U.S. EPA Region 6
EMS Lab & Field Operations Manual
Region 6
10625 Fallstone Road
Houston, Texas 77099
CD "7:
15®3
PRO^°
Environmental Management System Manual
Version EM-01
Control No.: HL EM-01
1/10/2005
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EMS Manual
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U.S. EPA Region 6
Region 6 Lab & Field Operations
HL EM-01: Environmental Management System Manual
(Version EM-01)
Approvals:
Daniel Young, EMS Coordinator
Date
Richard McMillin, Deputy Branch Chief
Date
Douglas A. Lipka, Branch Chief Date
Disclaimer: This Manual has been prepared solely for use by or under the supervision of
experienced EPA Region 6 personnel. Independent professional judgment must be exercised
when data or recommendations set forth in this guide are applied. This manual was developed
and written by the Region 6 lab & field operations EMS Coordinator, D.L. Young. Ph.D.
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Table of Contents
Section 1—Introduction to EMS Manual 5
Section 2—Organization Scope and Characteristics 13
Section 3—Environmental Policy 14
Section 4—EMS Procedures 15
Section 5—EMS Programs and Controls 69
Section 6—EMS Records 107
Section 7—EMS Definitions 108
Section 8—EMS References 109
Section 9—Appendices 110
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Section 1 — Introduction to EMS Manual
1. Purpose of EMS Manual
This Environmental Management System Manual serves as a repository for documentation
related to the Environmental Management System (EMS) including:
• EMS Procedures that describe how to carry out key tasks within the EMS such as
training, identifying environmental aspects, or managing records.
• Programs & Controls that operate under the EMS, such as programs for achieving EMS
objectives and targets and carrying out audits.
• EMS Records or directions that enable Individuals to locate appropriate records that
confirm the completion of specific EMS activities such as, the identification of
environmental aspects, EMS training that has been given to specific employees, or the
completion of management reviews.
• Definitions, References, and Appendices that contain additional information useful to
Individuals reviewing the EMS.
2. EMS Manual Maintenance
This EMS Manual is maintained by: Region 6 Laboratory, SHEM Manager. The formal version
of this EMS Manual is located: Within the office of the SHEM Manager. This EMS Manual was
updated on: September 21, 2007. (An electronic version is available to all employees located at
the Houston Lab on the Shared LAN directory).
In addition to the sequence of charts created — Significant Aspects, Objectives and Targets, the
EMS Manual holds documentation of the environmental management programs, the operational
controls, the EMS audit programs and procedures, all other EMS procedures, EMS records and
other descriptive information useful to anyone being introduced to the EMS or to those
responsible for the EMS.
3. EMS Implementation at the Region 6 lab & field operations.
EMS implementation Start date: July 2001
EMS implementation Completion date: December 2005
3.1 EMS Implementation
EPA's mission is to protect human health and safeguard the natural environment by setting
standards for environmental protection, assisting others in reducing or preventing pollution,
conducting environmental research and enforcing environmental protection standards in
conjunction with other government agencies.
In support of that mission, proper management of the environmental impacts of our own
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operations and facilities is essential. EPA continues to encourage regulated entities to use
effective environmental management systems that focus on compliance, pollution prevention,
and public outreach.
With this policy, EPA is committing to implement EMS's with these attributes for our own
employees, operations and facilities at the Region 6 lab & field operations. EPA Region 6 will
endeavor to become a leader in executing a model environmental management system within the
Agency.
At EPA, Region 6 lab & field operations, we commit to reduce the environmental impacts and
consumption of natural resources from our facility operations and comply with all legal and
applicable requirements. Our environmental management system (EMS) will be designed to
meet the following goals:
• Ensure compliance by meeting or exceeding all applicable environmental requirements;
• Strive to continuously improve environmental performance in terms of both regulated
and unregulated environmental impacts (e.g., energy and water conservation);
• Employ source reduction and other pollution prevention approaches whenever
practicable;
• Require consideration of environmental factors when making planning, purchasing and
operating decisions;
• Establish, track and review specific environmental performance goals; and
• Share information on environmental performance with the public and allow appropriate
opportunities for input into EMS development and implementation.
4. Background to Environmental Management Systems
Formal Environmental Management Systems (EMS) emerged in the early 1990s to provide
organizations with a proactive, systematic approach for managing the potential environmental
consequences of their operations. Such systems have been widely adopted by industry and
government and have been effective at improving regulatory compliance and environmental
performance.
In April 2000, President Clinton signed Executive Order (E.O.) 13148, "Greening the
Government through Leadership in Environmental Management" that established a 5-year EMS
implementation goal for all Federal Facilities. President Bush and the current administration
have supported this position. The U.S. Environmental Protection Agency (EPA), as the principle
steward for the environment, has taken a leadership position by developing an EMS
implementation initiative.
4.1 EMS Description
Although several recognized EMS frameworks exist, most are based on the International
Organization for Standardization's ISO-14001 EMS standard. As a result, ISO-14001 is the
framework on which organizations most frequently choose to base their EMS, and this is proving
to be the case with U.S. federal facilities. The Region 6 lab & field operations has chosen this
framework for implementation at the Region 6 lab.
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1. Phase 1: Planning
The organization identifies how its operations might harm the environment, and develops
methods to reduce this harm.
2. Phase 2: Doing
The organization implements these methods to reduce harm and operates them for a
designated time period.
3. Phase 3: Checking
The organization assesses whether the methods that it is operating to reduce environmental
harm and ensure regulatory compliance are proving to be effective.
4. Phase 4: Acting
The organization determines what changes are necessary based on the performance
assessment of the methods (see Phase 3) designed to reduce environmental harm.
The findings of Phase 4 may indicate that adjustments to methods already in place are necessary
or that entirely new methods are needed to achieve established environmental objectives. Output
from this phase is fed back into Phase 1 Planning, to make necessary changes and additions
designed to bring the EMS to the desired level of effectiveness. This system feedback propels
the continual improvement of the EMS.
The EMS continually moves through this cycle, fine-tuning its management of those areas of the
organization's operations that harm the environment. This "continual improvement cycle" is a
core tenet of the EMS; it allows the system to adapt to the dynamic nature of the organization's
operations.
5. Structure and key elements of the EMS
5.1. EMS Scope
The U.S. EPA Region 6 lab & field operations
Environmental Management System (EMS) is
designed to manage the environmental impacts that
result from the operations at the facility and, to a
limited extent, off-site field activities. All of the
operations conducted at the facility located at 10625
Fall stone Road, Houston, Texas 77099 as well as
field operations conducted with mobile labs as well as
enforcement activities are considered within the
scope of the EMS. The activities of all of the
occupants of the facility are subject to the policies
and procedures described in this manual. The Region
6 lab & field operations EMS is designed to conform
to the international standard ISO 14001 (1996).
Environmental Management Systems -
Specification With Guidance For Use. This
Figure 1: IS014001 EMS Model
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procedure applies to all EPA and contractor personnel working at the Region 6 lab & field
operations Region 6 facility.
5.2. Environmental Policy
The Environmental Policy verbalizes the organization's commitment to be environmentally
responsible. The content of the environmental policy is aspirational, evoking the degree of
commitment by top management and serving as a beacon to influence the behavior and actions
of all members of the organization to high achievement for environmental protection.
(For additional information and a copy of the organization's environmental policy, see Section 3.)
5.3. Planning
EMS planning activities determine the environmental aspects and impacts of the work conducted
at the Region 6 lab & field operations. Environmental Management Programs (EMPs) are
designed to control and reduce, where possible, the impacts associated with the identified
aspects.
5.3.1. Environmental Aspects
The organization's interactions with the environment are its environmental aspects. Reviewing
all the activities, products and services of the organization and assessing the possibility of each
of them to have an environmental impact identify these interactions. It is important to recognize
that these impacts may be positive or negative and that the organization should set objectives to
increase positive impacts and reduce negative impacts. The organization can then develop
programs to manage the environmental aspects they believe are significant either to the
environment or to the organization. .
(For additional information and a description of the approach taken to identify significant environmental
aspects, see Section 4, A.)
5.3.2. Legal and Other Requirements
An EMS recognizes that certain environmental aspects are significant for an organization
because they impinge upon certain legal or other requirements, which can affect the
organization's ability to carry out its mission. These may include federal and state requirements,
industry standards, or organizational standards.
(For additional information and a description of the approach taken to identify legal and other requirements, see
Section 4, B.)
