Integrating EMS / NEPA at the Idaho National Laboratory

1. Integrating EMS / NEPA at the Idaho National Laboratory John S. Irving NAEP Workshop - Integrating NEPA into EMSs April 16, 2005

2. 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.

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 Five 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 Sites Environmental Management System • The EMS is fully integrated into the Sites 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. Air Pollutants Asbestos Emissions Biological Hazards Chemical Use and Storage Contaminated Sites Disturbance Cultural/Historical Resource Disturbance Discharge to Wastewater Systems or Groundwater Drinking Water Contamination Hazardous/Mixed Waste Generation and Management Hazardous/Radioactive Material or Waste Handling and Transportation Industrial Waste Generation and Management Interaction with Wildlife/Habitat Managing Property and Materials PCB Contamination Radioactive Materials Use and Storage Radioactive Waste Generation and Management Storage of Hazardous/Rad. Materials or Waste in Tanks Surface Water and Storm Water Contamination Use, Reuse and Recycling of Resources Work within areas Subject to Flooding INL Environmental Aspects

7. Air Pollutants** Asbestos Emissions Biological Hazards Chemical Use and Storage** Contaminated Sites Disturbance** Cultural/Historical Resource Disturbance Discharge to Wastewater Systems or Groundwater** Drinking Water Contamination Hazardous/Mixed Waste Generation and Management** Hazardous/Radioactive Material or Waste Handling and Transportation** Industrial Waste Generation and Management Interaction with Wildlife/Habitat Managing Property and Materials** PCB Contamination Radioactive Materials Use and Storage** Radioactive Waste Generation and Management** Storage of Hazardous/Rad. Materials or Waste in Tanks** Surface Water and Storm Water Contamination** Use, Reuse and Recycling of Resources Work within areas Subject to Flooding** INL Environmental Significant Aspects

8. Environmental Aspects Significant Environmental Aspects Operational Control Equipment Key Characteristics Monitoring Procedures Monitoring Equipment 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

9. Working within a floodplain … Drinking water contamination Chemical Use & Storage X X X General vs Specific Work Activities Cultural/Historical Resource Dis.. General Constructing or modifying drinking water systems

10. Suface Water/Storm Water Con… Contaminated Site Disturbance Hazardous/Mixed Waste Gen… X S S General vs Specific Work Activities Cultural/Historical Resource Dis.. Specific Managing mixed waste in the tank farm

11. DOE’s NEPA Checklist INL Environmental Checklist DOE NEPA Checklist

12. 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.

13. 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.

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

15. 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

16. 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 . . .

17. 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?

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

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

20. 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

21. Wildland Fire Management at the Idaho National Laboratory … … Assignment? STOP

22. 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

23. 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) EMS and NEPA

24. 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.

25. 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

26. 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

27. The End Contact: John Irving John.Irving@inl.gov 208.526.8745 Or Bruce Angle Bruce.Angle@inl.gov 208.526.1841 ftp://ftp.inel.gov

28. Benefits Environmental Enforcement Violations (Numbers & Amounts)

29. Tangible & Intangible Benefits • Tangible • Environmental compliance • Reduced fines & penalties • Pollution prevention activities • Intangible • Environmentally conscious workforce • Environmental protection • Continual improvement Moving beyond compliance

30. 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