ISO 14000 Implementation at NUWC Keyport Dean Kohn NUWC Keyport

1. I’m Dean Kohn. the Environmental Director at NUWC Keyport. Keyport is now ISO14000 Certified within the fenceline (our phase 1 effort) This is an overview of our effort and some lessons learned that may help you implement your EMS.I’m Dean Kohn. the Environmental Director at NUWC Keyport. Keyport is now ISO14000 Certified within the fenceline (our phase 1 effort) This is an overview of our effort and some lessons learned that may help you implement your EMS.

2. What is ISO 14000? ISO14000 is really a series of separate standards. The primary standard and the one which we will be registered to is ISO 14001. ISO14000 is really a series of separate standards. The primary standard and the one which we will be registered to is ISO 14001.

3. ISO 14001 Definition of an EMS As we mentioned before, ISO14001 is the defining specification for an EMS. It goes on to say that there are 5 main parts to an EMS 1) Policy 2) Planning 3) Implementation & Operation 4) Checking & Corrective Action 5) Management Review These 5 parts form the continual improvement cycle of ISO14000As we mentioned before, ISO14001 is the defining specification for an EMS. It goes on to say that there are 5 main parts to an EMS 1) Policy 2) Planning 3) Implementation & Operation 4) Checking & Corrective Action 5) Management Review These 5 parts form the continual improvement cycle of ISO14000

4. ISO 14001 Elements Here are all of the 17 required elements for an EMS as defined by ISO14001. We’ll reference these elements in our overview of how Keyport is implementing ISO14000.Here are all of the 17 required elements for an EMS as defined by ISO14001. We’ll reference these elements in our overview of how Keyport is implementing ISO14000.

5. Our Approach to ISO 14000 ISO14000 is non-prescriptive, Our implementation is unique to us Use the KISS principle, Make use of what already exists Get a professional “Gap Analysis”. Knowing your deficiencies enables you to start planning We tied ours to ISO 9000 to make use of that existing structure to avoid duplicating effort. ISO14000 is non-prescriptive, Our implementation is unique to us Use the KISS principle, Make use of what already exists Get a professional “Gap Analysis”. Knowing your deficiencies enables you to start planning We tied ours to ISO 9000 to make use of that existing structure to avoid duplicating effort.

6. ISO 9000/14000 Schedule Keyport’s implementation of ISO14000 will be in 3 phases: Phase 1 was completed in CY02 and encompasses mission processes within the Keyport fenceline. Phase 2 is scheduled for CY03 and adds Bangor annex & the range. Phase 3 is scheduled for CY04 and adds the detachments. Implementation is aimed to coincide with the expansion of ISO 9000 in FY03 to all parts of Keyport. Where possible, common areas will share procedures and databases. Keyport’s implementation of ISO14000 will be in 3 phases: Phase 1 was completed in CY02 and encompasses mission processes within the Keyport fenceline. Phase 2 is scheduled for CY03 and adds Bangor annex & the range. Phase 3 is scheduled for CY04 and adds the detachments. Implementation is aimed to coincide with the expansion of ISO 9000 in FY03 to all parts of Keyport. Where possible, common areas will share procedures and databases.

7. How We Addressed ISO 14001 Elements The first and overarching element we addressed was our environmental policy.The first and overarching element we addressed was our environmental policy.

8. We took our existing policy and modified to meet the ISO requirements We reduced it in size to make it simpler to remember (Since all employees have to be aware of it !) We linked it to our mission We added specific commitments to Continual Improvement and Pollution Prevention We posted on the intranet and internetWe took our existing policy and modified to meet the ISO requirements We reduced it in size to make it simpler to remember (Since all employees have to be aware of it !) We linked it to our mission We added specific commitments to Continual Improvement and Pollution Prevention We posted on the intranet and internet

9. How We Addressed ISO 14001 Elements Planning elements were addressed by… Planning elements were addressed by…

10. Determine Aspects We developed a process to address environmental aspects. While this is tailored for Keyport, the concept can be applied anywhere. The goal was to take out most of the guess work and make a process that was not reliant on a particular person for repeatability. One common problem you hear with Aspect development is that you can waste a lot of time if you don’t “stay out of the weeds”. This method helped us do that!We developed a process to address environmental aspects. While this is tailored for Keyport, the concept can be applied anywhere. The goal was to take out most of the guess work and make a process that was not reliant on a particular person for repeatability. One common problem you hear with Aspect development is that you can waste a lot of time if you don’t “stay out of the weeds”. This method helped us do that!

