Integrating Environmental Requirements into a Project Life-Cycle

1. Integrating Environmental Requirements into a Project Life-Cycle Kliss McNeel Director, Environmental and Regulatory Services Steve Birrer Manager, Environmental and Regulatory Services November 29, 2007

2. CH2M-WG Idaho (CWI) Environmental Management System (PDD-1012) • Environmental Management System (EMS) integrates environmental principles into company work planning and execution as a part of the Integrated Safety Management System (ISMS) • Program is based on the five key elements of ISO 14001 integrated into the five core functions of ISMS. • Ensures environmental requirements receive adequate consideration in all aspects of a project’s life cycle. • CWI EMS is ISO 14001 Registered • Completed in December 2005 • Successfully completed four semi-annual surveillance audits (most recently October 2007) • Reviewed during DOE-HQ ISMS Phase II verification and DOE-HQ Independent Oversight Audit (November 2006 and June 2007, respectively) All audits have concluded that the CWI EMS is effective and well implemented

3. ISMS / EMS Integration of Policies, Procedures EMS Key Elements ISMS Core Functions • ICP Contract • Environmental Policy (POL-104) Environmental Policy & Commitment • Environmental Objectives and Targets (PDD-1012) • Activity Level Hazard ID (PRD-25) • Hazard Identification Analysis (MCP-3562) • Environmental Aspects (LST- 96) • Environmental Checklist (451.01) • Environmental Instructions for Facilities (PRD-5030, MCP-3480, PRD-4001) Define Work Analyze Hazards Planning • Integrated Safety ManagementSystem (PDD-1004) • Hazard Identification Analysis (MCP-3562) • Integrated Work Controls (STD-101) • Management and Operations (PDD-1005) • Environmental Permits (MCP-9109) • Emergency Mgmt. (PLN-114) • Environmental Instructions (MCP-3480) • Activity specific work orders, CERCLA O&M plans, TPRs Develop Controls Implementation Perform Work • ICARE, Non Conformance Corrective Actions (MCP-598) • Environmental Assessment Program (LST-202 & PLN-2106) • Performing Independent Assessments (MCP-552) Checking & Corrective Action Provide Feed Back • Environmental Program Metrics (PLN-2106) • ES&H Performance Measurement Analysis & Reporting (PDD-155) • Executive Safety Review Board (CTR-161) Management Review

4. Environmental Organization Maintains Program and Supports the Line Organization in Implementation • Environmental organization has technical resources and functional support that maintain the procedural driven program • Maintain the EMS program as defined in company manual • Procedures updates • Self assessments • Support to area project managers and PEL’s • Communication with regulators, area project managers and other contractors • Environmental organization structure supports line organizations and provides defense in depth through project environmental leads (PEL) • PEL is matrixed to line organization • Review of planning phase requirements, environmental checklist development, and review of implementing work packages • Conduct daily oversight from initial design to final facility disposition to ensure environmental requirements are met • Key in day to day interface with project

5. Assessments, Surveillances, Regulatory inspections, etc. Assessments, Surveillances, Regulatory inspections, etc. ICP Environmental Requirements and Implementation Regulations & Statutes Negotiated Requirements Agreements, Consent Orders, Reports & Contract Milestones R E Q U M T S • Site Treatment Plan • FFA/CO • Settlement Agreement • Voluntary Consent Order • NON Consent Order • Regulatory Required Reports • Contract • Statutes • Federal Regulations • State Regulations • Local Ordinances • DOE Orders • Permits • FFA/CO Documents • EE/CA’s • RCRA Closure Plans I M P L E M E N T Environmental Management System (e.g., PDD 5030 and MCP-3480) Implementation (CERCLA O&M, Permit Matrix, etc.) Life Cycle Baseline (level 3, 4, and/or 5) MCP-3562 STD-101 MCP-3562 STD-101 Perform Work (Work Packages, TPR’s, Round Sheets, etc.) Perform Work (Work Packages, TPR’s, Round Sheets, etc.) CHECK & REVIEW Monthly Project Review Environmental Support Staff Environmental Support Staff Weekly Inspection Form Review E&RS Milestone and Commitment Database Requirements Database

6. Example: Typical Requirements Flowdown (INTEC WLAP Sampling)

7. Major Contract Milestones are EMS Objectives and Targets • Objectives taken directly from the contract and defined in the CWI Project Management Plan • Ensures focus is on the priorities established by DOE and includes all federal, state and local agreements and regulations • Approved by the ICP Executive Safety Review Board (ESRB) and typically will not change for the duration of the contract • Targets chosen from key activities identified in the schedule baseline for each FY • Approved by the ESRB prior to the start of the FY • Focus is on critical work scope to be performed in each FY • Status is reviewed on a quarterly basis – ensure priorities are correct and aligned with current DOE and regulatory agencies focus • Targets are for defined work scope with established environmental requirements as defined in the planning process

9. Integrated Waste Treatment Unit FY 08 Objectives and Targets

10. TAN/RTC/PBF FY08 Objectives and Targets

11. Incorporating Environmental Requirements in Upfront Design Minimizes Changes and Resultant Schedule Impacts • Assigned a PEL to Integrated Waste Treatment Unit project (treatment of the remaining highly radioactive mixed waste in the tank farm) from the outset; environmental included in all design reviews • Used the EC process to identify potential environmental hazards to drive mitigation within the design • Incorporated environmental requirements in initial Technical and Functional Requirements document • Sets the design parameters for environmental compliance • Involved regulatory agencies well upfront on plans for permitting strategy and environmental compliance All environmental authorizations (e.g., permits) obtained in a timely manner to support start of construction.

12. CWI has not received a regulatory fine/penalty in over three years while undergoing 18 regulatory compliance inspections. Completed substantial cleanup including the demolition of two major facilities that had significant radiological and hazardous waste issues Engineering Test Reactor: Initial rad levels inside reactor were 1200 R/hr; grouted reactor weighed 112 tons and was disposed of as contact handled low level waste; over a million pounds of lead had to be removed from the reactor building. Test Area North Hot Shop Complex: total activity exceeded 75 curies; three concurrent RCRA closures; physically large structure with 7 foot thick shielding walls Work Completed Safely and Ahead of Schedule are Outcomes of Effective EMS and ISMS Integration Both facilities were completed significantly ahead of schedule and under budget!

13. Conduct a self-assessment program as an integral part of the EMS Monitor performance as a part of the CWI ESH&QA performance measurement process Monitor and report performance metrics to DOE as a part of the annually agreed to Safety, Performance, Objectives, Measurements, and Commitments process Active participation in Energy Facility Contractor Group Environmental Management Subgroup Developed an integrated ISMS/EMS/VPP/Worker Safety Program toolbox Continuous Improvements are Key to Success

14. Integration Occurs at Every Level of the Idaho Cleanup Project • Definition of the project scope and schedule outlined in contract and driven by regulatory commitments • Early involvement by environmental professionals in project planning, identification of hazards and mitigation implementation, feedback and improvement is key • EMS objectives and targets directly linked and aligned with work scope and priorities. • Metrics and work scope commitments are integrated • ISMS and EMS are the same system in ICP • Integration at every level of the program; work control, training, communication, feedback