5.3.3. Objectives and Targets
Objectives and targets are established to address each of the Region 6 lab & field operation's
significant environmental aspects and are integrated at all levels and functions of the entity.
Objectives and targets are set by considering, in part, the legal and other requirements, the views
of interested parties, as well as, technological, financial and other operational considerations.
This ensures that objectives and targets are robust, that they respond to legitimate concerns, that
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they are realistic for the organization, and that it is possible to develop strong management
programs to achieve them.
(For additional information and a description of the approach taken to set objectives and targets, see Section 4,
C.)
5.3.4 Environmental Management Programs (EMPs)
Environmental management programs serve to achieve Region 6 lab & field operation's
objectives and targets, and are therefore linked directly to them. EMPs contain details on the
resources (e.g., financial, human, and technological) and timeframes to accomplish the objectives
and targets. They contain information describing the approaches and strategies for achieving
objectives and targets, as well as the performance indicators, the operational controls, the roles
and responsibilities to accomplish tasks, and the competency of Individuals to accomplish those
tasks. The EMP ties many elements of the EMS together (e.g., significant aspects, objectives and
targets, resources, responsibilities, and capabilities) and provides an integrated view of the
disparate requirements in the EMS.
(For additional information and a description of the approach taken to create EMPs, see Section 4, E.)
5.4. Implementation and Operation
5.4.1. Roles, Authorities and Responsibilities
Roles and responsibilities for activities under the EMS must be clearly defined and as stated
above, many of these appear in the EMPs. While an EMS is largely sustained by the voluntary
participation and commitment of members of the organization, certain duties are assigned with
clear roles and responsibilities and with attendant accountability for performance and results. For
example, top management must appoint a management representative to be responsible for
leading the creation, implementation, and maintenance of the EMS. Other roles are assigned to
members at various levels and functions throughout the organization where significant
environmental aspects are present.
(Additional information regarding roles, authorities and responsibilities is provided in Section 4, F, J, Q, and R.)
5.4.2. EMS Coordinator
An EMS Coordinator will be appointed each year to ensure that implementation of EMS
processes and compliance with EO 13148 is maintained. The EMS Coordinator is responsible for
reviewing and updating this manual each July. The EMS coordinator reports directly to the
Administrative Team on ALL EMS processes and directs the activities of the EMS programs at
the Region 6 lab & field operations. EMS Team leaders submit reports, plans, proposals, and
like item through the EMS coordinator for approval prior to the EMS coordinator presenting
them to the Administrative Team for Approval.
The SHEM Manager at the Houston Lab will serve as EMS Coordinator and will ensure that
EMS implementation continues and personnel are continually trained in the EMS processes. It is
highly encouraged that EMS Committee/Team leader positions are rotated annually. EMS
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Coordinators shall be provided access to the EMS folder on the Shared directory and ensure that
all EMS documents are continually maintained.
5.4.2. Training, Awareness, and Competence
An EMS requires two types of training: general awareness, and competence training. General
awareness training for all employee's focuses on the importance of the environmental policy, the
role of employees, and the potential consequences of failing to provide environmental care.
Competence training is prescribed for members that work in proximity to significant
environmental aspects and focuses on the possible significant impacts of those aspects, their
specific roles and responsibilities, the objectives and targets for those aspects, and the
operational controls in place to avert the actualization of the potential impacts. Competence
training is detailed in the EMPs and in the documentation of operational controls. The EMS
Coordinator ensures that both types of training are conducted as appropriate to satisfy these
requirements.
(For additional information and a description of the approach taken to identify EMS training needs, see Section
4, F.)
5.4.3. Communication
Clearly, effective integrated environmental management demands effective communications to
coordinate staff internally and to liaise with external stakeholders. Maintaining employee
awareness of EMS initiatives, motivating them, and supplying them with knowledge of their
roles and responsibilities all require communication. It is also true that communication is a two-
way process; that employees can make recommendations to management and give their views
when necessary.
One must remember that views of interested parties should be considered in the EMS. This
means that there must be effective two-way communication between external stakeholders and
the facility. Interested parties should be able to communicate their views to the facility, and the
facility should be able to respond to these parties.
(For additional information and a description of the approach taken to provide internal and external
communications, see Section 4, J, K and L.)
5.4.4. EMS Documentation
It is important that the organization maintain information that would allow someone with a
legitimate interest in the EMS to understand how it is designed and implemented. This
information is essential for employees who need to know about an EMS issue, as well as for
external parties such as customers, regulators, registrars and other interested parties. In many
cases the EMS Manual will fulfill this documentation requirement. However it is likely that
some documents will be maintained outside the EMS Manual in which case they must be
referenced in the Manual.
(For additional information regarding documentation, see Section 4, N and O.)
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5.4.5. Document Control
Due to the wide variety of documents used in the EMS it is essential that a formal approach be
developed to control and organize them. This document control procedure must ensure that the
documents being used are the most up-to-date versions. This includes removing obsolete
documents from circulation.
(For additional information and a description of the approach taken to provide document control, see Section 4,
N.)
5.4.6. Operational Control
It is important to control those actives, products or services that might cause a deviation from the
organization's environmental policy or result in significant impacts. These controls are designed
to support the achievement of EMS objectives and targets. An operational control is a specified
engineering or administrative measure implemented to reduce the risk that an impact will occur.
Operational controls are included as integral components of the EMPs. Because of their volume,
they may be physically separated from the EMP but must be referenced in such instances with a
pointer in the EMP.
(For additional information and a description of the approach taken to provide operational controls, see Section
4,D.)
5.4.7. Emergency Preparedness and Response
The EMS provides a systematic method to manage known and expected elements of the
organization's operations. However, despite best efforts there is the possibility of unpredictable
accidents and emergencies. Those that are predictable should have been addressed in the EMS
through the EMPs and the operational controls. The organization's emergency preparedness and
response plan provides for the unexpected. From the perspective of the EMS, it is necessary that
measures be included in this plan to address the environmental consequences of such
occurrences. It is expected that such measures work to control and mitigate those possible
environmental consequences.
(For additional information and a description of the approach taken to provide emergency preparedness and
response, see Section 4, G.)
5.5. Checking and Corrective Action
5.5.1 Monitoring and Measurement
Monitoring and measurement is fundamental to the EMS, it ensures that management plans;
controls, and training are effective. Furthermore, it enables the organization to identify its
progress toward achieving objectives and targets, and the reasons for its level of achievement.
Without effective monitoring and measurement it is imposable to continually improve which is
the basis of the EMS. Organizations are required to periodically monitor performance,
operational controls, and general conformance with EMS objectives and targets.
(For additional information and a description of the approach taken to provide monitoring and measurement, see
Section 4, I)
5.5.2. Nonconformance and Corrective and Preventive Action
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When an organization identifies a weakness in the EMS or an ineffective part thereof it needs to
initiate and effect a correction. The EMS requires a procedure to receive, document and
investigate problems, understand their root causes, and then implement corrective actions that
prevent recurrence.
(For additional information and a description of the approach taken to provide monitoring and measurement, see
Section 4, P.)
5.5.3. Records
While it is critical to effectively implement and carry out all the various elements of the EMS, it
is also important to be able to demonstrate that you have done so. This is done through the
creation and management of records of various implementation activities and other EMS results
from training, audits and management reviews.
All relevant records for the Region 6 lab & field operations EMS can be located on the Region 6
shared directories, see records section in: "A. EMS Procedure for Identifying Significant
Environmental Aspects"
(For additional information and a description of the approach taken to provide records, see Section 4, O.)
5.5.4. EMS Internal Audits.
EMS audits test whether the system has been implemented and maintained as designed.
Importantly, they are not compliance audits. The reason to look at compliance data during an
EMS audit, for example, is not to test the organization's regulatory posture, but rather to test
whether the programs (EMPs) that have been implemented are actually working as they were
intended to work to achieve and maintain compliance.
(For additional information and a description of the approach taken to provide for EMS internal audits, see
Section 4, Q.)
5.6. Management Review.
The EMS reserves a special role for top management, as well it should. Not only must they
formulate and articulate the environmental commitments of the organization in the
environmental policy, they must also render judgment on whether the EMS continues to be
suitable, adequate and effective. This is accomplished through the periodic management review
that affords them the opportunity to judge the EMS and its results. On that basis, they are then
expected to make decisions relative to the EMS so that it continues to perform and deliver as
expected.
