EMS / NEPA Integration at the Idaho National Laboratory

1. 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

2. 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

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

4. 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 14001 requirements

5. Status of INL’s 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.

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

7. 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.

8. Not Significant Significant 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. or or Significance Determination

9. Environmental Aspects

10. INL’s Environmental ChecklistCombines EMS & NEPA Elements

11. Purpose of EC • Determine level of environmental review (such as environmental assessment or environmental impact statement. In other words, determine the potential for significant environmental impacts. • Flow down requirements (through instructions from MCP-3480) to the worker.

12. Purpose of EC • Identify new work activities with environmental requirements. • Identify new environmental aspects. • Identify significant environmental aspects of new work activities and develop controls.

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

14. 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

15. 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 . . .

16. 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?

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

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

19. Activity-Based Environmental Compliance System Work Control System DOE Integrated Safety Management System (ISMS) New Work Activity Identification and Change Control System (NEPA) Voluntary Protection Program (VPP) ISO Existing Systems (i.e., Documents, Records, Training, Monitoring, etc. ISO 14001 Registration INL’s Environmental Management System

20. Benefits Environmental Enforcement Penalties (Original Assessed Penalty)

21. 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

22. The End Contact: John Irving John.Irving@inl.gov 208.526.8745 Or Bruce Angle Bruce.Angle@inl.gov 208.526.1841