents, Records, Training, Monitoring, etc. ISO Registration ISO INL’s Environmental Management System

Benefits Environmental Enforcement Penalties (Original Assessed Penalty)

Tangible & Intangible Benefits of an EMS / NEPA Process Tangible –Environmental compliance –Reduced fines & penalties –Pollution prevention activities –Integration with other systems such as NEPA Intangible –Environmentally conscious workforce –Environmental protection –Continual improvement Moving beyond compliance

The End Contact: John Irving Or Bruce Angle