(For additional information and a description of the approach taken to provide for management review, see
Section 4, R)
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Section 2—Organization Scope and Characteristics
Organizational Mission
Dedicated to serve the Region 6 EPA mission and workforce with highly skilled and culturally
diverse workers; using the best available resources, and innovative and effective management
solutions. The Region 6 Laboratory provides environmental analytical services for regional
programs and serves as a source of scientific expertise for national and regional regulatory and
executive decisions. In addition, laboratory personnel perform evaluations and audits of
environmental monitoring laboratories and public water supply laboratories. Management of the
Contract Laboratory Program, including sample scheduling, sample routing, data verification,
data validation, and data usability, are also responsibilities of Region 6 lab & field operations.
Facility Description
Total number of employees:
68
Total number of buildings:
2
Square footage of facility:
42632
Property acreage:
4.5
Site boundaries:
F al 1 stone/Brookl et/Wi 1 crest/Stancl ift
Activities that occur outside site
boundaries:
Field sampling, mobile lab work, enforcement
activities
Approximate number of employees whose
activities may involve significant aspects:
68
Size of EMS team:
8
Composition of EMS team:
4 (lab, QA, SHEM, admin)
Environmental Hazards
The Region 6 lab & field operations utilizes current technology to reduce or eliminate potential
environmental hazards from entering the region 6 ecological areas. Fume hoods, waste
reduction, chemical reduction techniques, field procedures, as well as other procedures (e.g.,
CHP, SPPCP, OEAP) are followed to ensure environmental risks are mitigated at their source.
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Section 3 — Environmental Policy
ENVIRONMENTAL POLICY STATEMENT
EPA's Region 6 Laboratory
Environmental Management System Implementation Policy
At EPA Region 6 Laboratory in Houston, Texas, we commit to reduce the environmental
impacts and consumption of natural resources from our facility operations and comply with all
legal and applicable requirements. Our environmental management system (EMS) will be
designed to meet the following goals:
• Ensure compliance by meeting or exceeding all applicable environmental requirements;
• Strive to continuously improve environmental performance in terms of both regulated and
unregulated environmental impacts (e.g., energy and water conservation);
• Employ source reduction and other pollution prevention approaches whenever practicable;
• Require consideration of environmental factors when making planning, purchasing and operating
decisions;
• Establish, track and review specific environmental performance goals; and
• Share information on environmental performance with the public and allow appropriate
opportunities for input into EMS development and implementation.
To monitor our environmental performance regularly through rigorous evaluations.
¦ We will conduct annual environmental performance reviews with top management.
¦ We will conduct other environmental reviews periodically as suggested by the Environmental Management
System Team.
To seek to prevent pollution before it is produced, reduce the amount of waste at our facility, re-use
and recycle whenever possible, and support pollution prevention by our customers and suppliers.
¦ We will participate in pollution prevention programs and develop related reports that can be shared within our
facility and with others.
To communicate and reinforce this policy throughout our organizations.
¦ We will develop communications strategies that are designed to ensure that employees and others who use our
facilities have an appropriate understanding of the environmental management policy.
¦ We will share our environmental management successes and progress with all organizations at the Region 6 lab
& field operations.
In addition to our annual review of Region 6 lab & field operation's progress on environmental goals
and adherence to this policy, we invite interested parties to provide us with input on this policy
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Section 4—EMS Procedures
Introduction
Section 4 contains all the organization's EMS procedures. Each procedure describes the methodology
used by Region 6 lab to execute various elements of an integrated EMS. The purpose of these
procedures is to enable Individuals within the Region 6 lab & field operations to understand the
requirements of the EMS and to ensure a reliable and consistent execution of those requirements for an
effective system. Section 4 contains the authorized verbatim version of these procedures. Copies may
be distributed to each relevant function and level in the organization so that they are available to those
Individuals that need to reference them.
EMS Procedures
1. Significant Environment Aspects
2. Legal and other Requirements
3. Obj ectives and Targets
4. Environmental Management Programs
5. Operational Controls
6. Environmental Training of Employees
7. Emergency Preparedness and response
8. Tracking Environmental Performance
9. Calibrating Monitoring and Measuring Instruments
10. Internal Communications
11. Responding to External Interested Parties
12. External Communications of Significant Aspects
13. Communicating with suppliers and Contractors
14. Document Control
15. Records Management
16. Addressing Non-Conformances
17. EMS Audit Procedures
18. Management Review
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A. EMS Procedure for Identifying Significant Environmental Aspects
Purpose
Environmental Aspect - Element of an organization's activities, products or services that can interact
with the environment (ISO 14001:1996). Significant Environmental Aspects are determined through
an open and participative process. The purpose of this procedure is to ensure that all environmental
aspects and impacts from region 6 laboratory activities, products, and/or services are accounted for and
included in the EMS, and to provide a method for prioritizing environmental aspects in region 6
laboratory to focus on controlling and improving those deemed "significant".
Scope
This procedure applies to all activities, products, and services that are internal to and under the control
of EPA's Region 6 lab & field operations. The U.S.EPA Region 6 lab & field operations
Environmental Management System (EMS) is designed to manage the environmental impacts that
result from the operations at the facility and, to a limited extent, off-site field activities. All of the
operations conducted at the facility located at 10625 Fallstone Road, Houston, Texas 77099 are
considered within the scope of the EMS. The activities of all of the occupants of the facility are subject
to the policies and procedures described in this manual. The Region 6 lab & field operations EMS is
designed to conform to the international standard ISO 14001 (1996). Environmental Management
Systems - Specification With Guidance For Use. This procedure applies to all EPA and contractor
personnel working at the Region 6 lab & field operations Region 6 facility.
Definitions
Environmental Aspect: Element of an organization's activities, products, or services, that can interact
with the environment (ISO 14001:1996).
Environmental Impact: Any change to the environment, whether adverse or beneficial, wholly or
partially resulting from an organization's activities, products, or services (ISO 14001:1996). The
relationship between aspects and impacts is largely one of cause and effect.
Approach
The Region 6 lab & field operations staff were asked to list the facility activities that impact the
environment. The EMS Team collected the ideas of the staff, added additional ideas and then described
the specific impacts from the identified activities. The specific aspects of the activities that lead to
environmental impacts are listed for each activity. Process Maps were developed to help determine
Significant Environmental Aspects as well as document processes that impact other aspect areas (see
appendix 1 for an example Process Map).
1. The environmental aspects and significant environmental aspects for region 6 lab & field
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operations are determined through an open process. Each member of the EMS Team is
responsible for identifying activities, products and/or services associated with their functional
area (i.e., office, department) that impact or may impact the environment, (i.e., environmental
aspects). In addition, the EMS Team as a whole identifies any further environmental aspects
that may derive from other region 6 lab & field operations activities, products, or services. In
each case the environmental impact(s) associated with the aspect are identified.
2. EMS Team members share an initial list of activities, aspects, and impacts within their
department and modify the list based on this input. EMS Team members then use the
individual lists to create a consolidated list of activities, aspects, and potential impacts for the
facility as a whole.
3. The EMS Advisory Committee who may call on additional knowledge or expertise from within
the Agency reviews the list of activities, aspects, and potential impacts.
4. The EMS Team uses two significance criteria for assessing potential impacts by considering (a)
the probability an aspect would result in an impact and (b) the potential value of addressing the
aspect. In addition, any activity, product, or service addressed by legal or other requirements is
considered significant in accordance with EPA-wide EMS policy.
5. The EMS Team applies the significance criteria by rating each aspect as low, medium, or high
against each criterion, and then making a final determination as to whether each aspect is
significant. The final determination is based on an overall assessment of the information
available about each aspect.
6. The activities and aspects are reviewed by the EMS Team regularly (on an annual basis or in
response to significant changes) to ensure that the information is current. On an informal basis,
the EMS Team is responsible for ensuring that new activities, products, or services are reviewed
for their potential to result in new environmental aspects. This is achieved through general
EMS awareness training and broad understanding among Region 6 lab & field operations staff
of the concept of environmental aspects. Changes or modifications to the current list of aspects
are updated and communicated on a continuing basis.
The EMS Team has determined the following to be the significant environmental aspects associated
with Region 6 lab & field operations activities:
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I ji\iionmcntal Aspect Significance Ciitci'ia
High significance descriptor
Legal or other requirement
Existing Region 6 lab & field operations program
Aggregate of impacts is significant and/or EMS Team determines need for significance
When the significance criteria are applied to the body of knowledge regarding activities, aspects,
impacts, legal requirements, any inquiries received from external parties, and existing Region 6 lab &
field operations programs, the result is the determination of significant aspects.