11. Aspect Rating We developed an Aspect rating form that examines processes, presence of key aspects, and rates environmental interaction. The form is broken into 4 main areas. We start by identifying the process, location, and process owner. We track whether or not the process is already ISO9000 controlled because we knew that made documentation easier. ABNORMAL conditions were evaluated for some processes where we felt the most impact could occur.We developed an Aspect rating form that examines processes, presence of key aspects, and rates environmental interaction. The form is broken into 4 main areas. We start by identifying the process, location, and process owner. We track whether or not the process is already ISO9000 controlled because we knew that made documentation easier. ABNORMAL conditions were evaluated for some processes where we felt the most impact could occur.

12. Aspect Rating ASPECTS – This part of the form is simply check marks to indicate whether some main aspects (Hazardous Material Use, Resource/Energy Use, Releases to Environment, or Bulk Storage of Hazardous Liquid/Gas) are present and need to be considered during scoring. ASPECTS – This part of the form is simply check marks to indicate whether some main aspects (Hazardous Material Use, Resource/Energy Use, Releases to Environment, or Bulk Storage of Hazardous Liquid/Gas) are present and need to be considered during scoring.

13. Aspect Rating ENVIRONMENTAL IMPACTS – This area is the heart of the scoring system. Each category is given a numerical score (positive or negative) based upon criteria developed at Keyport. The categories were chosen to examine process interaction with the environment, process compliance, operator safety, and likely community sentiment. The criteria limits/thresholds were based upon typical values seen when examining the processes (e.g. amount of hazardous waste generated). Scoring criteria is contained in the process documentation. Category scores were weighted to represent relative importance (e.g. Maximum scores in “Health/Safety” versus “Other Resource Use” are almost an order of magnitude higher.) ENVIRONMENTAL IMPACTS – This area is the heart of the scoring system. Each category is given a numerical score (positive or negative) based upon criteria developed at Keyport. The categories were chosen to examine process interaction with the environment, process compliance, operator safety, and likely community sentiment. The criteria limits/thresholds were based upon typical values seen when examining the processes (e.g. amount of hazardous waste generated). Scoring criteria is contained in the process documentation. Category scores were weighted to represent relative importance (e.g. Maximum scores in “Health/Safety” versus “Other Resource Use” are almost an order of magnitude higher.)

14. Rating Criteria (Example) This is an example of a category rating criteria for Wastewater. Notice the scoring goes from positive to negative with environmental impact and/or complexity, risk, or cost. Thresholds are built in to reduce assumption. The scoring should be repeatable by different people. Score keeping induces improvement, since waste reduction or lowering toxicity reduces score for the next cycle and may move a process out of the top 20%This is an example of a category rating criteria for Wastewater. Notice the scoring goes from positive to negative with environmental impact and/or complexity, risk, or cost. Thresholds are built in to reduce assumption. The scoring should be repeatable by different people. Score keeping induces improvement, since waste reduction or lowering toxicity reduces score for the next cycle and may move a process out of the top 20%

15. Aspect Rating SCORING/COMMENTS – This area is a summation of all of the numerical scores from the ENVIRONMENTAL IMPACT area, multiplied by a number representing frequency of operation to yield a total weighted score that is representative not only of the environmental aspects associated with the process but also weighted to account for number of hours of operation. SCORING/COMMENTS – This area is a summation of all of the numerical scores from the ENVIRONMENTAL IMPACT area, multiplied by a number representing frequency of operation to yield a total weighted score that is representative not only of the environmental aspects associated with the process but also weighted to account for number of hours of operation.

16. Aspect Rating Results (Top 10) This list represents about half of the top 20% of processes (Top 20% was chosen to be our significant aspects) sorted by weighted total. These processes are our significant ones for this period. The Process evaluation will be revised once a year. In our case, approximately at the start of the fiscal year. For an example of how this works, The plating plant will always be at the top of the list because 1) It uses large quantities of hazardous material 2) It generates large quantities of hazardous waste 3) It uses a lot of resources (Electricity and water) 4) Its air releases require an air permit and source testing 5) Its water releases are part of our IWTP permit 6) It has a large, outside, bulk waste tank This list represents about half of the top 20% of processes (Top 20% was chosen to be our significant aspects) sorted by weighted total. These processes are our significant ones for this period. The Process evaluation will be revised once a year. In our case, approximately at the start of the fiscal year. For an example of how this works, The plating plant will always be at the top of the list because 1) It uses large quantities of hazardous material 2) It generates large quantities of hazardous waste 3) It uses a lot of resources (Electricity and water) 4) Its air releases require an air permit and source testing 5) Its water releases are part of our IWTP permit 6) It has a large, outside, bulk waste tank

