George A. Goode and John Selva Environmental & Waste Management Services

1. DOE/EFCOG EMS Workshop – March 8-9, 2005 Lessons Learned from a Maturing EMS George A. Goode and John Selva Environmental & Waste Management Services

2. Lessons Learned from a Maturing EMS - Agenda • BNL Operations Overview • Evolution of BNL’s EMS • Lessons Learned by ISO 14001 Element • What worked? • What didn’t? • Summary of Lessons Learned • Results

3. Brookhaven National Laboratory Mission:Basic and applied research in a variety of scientific fields: Physics, Chemistry, Materials Science Biology, Medicine and forefront technology Facts: Operated by Brookhaven Sciences Associate (BSA) for DOE 3000 employees; 4,000 visiting scientists annually 5,000 acre site located on eastern Long Island, NY

4. BNL MACHINES Collider-Accelerators Relativistic Heavy Ion Collider Alternating Gradient Synchrotron Booster Applications Facility Linear Accelerator National Synchrotron Light Source SCIENTIFIC ACTIVITIES Center for Functional Nanotechnology Medical Research Operations Computational Research Center Material Science Research Bench-top Experiments Environmental Research BNL Facilities, Programs, Operations • FACILITY OPERATIONS • Physical Plant Operations • Sewage Treatment Plant • Central Steam Facility • Major Petroleum Facility • Waste Management Facility • Environmental Restoration • SUPPORT PROCESSES • Radiation Source Material Storage • Machining Operations • Photography • Fleet Operations • Bulk Chemical Distribution Operations

7. Historical Environmental Management • Small, centralized Environmental support organization within Safety & Health Physics Division • Environmental risk overshadowed by health and safety risks • Limited jurisdiction of EPA regulation at federal facilities • Proliferation of regulations exceeded BNL response capability • Staff reactive to “urgent” environmental issues • Scientific staff shielded from regulatory requirements • External communication when and if required by law; limited “marketing” of accomplishments REACTIVE ENVIRONMENTAL MANAGEMENT

8. Achieving Environmental ExcellenceSystematic Approach of ISO 14001 EMS • BNL embarked on a project to implement an ISO 14001 EMS in 1999 • Phased approach • BNL Registered to ISO 14001 standard in 2001 • First DOE National Lab • Key Elements • Unwavering Sr. Mgmt Support • Commitment of resources • Financial and people • “Systems Thinkers” • Robust assessment • Prevention based programs

9. Planning EMS ImplementationKey Decisions: Level of Implementation • Implementation at the Laboratory Level • Benefits: Least documentation, consistency, one management review, consolidated list of aspects, objectives/targets, transparent to line, easier to manage and audit • Drawbacks: Less line involvement and ownership, tends to be “bottled up” in Environmental Dept, fewer focused objectives/targets, little culture change • Implementation at the Directorate Level • Benefits: Less documentation than division level, good ownership and line management involvement, limited number of management reviews, good focused objectives/targets, promotes teamwork and achieves culture change • Drawbacks: More documentation than Lab level, more meetings, less consistent and more difficult to audit • Implementation at the Division Level • Benefits: Most ownership and focus • Drawbacks: Most documentation, least consistent, most difficult to manage/audit

10. EMS Overview:Current Organization Directors Office HR, ITD, OMC HENP BES NSLS EENS Life Sciences F&O CEGPA P&GA Ed Programs Finance ESH&Q RadCon SHSD EWMSD Quality EM CAD Number of EMS Programs at Line Level: 11 (down from 14 originally) All Have EMS Representatives and Core Teams Physics Instrum Magnet

11. Planning EMS ImplementationKey Decisions: Integration • Integrate EMS Elements with existing management systems • Most important and powerful strategy for success • Obtain ownership by other Management System owners Aspects: Work Planning and Control Legal & Other Requirements: SBMS Objectives/Targets: Planning Resources/Roles: Planning and HR Competence/Training: Training Communication: Communication/PR Documentation: Quality Assurance Control of Docs: Quality Assurance Operational Control: Work Planning Emergency Prep: Emergency Mgmt Monitoring/Measuring: Integrated Assessment Evaluation of Compliance: Environmental Nonconformance: Quality Assurance Control of Records: Quality Assurance Internal Audit: Integrated Assessment Management Review: Integrated Assessment

12. Element by Element Review • What worked…what didn’t John Selva, EMS Program Manager Environmental & Waste Management Services Division Brookhaven National Laboratory