The EMS Team has determined the following significant environmental aspects:
Significant 1-n\ iionmental
Aspects
Associated Acli\ ities
Associated l-n\ iionmental
Impacts
Waste Reduction
Recycle ALL waste
Air Emissions
Energy Conservation
Reduce energy usage
Air Emissions
Water Conservation
Reduce water consumption
None
Noise Emissions*
Reduce Noise
None
Air Emissions
Reduce Air Emissions
None
Chemical Management
None
None
This table can be used in awareness building to remind everyone what the ultimate impact of the SEAs
have on the environment. By creating this awareness it will focus people's attention on things they can
do to ultimately prevent the impacts of concern.
Impacts are analyzed by the EMS Team and EMS Committee's and given a rating for two conditions:
likelihood of the impact occurring and magnitude of the impact should it occur. The descriptors
"high", "medium", and "low" are used to describe both conditions. The EMS Team bases this analysis
on the collective experience of the team members and, to a limited extent, on environmental
performance data. Descriptor pairs in the following manor to determine those with the highest potential
impact then sort the results of the impact analysis:
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1 liuli Significance
Medium Significance
Low Significance
Impact Descriptor Pairs -
H, H
H, L
L, L
Likelihood and Magnitude
M, H
M, M
M, L
H, M
L, H
L, M
Those environmental aspects that have activities and related impacts that are described with the high
significance descriptors, are considered significant aspects. There are three additional criteria that are
used to determine significant aspects. The full list of significance criteria is below:
Risk
Significant
Waste Generation
H,M
Yes
Energy Conservation
H,M
Yes
Water Usage
H,M
Yes
Noise Emissions*
L,L
Yes
Air Emissions
H,M
Yes
Chemical Management
H,M
Yes
The aspect analysis is reviewed by the EMS Team on a regular basis (at least annually) to ensure that
the information is up-to-date and to determine whether the scope of significant aspects has changed.
New developments and new or modified activities, products, and services are considered during the
regular review. (Be prepared to demonstrate that new developments and new or modified activities,
products, and services have been screened for potential significance and that activities, products, and
services of suppliers and contractors have been screened for significance.)
*After an intensive investigation of noise emissions it was determined not to be an SEA.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories listed below:
S: XEnvironmental Management Systems \
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B. EMS Procedure for Identifying Legal and Other Requirements
Purpose
The legal and other requirements that apply to the EMS are a combination of federal and state statutes,
federal executive orders, and internal EPA policies. The purpose of this procedure is to identify all
environmental laws, regulations, and "other requirements" that apply to the Region 6 lab & field
operations. This helps ensure that the Region 6 lab & field operations maintains an ongoing internal
awareness of, and provides access to, all legal and other requirements that apply to its activities,
products, and services. In addition, this procedure ensures that the EMS development process as a
whole is informed by awareness of all applicable mandates. Finally, the documentation of applicable
legal, regulatory, and other requirements enables internal and external reviewers to quickly ascertain
the scope of legal and other requirements the facility is operating under.
Scope
The focus of this procedure is on the Region 6 lab & field operations activities, products, and services
that impact or may impact the environment and the legal or other requirements that apply to such
activities, products and services. Legal and other requirements that apply to the Region 6 lab & field
operations EMS can include federal statutes, state statutes (Texas), statutes in Houston, TX, local laws,
Presidential Executive Orders, Region 6 lab & field operations, and internal Agency policies. This
procedure applies to all activities, products, and services that are internal to and under the control of the
Region 6 lab & field operations. The U.S.EPA Region 6 lab & field operations Environmental
Management System (EMS) is designed to manage the environmental impacts that result from the
operations at the facility and, to a limited extent, off-site field activities. All of the operations
conducted at the facility located at 10625 Fallstone Road, Houston, Texas 77099 are considered within
the scope of the EMS. The activities of all of the occupants of the facility are subject to the policies
and procedures described in this manual. The Region 6 lab & field operations EMS are designed to
conform to the international standard ISO 14001 (1996). Environmental Management Systems -
Specification With Guidance For Use. This procedure applies to all EPA and contractor personnel
working at the Region 6 lab & field operations Region 6 facility.
Definitions
Laws and Regulations: Federal, state, and local laws and regulations that apply to or otherwise
impact facility operations.
Other Requirements: In addition to meeting all applicable legal and regulatory requirements many
facilities are subject to "other requirements " contained in Agency policy directives and guidance,
Presidential Executive Region 6 lab & field operations, or other similar mandates. Facilities may also
be committed to certain actions as a result of their participation in voluntary programs related to the
environment
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SHEMD: The Safety, Health, and Environmental Management Division within the HQ Office of
Administrative Services. SHEMD provides regulatory compliance support to EPA facilities nationwide
including the Region 6 lab & field operations
SFPB: The Sustainable Facilities Practices Branch within the Office of Administrative Services. SFPB
provides support on non-regulatory environmental mandates and voluntary improvement programs to
EPA facilities nationwide, including the Region 6 lab & field operations. This support focuses
primarily but not exclusively on mandates established through various Presidential Executive Region 6
lab & field operations.
Approach
Legal and other requirements are determined for all aspects that then provide an indication of
significance. Environmental programs are in place to ensure that compliance is maintained for federal
and state statutes and that progress toward significant compliance with federal executive orders, and
internal EPA policies is achieved.
The registry of legal and other requirements is maintained and reviewed annually by the Safety Health
and Environmental Management (SHEM) Manager. While the line management of the Region 6 lab &
field operations has ultimate responsibility for environmental compliance, the SHEM Manager has
responsibility for conducting environmental compliance activities. The SHEM Manager relies on
information gained through the network of national EPA SHEM Managers and other sources to ensure
that the appropriate compliance requirements are identified. In addition, EPA Headquarters' Safety
Health and Environmental Management Division perform a tri-annual compliance audit with assistance
from an independent contractor. The SHEM Manager based on the findings of the tri-annual audits
(Based on the SHEM Manager audits you would have the list of legal and other requirements
applicable to the Region 6 lab & field operations. Also this headquarters audit is a good procedure to
review the applicable regulations on an annual basis and keeping the EMS team aware of any changes
in the applicable regulations.) Coordinates corrective actions. If necessary, the Region 6 lab & field
operations Board, the Facility Manager and/or the SHEM Manager initiate and complete required
corrective actions. The SHEM Manager is responsible for all records pertaining to environmental
compliance.
The following steps illustrate how the EMS Team identifies the legal and other requirements that apply
to the Region 6 lab & field operations activities, products, or services.
1. For regulatory requirements, the EMS Team relies on the internal regulatory compliance
expertise based in SHEMD. The EMS Team provides SHEMD with the final list of the Region
6 lab & field operations activities, products and services; environmental aspects; and associated
environmental impacts (see A-Significant Environmental Aspects). SHEMD reviews these lists
and develops a preliminary list of legal and regulatory requirements that apply to the Region 6
lab & field operations activities, products or services. The list identifies the legal and regulatory
requirement and the associated activity, product or service to which it applies.
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2. For other requirements, the EMS Team relies on the internal expertise of SFPB. The EMS
Team provides SFPB with the final list of the Region 6 lab & field operations activities,
products and services; environmental aspects; and associated environmental impacts (see A-
Significant Environmental Aspects). SFPB reviews these lists and develops a preliminary list of
legal and regulatory requirements that apply to the Region 6 lab & field operations activities,
products or services.
3. SHEMD and SFPB maintain awareness of applicable legal and other requirements by:
consulting with compliance professionals that provide regulatory compliance support to EPA
facilities; periodic attendance at environmental conferences or training; periodic contact with
state and local regulatory officials; periodic contact with EPA regulatory, compliance, or
technical staff involved in developing new mandates such as Executive Region 6 lab & field
operations; and periodic contact with EPA purchasing officials who may identify new or
modified contractual arrangements to be brought to the attention of the EMS Team.
4. The EPA Office of General Counsel (OGC) reviews the consolidated list of applicable legal and
other requirements. Following approval by OGC the list is finalized and retained as an EMS
document.
5. SHEMD and SFPB are responsible for keeping the EMS Team aware of any changes in
applicable legal and other requirements. Following review by OGC, the list is revised and
updated.
