Using the Directives Process to Track EMS Requirements

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Using the Directives Process to Track EMS
Requirements

• Department of Energy
• EMS Training Workshop
• Columbus, OH
• March 7-8, 2005

Daniel L. McCollum, Quality Assurance
Manager National Energy Technology Laboratory
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4.3.2 Legal and Other Requirements

• The organization shall establish and maintain a
  procedure to identify and have access to legal
  and other requirements to which the organization
  subscribes, that are applicable to the
  environmental aspects of its activities, products
  and services.
• ISO 140011996 Standard

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Implementation Philosophy

• Use existing process where they work
• Build separate process if needed
• Converge the multiple processes later if possible
• ? What process exists that could be used to
  maintain the list of legal and other requirements?

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History

• Worksmart Standards
• Identified all legal, DOE, consensus standards
  which applied to NETL
• ISM
• Converted WS standards to ISM-related standards
• EMS
• Use of ISM identified standards and their
  relation to EMS called the FOCUSED STANDARDS
  LIST

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Focused Standards List

• DOE Directives
• Other DOE Requirements
• Executive Orders
• Federal laws/regulations
• State laws/regulations
• Local ordinances
• ESH References (consensus) Standards

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The Challenge How to Maintain the FSL?

• Bi-weekly regulatory updates
• OSHA
• EPA
• DOE
• State/Local/Reference Standards
• Rely on the program manager who is the subject
  matter expert
• Relationships with local regulators
• Directives Process
• References and requirements are captured in
  directives

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Directives Process

• Four Tiers of documents
• Tier 1 Policy
• Orders
• Notices
• Tier 2 Strategy/Implementation
• Operating Plans
• Procedures
• Tier 3 Operational Control
• Standard Operating Procedures
• Tier 4 EMS Records
• Forms
• Other records

Directives Process
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Example

• 450.1, Environmental Management System
• 450.1-1, Environmental Media Release Management
• 450.1-1, Ambient Air Quality Management
• 450.1-2, Groundwater Quality Management
• 450.1-3, Surface Water Quality Management
• 450.1-4, Industrial Wastewater Management
• 450.1-5, Spill Prevention and Control
  Management
• 450.1-9, Waste Handling, Storage and Disposal
• 450.1-10, Waste Minimization, Pollution
  Prevention, and Recycling Program

POLICY
STRATEGY
IMPLEMENTATION
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Reference Section

• In each directive (order/notice, operating plan,
  procedure)
• DOE Directives (orders, policy, manuals, guides)
• Regulations (state, local, CFR, USC)
• Consensus standards (ANSI, ASME)
• This makes up the universe of our legal and other
  requirements for all ESH programs