13. Policy writers were well versed in BNL operations, ISO language and had full management commitment Policy is direct and to the point Commitments translated well into an acronym (P2C4) Policy reflected real changes (not too lofty) Lots of Posters, Training Aids, and reminders Environmental Policy P2C4 Pollution Prevention Compliance Community Involvement Cleanup Continual Improvement What worked Issues Encountered • Policy awareness fades over time • Frequent reinforcement needed • Heightened attention prior to audits needed • Integration with safety, health, and security blurs message EMS Policy evolved to include Safety, Security and Health

14. Integrated into Work Planning Experimental Safety Reviews ECR involvement a must!!!! Process Assessment Approach Key for routine processes Identified aspects, operational controls, and led to many P2 opportunities. Big $ savings BNL Products not initially addressed Especially “intellectual property” Procedure criteria specific to negative impacts Did not consider positives Criteria may be too focused and may be missing obvious (everyday) aspects Skill of the craft not fully captured Environmental Aspects What worked Issues Encountered P2 Award Winner

15. EMS Manual is very descriptive Lists Key requirements SBMS ROD process Very effective system for capturing lab level requirements Departments can rely on Lab level program Requirements (subject areas) developed by cross-functional teams lead by Subject Matter Expert All significant aspects have subject area to flow requirements to line and guide employees High level of effort to revise a Subject Areas Simple procedures may also do the trick Information overload Legal and Other Requirements What worked Issues Encountered

16. Integration with Lab Planning processes Demonstrates connection to institutional priorities ESH&Q Environmental Priorities Helps line focus on key objectives Divisions personalize EMS with specific O&T’s Well documented using Operational Control Forms and Planning Forms at Division level Use of Self Assessment Plan Feedback at Management reviews – Key Management involvement flowed down into objectives Flowdown not always clear Departments needed to learn how to develop measurable O&T’s (They were often based on routine work) Needed Training Planning could be integrated with existing Self Assessment Program Objectives, Targets and Programs What worked Issues Encountered

17. Objectives, Targets and Programs

18. Created “Agent R2A2’s”, roles documented by procedure Lab Director EMS Representatives 90-Day Area Managers ECRs Operational Controls/Planning Forms force line management to assign responsibility Planning forms identify responsible personnel Flow down to relevant personnel is challenging Employee Reminders needed on E Issues R2A2’s must be E-Specific Supervisors were not playing needed role in delivering message Resources, Roles, Responsibilities and Authorities What worked Issues Encountered

19. Training tailored to ‘need to know’ All Employees: Gen Env Training (Policy, Emergency Response) All Managers: EMS Overview Briefing EMS Representatives: Overview, Obj/Targets, Audits Staff involved with significant aspects: Job Specific Training Contractors: Contractor/Vendor Orientation (Policy, Emergency Response) Web-based CBT Maintaining Awareness is a constant challenge Need constant vigilance (Advertising) Constant reminders by EMS Reps and Lab director Skill of the craft may assume that they understand E issues and may be outside of training systems. This was recognized in recent OHSAS Project Competence, Training and Awareness What worked Issues Encountered

20. Dedicated Communication Staff  Lots of avenues to promote (Bulletin) (Monday Memo) (Interoffice Bulletins) Mature Well established communication with Public Extremely open forums We tell the public everything We offer information rather then wait to be asked Used lots of tools (Posters, Charts, Cards) Policy is posted in obvious places. Hard to communicate to all employees due to the diverse job base. Communication What worked Issues Encountered

21. Major program elements documented in SBMS Helps reduces duplication One Aspects Procedure ISO 14001 elements linked in EMS Manual Serves as good roadmap Tendency to duplicate in Departments still exists Try to stick to common website Opportunities for right sizing Documentation What worked Issues Encountered

22. Web-based documentation Reduces doc control problems Out of date Current revisions Large number of documents, procedures, and forms Lots of opportunities for nonconformance No common Lab-wide system Difficult for auditors to understand Lack of common understanding of what documents need to be controlled Control of Documents What worked Issues Encountered

23. Well addressed through Work Planning Experimental Safety Reviews Process Assessments Non-routine work planning Dedicated forms Provides a road map for Departments Lists environmental records and assigns responsibility Links operating procedures to aspects Distinguishing between Operational Controls Aspects Significant Aspects Tough to manage Facilities and Operations work Assuring the work permit system is implemented Missing Skill of the craft items Operational Control What worked Issues Encountered

24. Integration with existing Emergency Response systems Improved awareness of staff Spill Reporting Effluent monitoring RCRA SPCC Most existing systems meet the intent but must be sure all EMS concerns are addressed Be sure to properly address compliance (spills) issues well. Routine drills must be up to date- will be included in EMS Audits Emergency Preparedness and Response What worked Issues Encountered