Records
All relevant records for the Region 6 lab & field operations EMS can be located on the Region 6 shared
directories, see records section in: "A. EMS Procedure for Identifying Significant Environmental
Aspects "
S: XEnvironmental Management Systems\
Record
Location
Blank worksheet template for identifying legal and
other requirements
Shared drive
Final listing of legal and other requirements
Shared drive
Listing of Executive Region 6 lab & field
operations
Shared drive
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Environmental Regulations for Each Identified
EMS Regulatory drivers were researched and developed for all Aspects. Below is an example of the
drivers for Air Emissions:
o Federal Code, Clean Air Act (CAA) 42 U.S.C. 7412, section 112(r), "Prevention of Accidental
Releases." Owner or operator of a facility at which a regulated substance is present in more
than the threshold quantity must prepare, register, and implement a Risk Management Plan,
o EPA regulation, 40 CFR Part 68, Subpart F, "Regulated Substances for Accidental Releases"
(under CAA section 112(r)): Regulated toxic and flammable substances and threshold quantities
required under section 112(r) of the CAA are listed in Tables 1, 2, 3, and 4 of 40 CFR 68.130.
o EPA regulation, 40 CFR Part 60, Subpart Dc, "Standards of Performance for Small Industrial -
Commercial-Institutional Steam Generating Units."
o EPA regulation, 40 CFR Part 82, Subpart F, under authority of CAA, "Recycling and Emissions
Reduction": Maintain, service, repair, and dispose of appliances without releasing class I or
class II substances used as a refrigerant,
o EO 13148 GREENING THE GOVERNMENT THROUGH LEADERSHIP IN
ENVIRONMENTAL MANAGEMENT: including the Emergency Planning and Community
Right-to-Know Act of 1986 (42 U.S.C. 11001-11050) (EPCRA), the Pollution Prevention Act
of 1990 (42 U.S.C. 13101-13109) (PPA), the Clean Air Act (42 U.S.C. 7401-7671q) (CAA),
and section 301 of title 3, United States Code,
o Class I Ozone-Depleting Substances: The Scientific Assessment of Ozone Depletion, 2002
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C. EMS Procedure for Determining Objectives and Targets
Purpose
The purpose of this procedure is to establish objectives and targets for all or some of the Region 6 lab
& field operations significant environmental aspects, or for other elements of the EMS. The objectives
and targets form the basis for region 6 lab & field Operation's continuous improvement process and are
supported by the Environmental Management Programs established for each target.
Environmental Objective - Overall environmental goal, arising from the environmental policy, that an
organization sets itself to achieve, and which is quantified where practicable (ISO 14001:1996)
Environmental Target - Detailed performance requirement, quantified where practicable, applicable to
the organization or parts thereof, that arises from the environmental objectives and that needs to be set
and met in order to achieve those objectives (ISO 14001:1996)
Scope
The EMS Team constructs objectives and targets for some (or all) of its significant environmental
aspects. Objectives and targets may also be developed for other aspects of the Region 6 lab & field
operations activities, products, and services, or for elements of the environmental policy, if the EMS
provides an effective vehicle for addressing them.
The U.S.EPA Region 6 lab & field operations Environmental Management System (EMS) is designed
to manage the environmental impacts that result from the operations at the facility and, to a limited
extent, off-site field activities. All of the operations conducted at the facility located at 10625 Fallstone
Road, Houston, Texas 77099 are considered within the scope of the EMS. The activities of all of the
occupants of the facility are subject to the policies and procedures described in this manual. The
Region 6 lab & field operations EMS are designed to conform to the international standard ISO 14001
(1996). Environmental Management Systems - Specification With Guidance For Use. This procedure
applies to all EPA and contractor personnel working at the Region 6 lab & field operations Region 6
facility.
Definitions
Environmental Objective: Overall environmental goal, arising from the environmental policy, that an
organization sets itself to achieve, and which is quantified where practicable (ISO 14001: 1996).
Environmental Target: Detailed performance requirement, quantified where practicable, applicable to
the organization or parts thereof, that arises from the environmental objectives and that needs to be set
and met in region 6 lab & field operations to achieve those objectives (ISO 14001:1996)
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Approach
The EMS team constructs objectives and targets for each significant environmental aspect objectives
and targets (O/T) need to be set for each significant aspect. Objectives and targets are developed while
considering criteria such as whether there is an existing program that addresses the activities that
contribute to that aspect, compliance issues, the availability of Region 6 lab & field operations -specific
performance data, and the opinion of the EMS Team as to where the greatest environmental
performance improvements can be made. Consideration is also given to the Region 6 lab & field
operation's environmental policy, applicable legal and other requirements, technological options and
financial feasibility, and views of interested parties.
After finalizing draft objectives and targets, the EMS team constructs an estimate of the resources
needed to achieve the targets and the dates to meet the objectives. The objectives, targets, target
resource estimates, and estimated completion dates are presented to the Region 6 lab & field operations
Administrative Team for decisions regarding which targets to implement. The Region 6 lab & field
operations Administrative Team reviews the resource estimates and decides which targets to purse
considering the operational and resource constraints that exist at that time.
After the decision is made regarding which targets will be pursued, the EMS Team is responsible for
documenting existing programs that are in place to address targets and for launching any new initiatives
that are expressed in the targets. The Region 6 lab & field operations uses volunteer workgroups and
existing workgroups (e.g., Waste Committee and Chemical Resources Committee) in many instances to
achieve targets.
In general, the outputs (e.g., strategies, proposals) from EMS sub-workgroups are submitted to the
EMS Team for review. The EMS Team presents recommendations developed by sub-workgroups to
the Region 6 lab & field operations Administrative Team for decisions regarding implementation. The
EMS Coordinator is responsible for records pertaining to objectives and targets. The procedure should
require that the list of O/Ts and progress made towards them be kept up to date.
The following steps illustrate how the EMS Team identifies the objectives and targets for each selected
aspect:
1. The EMS Team records preliminary ideas about objectives and targets that could be established
for the selected aspects, including the elements of a program or initiative that could be
implemented to improve performance with respect to the aspect.
2. In setting objectives and targets, the EMS Team takes into consideration the Region 6 lab &
field operations environmental policy, applicable legal and other requirements, available
technological options, and relevant operational and business requirements. In addition, the EMS
Team considers any critical implementation issues that might significantly affect the feasibility
of implementing such a program.
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3. Each member of the EMS Team shares the list within their department and collects additional
ideas specific to that department.
4. The EMS Team compiles a comprehensive list of objectives and targets for the Region 6 lab &
field operations as a whole (using the individual lists collected already).
5. Once the list is finalized and approved by each department, the team estimates the resources,
including staff time; capital and operating requirements, and extramural support that may be
needed to achieve the targets.
6. The EMS Team presents the list of objectives and targets, and associated resource needs, to
region 6 lab & field operations management for review and approval. Approval by management
is essential due to resource commitments.
7. The objectives and targets are reviewed by the EMS Team regularly (on an annual basis or in
response to significant changes) to ensure that the information is current. Changes to the
objectives and targets or the need for new objectives and targets are considered during this
review. Changes or modifications to the current list of aspects are updated and communicated
on a continuing basis.
Records
All relevant records for the region 6 lab & field EMS can be located on the Region 6 shared directories,
see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects. " The objectives and targets
have been finalized andformalized to enable their implementation at the Region 6 Laboratory.
Environmental
Aspect
Objective
Target
Current available
resources
Proposed additional resources
Waste
Reduction
Promote &
expand upon a
waste
reduction/recy
cling program
No deviation from
CHP, SPCCP & OEP
Team Leaders (Organic,
Inorganic, External Lab
Oversight & Sample
Management)
Checklist/Evaluation forms to track lab compliance
100% Regulatory
Compliance
SHEMP Manager 1 day
per year to complete
Hazardous Waste
Manifest and Annual
Waste Summary
None - small generator
Promote awareness
Region 6 Management
Appoint lead and team to track recycling/waste
generation.
Determine base
amounts for recycled
materials within 1
year
Tim Sanders current
recycle coordinator
Building Engineer assists with recycling activities
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EMS Manual
Houston Lab
|-'.IUT!»\
( o||s(T\;||jo||
Reduce energy
consumption
demand
Reduce demand by
10% by 2010
None
Building Engineer 100 hrs per year
Promote awareness
Region 6 Management
Appoint Lnergy I.ead
( llClllilill
\l;ill;i«!('lllclll
Reduce use of
chemical
resources
Combine as many
runs as you can so
you can reduce the
amount of standards
used.
Team Leaders (Organic.
Inorganic. Lxternal I.ab
Oversight & Sample
Management)
Appoint Chemical Management I.ead
Innovative
equipments (to
reduce amount of
chemical use.)