17. Legal Requirements Another element of PLANNING is Legal Requirements. Environmental legal drivers, from Local, State or Federal regulations all create demands of the Environmental Management System and must be tracked to ensure their requirements are meet. Another element of PLANNING is Legal Requirements. Environmental legal drivers, from Local, State or Federal regulations all create demands of the Environmental Management System and must be tracked to ensure their requirements are meet.

18. Determine Legal Requirements We handled legal requirements by documenting them in the REFERENCES section of our environmental directives. This ties them to the local implementing procedure and makes them visible to the users. The actual legal requirements are available as links off the environmental webpage. Since the directives require annual review, update will not be an issue. We handled legal requirements by documenting them in the REFERENCES section of our environmental directives. This ties them to the local implementing procedure and makes them visible to the users. The actual legal requirements are available as links off the environmental webpage. Since the directives require annual review, update will not be an issue.

19. Determine Objectives & Targets For Objectives & Targets we borrowed from existing programs We considered strategic targets We used P2 Goals We used our Environmental Protection Group to implement We used EQA Findings And ISO goals too! For Objectives & Targets we borrowed from existing programs We considered strategic targets We used P2 Goals We used our Environmental Protection Group to implement We used EQA Findings And ISO goals too!

20. Targets Targets came from our objective areas. Typical sources for targets are Strategic thrust areas Compliance Pollution Prevention Concerns from Interested parties Targets came from our objective areas. Typical sources for targets are Strategic thrust areas Compliance Pollution Prevention Concerns from Interested parties

21. Management of Targets (Example) Here is a list of our typical targets. These targets were chosen to be meaningful, But we also chose targets that were readily achievable so that the external auditors could see progress and we could achieve ISO14000 registration. GREEN shaded targets are complete. YELLOW shaded targets are behind. Targets without colors are being tracked but are not yet due. Target status is tracked monthly at Environmental Protection Group meetings Here is a list of our typical targets. These targets were chosen to be meaningful, But we also chose targets that were readily achievable so that the external auditors could see progress and we could achieve ISO14000 registration. GREEN shaded targets are complete. YELLOW shaded targets are behind. Targets without colors are being tracked but are not yet due. Target status is tracked monthly at Environmental Protection Group meetings

22. How We Addressed ISO 14001 Elements Implementation & Operation elements were addressed by… Implementation & Operation elements were addressed by…

23. EMS Documentation For EMS documentation we again Tried to keep it simple, by using existing documentation We tied to ISO 9000 Documentation We linked to the ISO 14000 elements for clarity Most importantly we built an “ISO TREE” which served as a road map for our documentation effortFor EMS documentation we again Tried to keep it simple, by using existing documentation We tied to ISO 9000 Documentation We linked to the ISO 14000 elements for clarity Most importantly we built an “ISO TREE” which served as a road map for our documentation effort

24. OurISO 14000Road Map We made use of the existing environmental documentation structureWe made use of the existing environmental documentation structure

25. OurISO 14000Road Map We added new environmental documentation to interleave the ISO RequirementsWe added new environmental documentation to interleave the ISO Requirements

26. OurISO 14000Road Map We used common procedures with ISO 9000. Three major ones being: Management Review Corrective and Preventative Action AuditingWe used common procedures with ISO 9000. Three major ones being: Management Review Corrective and Preventative Action Auditing

27. OurISO 14000Road Map We used existing documentation in crossover areas such as Public Affairs for external communication control Safety procedures addressing Emergency Drills and Action PlansWe used existing documentation in crossover areas such as Public Affairs for external communication control Safety procedures addressing Emergency Drills and Action Plans

28. OurISO 14000Road Map Lastly, we linked to the ISO elements so: 1) Auditing is simplified 2) We knew when we had all elements addressedLastly, we linked to the ISO elements so: 1) Auditing is simplified 2) We knew when we had all elements addressed

29. How We Addressed ISO 14001 Elements Checking and Corrective action was largely addressed by … Checking and Corrective action was largely addressed by …