25. Lab Level: Leverage the Annual Site Environmental Report Line Level: Use Self Assessment Plan to monitor progress Systems are centralized at the Compliance group level Detailed environmental monitoring plan Dedicated Field Sampling Team Management reviews roll up information for Sr. Managers Line management tendency to not understand where this applies Tendency to use routine requirements as a measure of success Linkage to Significant Aspects Supervisors and EMS Reps needed better training Monitoring and Measurement What worked Issues Encountered

26. BNL ISO 14001 Plus Plus = compliance and community Dedicated procedure requires compliance assessments Targeted Assessments based on past performance and importance Common format and scope Self Assessment process includes compliance Regulatory (external) assessment results well communicated Reliance on other management systems can lead to vulnerabilities Management system owners must take responsibility for implementation effectiveness Results of Self Assessments not rolled up effectively Evaluation of Compliance What worked Issues Encountered

27. Integration with existing systems NCR ORPS Excellent Assessment Tracking System (ATS) Tracks all actions to closure Developed two specialized SOPs Groundwater Contingency Plan Environmental Event Response Effectiveness of corrective actions Fighting the next fire Stigma associated with NCR and ORPS Reluctance to report based on response by DOE and Management Trending not well established Nonconformity, corrective and preventative action What worked Issues Encountered

28. One common procedure Defines what a record is Establishes records inventory One common database of records Variability concerning what constitutes an Environmental record Training required Records storage is not uniform Control of Records What worked Issues Encountered

29. Rolled up to Lab Level Eliminated 14 audits at line level Ensure scope involves line input Documented on audit planning forms Initially used industry experts Helped get system up to speed Now only occasionally use external auditors Trained Internal Staff Line and Environmental staff Share Internal Auditor resources with other Labs Allows staff to see how it’s done at other sites Started out making all departments audit themselves Too many and low quality Awareness of ISO auditing standards ISO 19011 ANSI/ISO 14010 ANSI/ISO 14011 ANSI/ISO 14012 Internal Audit What worked Issues Encountered

30. Lab Level Mgmt Review Reviews major trends and issues with Sr. Mgmt  Department level Mgmt Review Specifically reviews performance Creates very good ownership Good opportunity to show Value  Lots of metrics Tool to document Senior Management input and continual improvement. Hard to maintain focus when things are going well Competing with the issue of the day Multi-level management reviews sometimes considered redundant Slow to get effective input from management Significant improvement as Managers realized the value Management Review What worked Issues Encountered

31. Lessons Learned • Summary of Lessons Learned George A. Goode, Division Manager Environmental & Waste Management Services Division Brookhaven National Laboratory

32. EMS Implementation at BNLLessons Learned • EMS managed as an integrated project • Formal Project Management Plan • Established scope, schedule, cost, tasks, project controls and tracking systems • Tap expertise when designing EMS • Project manager was ISO 14001 expert • Used top consultant to get Sr. Management on board • Implementation Strategy • Decide what level: Lab, Directorate, or Division • Phased implementation using Pilot Project works well • Design for success: Pick a winner to start, celebrate victories, recognize teams • Integrate EMS with Management System Initiatives (ISM, QA, IA) • Tap invaluable resource: People • Systems Thinkers on Team, Pilot process first • Team approach -- increases ownership, innovation, and value • Senior Managers-- unwavering commitment & support

33. EMS Implementation at BNLLessons Learned • Use Web-based systems • Procedure and documentation delivery • Patience…maturation of system takes time • Anticipate “Requisite floundering” stage • Expect resistance to organizational change • Self-Examine, Self-Identify & Self-Correct • Test programs & provide feedback • Minimize external audit costs by minimizing findings - be prepared • Set & prioritize your own improvement agenda • Challenges • Change operations, Change image, Change culture

34. Today at BNL • All BNL facilities, experiments & operations certified to ISO 14001 • Unprecedented knowledge of environmental aspects & comprehensive system to control/minimize impact • EPA Performance Track member • Improving compliance status • Pollution prevention projects saving millions • Survey shows managers believe environmental stewardship important • Openly communicating on issues & progress; highlighting science • Regaining reputation & receiving independent recognition • Awards this year: L.I. Pine Barrens Society Env Stewardship award, EPA Environmental Quality award, White House ‘Closing the Circle’ award, DOE Office of Science ‘Best in Class’ Pollution Prevention award and Stony Brook Univ WRMI Env. Stewardship award

35. Resources Web Resources • P2 Web Page, http://www.bnl.gov/esd/pollutionpreve • EMS Web Page, http://www.bnl.gov/esh/ems/ People Resources • George Goode: goode@bnl.gov, 631-344-4549 • John Selva (EMS): selva@bnl.gov, 631-344-8611 • Bob Lee (Performance Track): blee@bnl.gov, 631-344-3148