Same
Promote awareness
Same
\\ jUt
( oiis('i-\iiiioii
Reduce \\ aler
consuniplion
demand
Reduce water
consumption by 3%
by 2010
None
Lncourage Building Engineer (leasor) to:
1) utilize lancet restrictors. low llush toilet systems
2) Xeri landscaping
3) reduce sprinkler usage
Promote awareness
Region 6 Management
Appoint Water I'sage I.ead
\oisi»
1 mi-^ions
Reduce noise
exposure
100% Regulatory
Compliance
Hearing protection
currently available
Purchase noise meter hearing protection to comply
with OSIIA 29 CLR 1910.95 requirements
Promote awareness
None
SIILMP Manager L valuations:
8 hrs per month
Total 96 hrs
\ir 1 minion*.
Improve
Indoor
Outdoor Air
Quality
Obtain Cireen Lnergy
source supplies
Management Analyst
serves as poinl-ol-conlact
lor laboratory's
utilization of Green
energy
Minimal
Improve building
indoor air quality
None
Purchase air quality monitoring instruments.
Reduce intake ofpoor air quality through ventilation
system:
1) Move modify air intake.
2) Xeri landscape in Iron I of air intake.
3) Limit truck vehicle parking in Iron I of air intake.
4) I .imil mow ing around rear air intakes.
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D. EMS Procedure for Determining Operational Controls
Purpose
The purpose of this procedure is to identify the need for and subsequently develop operational controls
that are applied to activities, products, or services associated with the Region 6 lab & field operations
significant environmental aspects. In addition to controlling the significant environmental aspects,
operational controls are developed to prevent any deviations from commitments made in the Region 6
lab & field operations environmental policy. This procedure also ensures that region 6 lab & field
operations communicates relevant operational controls to contractors and suppliers. The planned EMS
is implemented and operated through a responsibility structure that is agreed upon by the Region 6 lab
& field operations Administrative Team.
Scope
This procedure applies to all the Region 6 lab & field operations activities, products and services,
including goods and services purchased or otherwise received from external sources and used by the
Region 6 lab & field operations. The U.S.EPA Region 6 lab & field operations Environmental
Management System (EMS) is designed to manage the environmental impacts that result from the
operations at the facility and, to a limited extent, off-site field activities. All of the operations
conducted at the facility located at 10625 Fallstone Road, Houston, Texas 77099 are considered within
the scope of the EMS. The activities of all of the occupants of the facility are subject to the policies
and procedures described in this manual. The Region 6 lab & field operations EMS is designed to
conform to the international standard ISO 14001 (1996). Environmental Management Systems -
Specification With Guidance For Use. This procedure applies to all EPA and contractor personnel
working at the Region 6 lab & field operations Region 6 facility.
Definitions
Operational Controls: The planning and carrying out of operations and activities in such a way that
they are conducted under specified conditions. Operational controls include but are not limited to:
work instructions, operating procedures, operation manuals, guidance, handbooks, training, and
contractual language. Operational controls also include any equipment or instruments used to
maintain operations within a specified operating range.
Operating criteria: TBD
Significant Environmental Aspect (SEA): An element of an organization's activities, products, or
services that can interact with the environment (ISO 14001:1996).
Operational Control Form (OCF): An EMS form that clarifies what steps must be taken to properly
identify and control environmental aspects.
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Environmental Management Program (EMP): A program designed to achieve the organization's
objectives and targets, including, but not limited to, regulatory compliance, conformance to Executive
Region 6 lab & field operations, going beyond regulatory compliance, staff training, or the Region 6
lab & field operations environmentally-related procedures (such as recycling procedures). EMPs
contain details on the resources (e.g., financial, human, and technological) and timeframes necessary
to accomplish the objectives and targets.
Approach
There following steps describe the approach used to develop operational controls for Region 6 lab &
field operations:
1. The EMS Team reviews the list of significant environmental aspects to identify those Region 6 lab
& field operations activities, products, or services that may require operational controls. The need
for operational controls is assessed with the following objectives in mind:
¦ Avoiding significant environmental impacts that could occur in the absence of such
controls;
¦ Preventing Houston Lab from achieving its objectives and targets; and
¦ Preventing any deviations from the Region 6 lab & field operations environmental policy.
2. The EMS Team recognizes that existing Houston Lab practices, procedures, guidance, etc. may
already address environmental impacts associated with Region 6 lab & field operations activities,
products, and services. In assessing the need for operational controls under this EMS procedure, the
EMS Team takes into account any existing operational controls. In this way, the EMS Team can
refer in its EMS documentation to existing operational controls it judges to be acceptable. Use of
acceptable operational controls, where such controls already exist, can help achieve integration of
the EMS into the normal business practices of Region 6 lab & field operations.
3. The EMS Team also recognizes that many practices, procedures, guidance, etc. exist to address
environmental impacts associated with Houston Lab activities, products, and services, but these
may not be documented or may not be documented in a fashion that satisfies the requirements of
this EMS procedure and the Region 6 lab & field operations EMS overall. In these cases it may be
sufficient for the EMS Team to document existing practices or revise existing documentation to
satisfy an operational control requirement.
4. To assess the need for operational controls and the nature of any existing controls, the EMS Team
consults Region 6 lab & field operations employees (and contractors and suppliers) at the
appropriate level and function of the organization. This is in recognition of the fact that those
employees who directly interact with the Region 6 lab & field operations significant environmental
aspects are most qualified to describe existing operational controls, assess the need for additional
operational controls, and assist in writing and implementing any new or revised operational
controls.
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5. Documentation of operational controls is developed using the operational control template. The
template identifies: the specific activity, product, or service to which the control applies; the
specific steps that need to be taken to control the environmental aspect; the key characteristics of
the activity, product, or service that need to be monitored; plans for any maintenance required to
ensure an activity, product, or service remain in control; and the actions to be taken when controls
may be interrupted or might otherwise fail.
6. Documentation associated with operational controls must be kept current and accessible to relevant
employees, including contractors and vendors.
The following Individuals and groups have specific responsibilities within the structure of the EMS:
liuli\ iclnal (iroup
Responsibilities
EMS Coordinator
Implement and maintain the EMS for continued
conformance to ISO 14001. Reports directly to Region 6
lab & field operations Administrative Team. Directs
EMS activities through the EMS Team/Leads at the lab.
Appoints EMS Team Leaders each year.
EMS Team
Directly participate in the design and implementation/
operation of the EMS.
Facility Manager
Facility operation and maintenance, energy management.
SHEM Manager
Overall responsibility for environmental compliance.
EMS Internal Audit Group
Conduct internal audits to determine system
conformance. Reports directly to EMS Coordinator for
ALL EMS activities.
Region 6 lab & field operations
Administrative Team
Final responsibility for environmental compliance and
decisions regarding the allocation of EMS resources (i.e.,
Top Management).
Environmental Management
Contractors
Assist as needed with EMS tasks.
Region 6 lab & field operations
Supervisors/Team Leads
Ensure that staff is aware of and complying with EMS
policies and procedures. Assist with completion of non-
conformance corrective actions. Participates in and is
aware of EMS activities. Supports EMS Coordinator.
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EMS Manual
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liuli\ iclnal (iroup
Responsibilities
Region 6 lab & field operations
Staff
Be familiar with EMS structure, points of contact, the
policies and procedures contained in the EMS
documents. Participates in and is aware of EMS
activities.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects"
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EMS Manual
Houston Lab
E. EMS Procedure for Determining Environmental Management Plans
Purpose
The purpose of this procedure is to establish Environmental Management Plans that support meeting all
environmental objectives and targets identified for the Region 6 lab & field operations. Environmental
management plans (EMPs) are in place for each significant environmental aspect.
Scope
This procedure encompasses those environmental objectives and targets associated with all activities,
products and services that occur at the Region 6 lab & field operations, including the activities of
suppliers and contractors while operating at the Region 6 lab & field operations. The U.S.EPA Region
6 lab & field operations Environmental Management System (EMS) is designed to manage the
environmental impacts that result from the operations at the facility and, to a limited extent, off-site
field activities. All of the operations conducted at the facility located at 10625 Fallstone Road,
Houston, Texas 77099 are considered within the scope of the EMS. The activities of all of the
occupants of the facility are subject to the policies and procedures described in this manual. The
Region 6 lab & field operations EMS is designed to conform to the international standard ISO 14001
(1996). Environmental Management Systems - Specification With Guidance For Use. This procedure
applies to all EPA and contractor personnel working at the Region 6 lab & field operations Region 6
facility.