30. Checking & Corrective Action Using the ISO 9000 common procedures.Using the ISO 9000 common procedures.

31. Environmental Operational Control Environmental Operational Control means there has to be documentation to control the environmental impact of processes. First as a refresher you remember whatever you do in your job. Your process has an environmental impact. Here you see a typical process Let’s look at the areas which need environmental operational control This operational control is provided in directive KPT5090-17-03Environmental Operational Control means there has to be documentation to control the environmental impact of processes. First as a refresher you remember whatever you do in your job. Your process has an environmental impact. Here you see a typical process Let’s look at the areas which need environmental operational control This operational control is provided in directive KPT5090-17-03

32. Environmental Operational Control Why did we develop KPT5090-17-03? There are thousands of procedures on station. Instead of revising all of them, it made sense to have only one. Why did we develop KPT5090-17-03? There are thousands of procedures on station. Instead of revising all of them, it made sense to have only one.

33. What’s in the Operational Control Procedure Roles & Responsibilities References to Environmental Requirements gathered together in one place. Definitions What’s in KPT5090-17-03? It has Roles & Responsibilities for everyone. It has references to all the applicable environmental directives It also contains some key definitions What’s in KPT5090-17-03? It has Roles & Responsibilities for everyone. It has references to all the applicable environmental directives It also contains some key definitions

34. Emergency Planning Emergency planning is Proactive. Spill Prevention Planning Emergency Action Plan so you know YOUR role! Response drillsEmergency planning is Proactive. Spill Prevention Planning Emergency Action Plan so you know YOUR role! Response drills

35. How We Addressed ISO 14001 Elements Management Review was covered by …Management Review was covered by …

36. Management Review Management Review is accomplished by Keyport’s Board of Directors to provide feedback on the EMS and set Targets. They review 4 areasManagement Review is accomplished by Keyport’s Board of Directors to provide feedback on the EMS and set Targets. They review 4 areas

37. Management Review (Audit Results) Here you see the a reporting tool for management. Results of auditing in stoplight colors ISO elements on the side (including the three in common with 9000) 6 audits across the top GA=Gap Analysis I1=Internal audit 1 I2=Internal audit 2 I3=Internal Audit 3 E1=External Pre-certification Inspection I4=Internal Audit 4 GREEN indicates good progress. YELLOW indicates minor deficiencies during the last audit(s). RED indicates major deficiencies during the last audit(s). Here you see the a reporting tool for management. Results of auditing in stoplight colors ISO elements on the side (including the three in common with 9000) 6 audits across the top GA=Gap Analysis I1=Internal audit 1 I2=Internal audit 2 I3=Internal Audit 3 E1=External Pre-certification Inspection I4=Internal Audit 4 GREEN indicates good progress. YELLOW indicates minor deficiencies during the last audit(s). RED indicates major deficiencies during the last audit(s).

38. Management Review (Example Targets) Here is a example of a target review with management using typical targets. These targets were chosen to be meaningful, But we also chose targets that were readily achievable so that the external auditors could see progress and we could achieve ISO14000 registration. GREEN shaded targets are complete. YELLOW shaded targets are behind. Targets without colors are being tracked but are not yet due. Target status is tracked monthly at Environmental Protection Group meetings Here is a example of a target review with management using typical targets. These targets were chosen to be meaningful, But we also chose targets that were readily achievable so that the external auditors could see progress and we could achieve ISO14000 registration. GREEN shaded targets are complete. YELLOW shaded targets are behind. Targets without colors are being tracked but are not yet due. Target status is tracked monthly at Environmental Protection Group meetings

39. Management Review (Outside Concerns) Since the EMS was established we have documented 3 concerns from outside parties: At the last review we discussed #1. DOE would like all plating plant owners to reduce waste. We are participating in a DOE sponsored learning forum to look for improvement, We have included a waste reduction project in the targets.Since the EMS was established we have documented 3 concerns from outside parties: At the last review we discussed #1. DOE would like all plating plant owners to reduce waste. We are participating in a DOE sponsored learning forum to look for improvement, We have included a waste reduction project in the targets.