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Groundwater Procedure
3. REFERENCES. a. DOE Order 225.1, Accident
Investigations. b. DOE Order 231.1,
Environmental, Safety and Health Reporting.
c. DOE Order 414.1, Quality Assurance. d. DOE
Order 450.1, Environmental Protection Program.
e. NETL Order 450.1, Environmental Management
System (EMS). f. NETL Operating Plan 151.1-1,
Comprehensive Emergency Management System. g.
NETL Operating Plan 450.1-1, Environmental Media
and Release Management. h. NETL Operating
Plan 450.4-1, Integrated ESH Management Plan.
i. NETL Procedure 151.1-1, Comprehensive
Emergency Management System Administration.
j. NETL Procedure 421.1-1, RD Safety Analysis
and Review System.
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Groundwater Procedure
k. Statutory ESH Standards (1) 33 U.S.C.
1251, Federal Water Pollution Control Act, as
amended. (2) 42 U.S.C. 300, Safe Drinking
Water Act, as amended. (3) 40 Code of Federal
Regulations (CFR) 141, National Primary Drinking
Water Regulations. (4) 40 CFR 142, National
Primary Drinking Water Regulation
Implementation. (5) 40 CFR 143, National
Secondary Drinking Water Regulations. (6)
Pennsylvania Clean Streams Law (35
691.1-691.801). (7) Pennsylvania Act 610,
Water Well Driller License Act. (8) West
Virginia Code, Chapter 16, Article 1, Series III,
Water Well Design Standards. (9) West
Virginia Code, Chapter 20, Article 5A, Water
Pollution Control Act. (10) West Virginia
Code, Chapter 20, Article 5M, West Virginia
Groundwater Protection Act. (11) West
Virginia Code, Chapter 22, Article 6, Section 19,
Continuance During Life of Well Dry and
Abandoned Wells. (12) WV Title 33 Code of
State Rules, Series 23 (33 CSR 23), Groundwater
Protection Standard. (13) WV 46 CSR 12,
Requirements Governing Groundwater Standards.
(14) WV 47 CSR 55, Groundwater Protection Act Fee
Schedule. (15) WV 47 CSR 58, Groundwater
Protection Regulations. (16) WV 47 CSR 59,
Monitoring Well Regulations. (17) WV 47 CSR
60, Monitoring Well Design Standards.
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Groundwater Procedure
l. DOE Policy ESH Standards (1) Executive
Order 12088, Federal Compliance With Pollution
Control Standards, 10/13/78. m. References
(1) Groundwater Protection Management Plan at
NETL-Pittsburgh (2) Groundwater Protection
Management Plan at NETL-Morgantown (3)
Handbook for Analytical Quality Control in Water
and Wastewater Laboratories, (EPA-600/4-79-019)
, latest edition, EPA. (4) Handbook for
Sampling and Sample Preservation of Water and
Wastewater, (EPA-600/4-76-049), latest
edition, EPA. (5) Methods for Chemical
Analysis of Water and Wastewater, U.S. EPA
Technology Transfer (1974). (6) Standard
Methods for the Examination of Water and
Wastewater, Sixteenth Edition APHA, AWWA,
WPCF, current edition. (7) Test Methods for
Evaluating Solids Waste - Physical/Chemical
Methods, SW-846, 3rd Edition, U.S. EPA. (8)
PADEP Groundwater Monitoring Guidance Manual,
current edition.
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The Process
Directive is created by subject matter expert
Directive is approved by approving authority
Entered into Tracking System
FSL is updated
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Tracking System
Number Title References
151.1 Comprehensive Emergency Management System DOE Order 151.1A, Comprehensive Emergency Management System
231.1 Environment, Safety, and Health Reporting DOE Order 231.1, Environment, Safety, and Health Reporting.DOE Manual 231.1-1, Environment, Safety, and Health Reporting Manual.DOE Manual 231.1-2, Occurrence Reporting and Processing of Operations Information.
440.1 Safety and Health Program DOE Order 440.1, Worker Protection Management for DOE Federal and ContractorEmployees.DOE Policy 450.1, Environment, Safety and Health Policy.DOE Policy 450.5, Line Environment, Safety and Health Oversight.DOE Policy 454.1, Use of Institutional Controls.NETL Order 421.1, Safety Analysis and Review System.NETL Order 450.1, Environmental Management System (EMS).NETL Order 450.4, NETL Integrated Safety Management Program.NETL Operating Plan 440.1-1, Industrial Hygiene and Occupational Medicine Program.NETL Operating Plan 440.1-2, Chemical Hygiene Program.NETL Operating Plan 440.1-3, Construction and Maintenance Safety.NETL Operating Plan 440.1-4, General Workplace Safety Program.NETL Operating Plan 440.1-5, Fire Protection Program.NETL Operating Plan 440.1-6, Indoor Air Quality and Ventilation Operating Plan.NETL Operating Plan 450.4-1, Integrated ESH Management Plan.DOE F 5484.3, Individual Accident/Incident Report.Statutory ESH Standards(1) 29 CFR 1910, Occupational Safety and Health Standards.(2) 29 CFR 1910.119, Subpart H, Process Safety Management of Highly HazardousChemicals.(3) 29 CFR 1926, Safety and Health Regulations for Construction.(4) 29 CFR 1960, Federal Occupational Safety and Health Program.
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Example

• New Water Quality Standard is issued
• 40 CFR XXX
• Directive is revised
• 450.1-2, Groundwater Quality Management
• References Section is updated to include new
  standard
• Directive is entered into tracking system
• FSL is updated
• Includes hyperlink to new standard, if available
• Order hardcopy if hyperlink is not available

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Lessons Learned

• The FSL meets ISO 14001 requirements
• Forces the SME to be more judicious in choosing
  references
• Each one must be tracked
• Used an existing process to meet a new need
• One contractor maintains the directives process
  and the FSL
• Virtually no additional cost
• FSL is accurate and timely