Definitions
Environmental Management Plan: An Environmental Management Plan (EMP) is an action plan, or
series of action plans, prepared, implemented and tracked for achieving specific environmental
objectives and targets identified by region 6 lab & field operations.
Approach
EMPs are developed for meeting each established target. EMPs are designed to manage the activities
that substantially contribute to the impacts of the significant aspects and to achieve EMS targets and
objectives. At any given time the EMP is comprised of existing program components and/or new
program components that will result from targets. The details of the EMPs including Individual
responsibilities and operational controls are documented in the EMP Forms. The completion date to
meet the objectives is also included in the EMP forms. The EMS Coordinator is responsible for
maintaining the EMP Forms
1. Specific EMPs are established for each environmental objective and target. Each EMP activity is
linked to a Region 6 lab & field operations environmental objective.
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EMS Manual
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2. EMPs are documented, and specifically identify:
2.1. Objective and target associated with the EMP
2.2. An indicator for tracking progress on achieving the EMP
2.3. A time schedule
2.4. Identification of specific actions or an action plan to achieve the EMP
2.5. Identification of resources and individuals and/or teams
3. EMPs should be reviewed and possibly modified whenever the following occur:
3.1. HOUSTON LAB activities, products, or services (i.e., installation of new equipment or
implementation of a new program)
3.2. Environmental objectives and targets are modified or added
3.3. Relevant legal or other requirements are changed or introduced (e.g., new Executive
Order requirements)
3.4. Significant progress has been made on achieving an objective or target such that it
should be re-examined to determine if it is still relevant, should be modified, achieved,
etc.
4. Whenever possible, EMPs should be coordinated or integrated with other P4, business unit or
corporate goals and plans.
5. The results of each EMP should be documented for future reference. Reporting in formal
performance reports should be considered as an option.
Responsibilities
The EMS Team identifies the Region 6 lab & field operations employees best suited to take the lead in
establishing specific EMPs. Input should be solicited from all parties affected by the EMP, or who are
providing resources to achieve the associated objective and target. These parties include:
Region 6 lab & field operations Management
SHEMD management
Environmental staff
Communications
Legal services
the Region 6 lab & field operations employees are encouraged to suggest and contribute to the
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EMS Manual
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identification of potential objectives and targets (that may subsequently become EMP activities) by
identifying activities and processes that may present potentially significant environmental impacts that
are not being adequately addressed.
The EMS Coordinator and top management approves all EMPs.
The EMS Coordinator is responsible for tracking progress on EMPs .
Records
All relevant records for the Region 6 lab & field operations EMS can be located on the Region 6 shared
directories, see records section in: S:\EnvironmentalManagement Systems\
"A. EMS Procedure for Identifying Significant Environmental Aspects"
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EMS Manual
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F. EMS Procedure for Environmental Training of Employees
Purpose
The purpose of this procedure is to ensure that the Region 6 lab & field operations employees receive
periodic environmental awareness training and to identify and provide appropriate training for those
Region 6 lab & field operations employees whose work activities are related to the region 6 lab & field
operations significant environmental aspects. The provision of such training is necessary to ensure
operation of the Region 6 lab & field operations in accordance with the EMS and to achieve the
objectives and targets established as part of the EMS. This procedure outlines training currently offered
to Region 6 Lab employees as well as training currently under development as part of our EMS
implementation process.
Scope
This procedure applies to all the Region 6 lab & field operations employees. Those portions of this
procedure concerned with competency training will generally apply only to those employees whose
work interacts with or influences the Region 6 lab & field operations significant environmental aspects.
The U.S.EPA Region 6 lab & field operations Environmental Management System (EMS) is designed
to manage the environmental impacts that result from the operations at the facility and, to a limited
extent, off-site field activities. All of the operations conducted at the facility located at 10625 Fallstone
Road, Houston, Texas 77099 are considered within the scope of the EMS. The activities of all of the
occupants of the facility are subject to the policies and procedures described in this manual. The
Region 6 lab & field operations EMS is designed to conform to the international standard ISO 14001
(1996). Environmental Management Systems - Specification With Guidance For Use. This procedure
applies to all EPA and contractor personnel working at the Region 6 lab & field operations Region 6
facility.
Definitions
Awareness training ensures that all employees understand the environmental policy, the role of
employees in furthering the policy, and the potential consequences of failing to provide environmental
care.
Competence training is prescribed for employees whose work interacts with or influences the Region 6
lab & field operations significant environmental aspects. Competence training ensures that employees
understand (a) how their work interacts with the significant aspects, (b) the possible influence and
consequences of their actions on those aspects and the environment, (c) their specific roles and
responsibilities in controlling the significant aspect and achieving any objectives and targets
establishedfor those significant aspects.
Environmental Management Program (EMP) - program designed to achieve the organization's
objectives and targets, including, but not limited to, regulatory compliance, conformance to Executive
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Region 6 lab & field operations, going beyond regulatory compliance, staff training, or the Region 6
lab & field operations environmentally-related procedures (such as recycling procedures). EMPs
contain details on the resources and timeframes necessary to accomplish the objectives and targets.
Approach
1. Awareness Training
1.1. General environmental awareness training is provided to all employees as part of the EMS
initiation. New employees receive environmental awareness training as part of the new
employee orientation process. On a periodic basis, determined by management, all employees
receive refresher training to ensure a continuous level of environmental awareness.
1.2.The objective of general environmental awareness training is to make all the Region 6 lab &
field operations employees aware of:
¦ The existence of the Region 6 lab & field operations EMS and its scope
¦ The Region 6 lab & field operations Environmental Policy and its core principles and
commitments
¦ The significant environmental aspects identified for the Region 6 lab & field operations
¦ The importance of conformance with the environmental policy and established
procedures
¦ Employee roles and responsibilities in achieving established objectives and targets
¦ The potential consequences of departure from specified operating procedures
¦ Who to contact if they have suggestions or become aware of problems
1.3.Awareness training programs are reviewed and updated on an annual basis.
2. Competency Training
2.1.Employees whose work activities are associated with or influence the Region 6 lab & field
operations significant environmental impacts may take part in environmental competence
training.
2.2.The need for competence training is established through a needs assessment that identifies those
jobs or employees affected, reviews the level of competence of and training provided to such
employees, and defines any additional training that may be needed.
2.3.When required, such training will occur before the employee begins the assigned function.
2.4.In general, competence training will focus on:
¦ The significant environmental impacts, actual or potential, of their work activities and
the environmental benefits of improved personal performance.
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¦ The proper procedures for environmental monitoring or measuring.
¦ Employee roles in achieving conformance with the environmental policy and procedures
and with the requirements of the EMS.
¦ The potential consequences of departure from specified operating procedures.
Several types of training are employed in the Region 6 lab & field operations EMS:
Type of EMS Training
Training Recipients
Training Purpose
EMS Implementation
EMS Implementation Team
Detailed EMS training
EMS Internal Audit
EMS Internal Audit Group
Planning and conducting internal
EMS audits
EMS Awareness
All staff permanently
stationed at the Region 6 lab
& field operations
General EMS, Importance of
conformance to EMS policy,
Roles and Responsibilities,
Targets and Objectives
EMS Procedure-specific
Those staff whose jobs are
directly associated with EMS
procedures
Roles and Responsibilities,
potential consequences of
departures from SOPs
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects"
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G. EMS Procedure for Emergency Preparedness and Response
Purpose
The purpose of this procedure is to provide for the identification and response to potential accidents and
emergency situations at the Region 6 lab & field operations, and to prevent, mitigate, and minimize the
threat of environmental impacts from these situations. Emergency preparedness and response
procedures are documented in the Occupant Emergency Plan (OEAP), Spill Prevention Control and
Countermeasures Plan (SPCC), and the facility Chemical Hygiene Plan (CHP). All occupants of the
Region 6 lab & field operations are provided with an electronic copy of the OEAP located on the
shared directory. The SPCC and the CHP are also available to all staff on the local area network.
Scope
The emergency preparedness and response procedure applies to all the Region 6 lab & field operations
facilities. The U.S.EPA Region 6 lab & field operations environmental Management System (EMS) is
designed to manage the environmental impacts that result from the operations at the facility and, to a
limited extent, off-site field activities. All of the operations conducted at the facility located at 10625
Fallstone Road, Houston, Texas 77099 are considered within the scope of the EMS. The activities of
all of the occupants of the facility are subject to the policies and procedures described in this manual.