40. Management Review (Suitability) Some questions here to promote discussion with management as far as suitability. Are we covering the ISO14001 elements? Are targets appropriate (strategic, compliance, P2)? Is BOD compliance awareness being improved? Is overall environmental condition being improved? Is compliance standing being improved?Some questions here to promote discussion with management as far as suitability. Are we covering the ISO14001 elements? Are targets appropriate (strategic, compliance, P2)? Is BOD compliance awareness being improved? Is overall environmental condition being improved? Is compliance standing being improved?

41. Add slides identifying where management support is needed the most! A lead in to areas where the EMS needs management helpA lead in to areas where the EMS needs management help

42. TrainingExamples Examples of training methodologies used at NUWC Keyport: On-line Awareness refers to a 15 minute streaming media all-hands training video. Badge-size wallet cards were distributed to promote the policy and employee roles. ISO posters with the policy and POCs were hung in work areas. A contractors guide is required reading for all contractors. Shop office visits were used to fully deploy the information. Gate handouts were used the last week to ensure everyone got some more information as well as promoting the actual certification attempt date. We also made use of articles in our monthly newsletter “Keynotes” to keep awareness up. Examples of training methodologies used at NUWC Keyport: On-line Awareness refers to a 15 minute streaming media all-hands training video. Badge-size wallet cards were distributed to promote the policy and employee roles. ISO posters with the policy and POCs were hung in work areas. A contractors guide is required reading for all contractors. Shop office visits were used to fully deploy the information. Gate handouts were used the last week to ensure everyone got some more information as well as promoting the actual certification attempt date. We also made use of articles in our monthly newsletter “Keynotes” to keep awareness up.

43. Here you see the a timeline for EMS implementation Month 00 – Started the effort, established the team, team basic ISO 14000 training Month 03 – Gap Analysis, POA&M, Aspects, Objectives & Targets, Documentation Month 06 – Rolling out to all hands & Upper management Month 09 – Start of Internal Audits Month 12 –External pre-certification audit (Keyport familiarity, documentation audit) Month 15 – External certification audit (Mostly process/personnel audits) Here you see the a timeline for EMS implementation Month 00 – Started the effort, established the team, team basic ISO 14000 training Month 03 – Gap Analysis, POA&M, Aspects, Objectives & Targets, Documentation Month 06 – Rolling out to all hands & Upper management Month 09 – Start of Internal Audits Month 12 –External pre-certification audit (Keyport familiarity, documentation audit) Month 15 – External certification audit (Mostly process/personnel audits)

44. ISO14000 & Interrelationships This is a flow diagram of the ISO14000 Plan/Do/Check/Act cycle You can see the Internal roles BOD sets Policy, oversees planning and conducts mgt reviews Middle Mgt and Shops are involved in Implementation and checking Internal Auditors verify the entire cycle You can also see the External roles NAVSEA guides Policy Regulators and laws establish requirements Public has input on our stewardship during operations External Auditors verify the entire cycle You can also see the ISO9000 common areas of Auditing, CAPA, and Management Review This is a flow diagram of the ISO14000 Plan/Do/Check/Act cycle You can see the Internal roles BOD sets Policy, oversees planning and conducts mgt reviews Middle Mgt and Shops are involved in Implementation and checking Internal Auditors verify the entire cycle You can also see the External roles NAVSEA guides Policy Regulators and laws establish requirements Public has input on our stewardship during operations External Auditors verify the entire cycle You can also see the ISO9000 common areas of Auditing, CAPA, and Management Review

45. What We Have Gained Now we start a series of slides just to give quick program overviews. First, Environmental Management We work toward integrating goals from multiple sources Report to the BOD and the Captain Review projects from across the station for environmental aspects Work on spreading awareness across the station Perform comparisons seeking improvement (regional teams, success stories) Liaison with regulators and Region Manage for best results (Balance compliance, risk, and mission).Now we start a series of slides just to give quick program overviews. First, Environmental Management We work toward integrating goals from multiple sources Report to the BOD and the Captain Review projects from across the station for environmental aspects Work on spreading awareness across the station Perform comparisons seeking improvement (regional teams, success stories) Liaison with regulators and Region Manage for best results (Balance compliance, risk, and mission).

46. Lessons Learned Best advice on lessons learned Get lead auditors training and do it early Do a gap analysis, build your draft system, then fine tune it with management Build a “Road Map” Build a POA&M Management has a role from the start Best advice on lessons learned Get lead auditors training and do it early Do a gap analysis, build your draft system, then fine tune it with management Build a “Road Map” Build a POA&M Management has a role from the start

47. Questions ??