The Region 6 lab & field operations EMS is designed to conform to the international standard ISO
14001 (1996). Environmental Management Systems - Specification With Guidance For Use. This
procedure applies to all EPA and contractor personnel working at the Region 6 lab & field operations
Region 6 facility.
Definitions
N/A
Approach
The following steps describe the procedure for emergency preparedness and response:
1. EPA maintains a comprehensive emergency preparedness and response plan for it's the Region 6
lab & field operations facilities. These plans identify a range of possible incidents, accidents, and
emergency situations that may arise within, around, or otherwise effect the Region 6 lab & field
operations facilities, and provide for effective response to such situations.
2. The EMS Team met with the Region 6 lab & field operations emergency preparedness and response
Coordinator to review these plans and determine the extent to which these plans adequately
identify:
2.1. The potential environmental consequences of each scenario;
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2.2. The appropriate preventative steps to be taken to minimize the potential for any
environmental impacts to occur as a result of such incidents; and
2.3. The appropriate steps to be taken in response to such incidents to assess the potential for,
mitigate, and minimize any environmental impacts.
3. Based on this review, the Region 6 lab & field operations emergency preparedness and response
Coordinator revised the plans and communicated the changes to all necessary personnel and
officials (as detailed in those plans).
4. The Region 6 lab & field operations emergency preparedness and response plans provide for
regular exercise of the plans. The plans also provide for a written assessment following each
exercise of the plan. In response to the EMS Team review of the plans, the Region 6 lab & field
operations emergency preparedness and response Coordinator has revised the form used to
report out following exercise of the plans to include a statement concerning any findings
regarding potential environmental consequences.
5. The Region 6 lab & field operations emergency preparedness and response plans also provide for a
written assessment following any actual incidents that trigger the plans. In response to the EMS
Team review of the plans, the Region 6 lab & field operations emergency preparedness and
response Coordinator has revised the form used to report out following an actual incident to
include a statement concerning any findings regarding actual or potential environmental
consequences, and the effectiveness of the plan in mitigating and minimizing any such impacts.
6. The plan is evaluated and modified on at least an annual basis.
The SHEM Manager provides initial training on the OEAP to all new employees. The SHEM Manager
provides refresher training on laboratory OEAP procedures during annual safety training.
Responsibilities and procedures for environmental incidents are described in the OEAP section titled
"Hazardous Materials Spills" as well as the sections titled "Chemical Spill Control and Reporting " and
"Fire and Emergency Evacuation Plan" in the CHP. In addition the SPCC sections titled "SPCC Plan
Elements" and "Spill Discovery And Notification" further describe the responsibilities and procedures
for environmental incidents. These plans identify and plan for any environmental impact. (Verify that
your plans do identify and plan for any environmental impact.)The OEAP and SPCC include
emergency contact information and phone numbers. The SHEM Manager reviews the OEAP, SPCC,
and the CHP annually. Generate a record reflecting a review of these plans has been conducted to
identify potential environmental impacts, determine whether their mitigation is adequately covered by
the plan, and document any recommended changes to the plan and follow up to determine the changes
have been made.
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Every quarter, the Region 6 lab & field operations conducts an evacuation drill according to EPA and
FGGM requirements. While this is commonly referred to as a "fire drill", the emergency procedures
used are the same as those for an Environmental emergency and subsequent Haz-Mat response if the
incident is severe enough. Additionally, every two years the Region 6 lab & field operations conducts
a "mock spill exercise" with the local Fire Department/Haz-Mat Team. The objective of the exercise is
to ensure that the emergency responders and Region 6 lab & field operations staff, grantees, and on-site
contractors are familiar with the emergency preparedness and response procedures.
The SHEM Manager coordinates corrective actions and changes in procedures are documented in
revisions to the OEAP, SPCC and/or CHP.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects"
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H. EMS Procedure for Tracking Environmental Performance
Purpose
The purpose of this procedure is to allow region 6 lab & field operations to monitor and measure those
aspects of its operations that can have a significant impact on the environment, to assess the
effectiveness of its operational controls, and to track its progress towards achieving environmental
objectives and targets. Primarily the Building Engineer and the SHEM Manager conduct monitoring
and measuring of operations and activities relative to significant aspects with assistance from on-site
contractors and other Region 6 lab & field operations staff.
Scope
This procedure applies to those Region 6 lab & field operations activities that are linked to the Region 6
lab & field operations significant environmental aspects. The U.S.EPA Region 6 lab & field operations
Environmental Management System (EMS) is designed to manage the environmental impacts that
result from the operations at the facility and, to a limited extent, off-site field activities. All of the
operations conducted at the facility located at 10625 Fallstone Road, Houston, Texas 77099 are
considered within the scope of the EMS. The activities of all of the occupants of the facility are subject
to the policies and procedures described in this manual. The Region 6 lab & field operations EMS is
designed to conform to the international standard ISO 14001 (1996). Environmental Management
Systems - Specification With Guidance For Use. This procedure applies to all EPA and contractor
personnel working at the Region 6 lab & field operations Region 6 facility.
Definitions
Key characteristics
Approach
The procedures followed are documented in written work assignments to staff and contractors. The
records associated with monitoring and measuring as well as the calibration of monitoring equipment
are specified on the EMPs and OCFs and are maintained in the files of the Facility Manager and the
SHEM Manager. Need to verify that monitoring and measuring is included in the EMPs and OCFs.
The following steps describe the procedure used to establish performance metrics for the Region 6 lab
& field operations
I. The EMS team examines the significant environmental aspects and identifies the key characteristics
of each. To identify these characteristics and understand how they can be monitored the EMS
Team may consult with subject matter experts or those whose work directly interacts with the
significant aspect. The key characteristics will include indicators of operational control
effectiveness as well as effectiveness in reaching established environmental objectives and targets.
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2. For each significant aspect, the EMS Team establishes methods for monitoring the key
characteristics. To develop the methods, the EMS Team may consult with subject matter experts or
those whose work directly interacts with the significant aspect. The methods will identify any
necessary equipment, describe the data to be collected, identify individuals with responsibilities for
helping monitor the aspect, and establish the frequency of data collection and the frequency, format,
and recipient(s) of any reporting.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects"
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I. EMS Procedure for Calibrating, Monitoring and Measuring Instruments
Purpose
The purpose of this procedure is to specify responsibilities and provide guidance on the calibration and
maintenance of any monitoring and measuring equipment or instruments used for tracking region 6 lab
& field operations environmental performance. This procedure addresses the calibration, monitoring
and measurement of instruments used to assist in EMS implementation of Region 6 lab & field
operations objectives and goals.
Scope
This procedure applies to any equipment or instrument used to monitor or measure the various
indicators used to determine the environmental performance of the region 6 lab & field operations
EMS. These indicators and any necessary equipment or instrument are defined under H—EMS
Procedure for Tracking Environmental Performance. The U.S.EPA Region 6 lab & field operations
Environmental Management System (EMS) is designed to manage the environmental impacts that
result from the operations at the facility and, to a limited extent, off-site field activities. All of the
operations conducted at the facility located at 10625 Fallstone Road, Houston, Texas 77099 are
considered within the scope of the EMS. The activities of all of the occupants of the facility are subject
to the policies and procedures described in this manual. The Region 6 lab & field operations EMS is
designed to conform to the international standard ISO 14001 (1996). Environmental Management
Systems - Specification With Guidance For Use. This procedure applies to all EPA and contractor
personnel working at the Region 6 lab & field operations Region 6 facility.
Definitions
N/A
Approach
Region 6 lab & field operations personnel utilizing equipment to assist with EMS implementation at the
Region 6 lab will follow standard operating procedures supplied by the manufacturer (i.e., Sound Level
Meter used to assist with Noise Emission Aspect will use SOP to calibrate meter).This information
should be identified in the OCFs.
1. For any equipment used to monitor and measure the key characteristics specified under H—EMS
Procedure for Tracking Environmental Performance, the EMS Team determines the appropriate
methods for calibrating and maintaining such equipment and the necessary frequency of such
calibration and maintenance. In establishing the methods and frequency for equipment calibration
and maintenance, the EMS Team may consult with subject matter experts or those whose work
directly interacts with the significant aspect.
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2. A procedure describing the method, frequency, and responsibility for calibration and maintenance is
established for each piece or type of equipment.
3. Records of equipment calibration and maintenance are retained according to the procedures
established in step 2.
A record should be created listing the instruments used to monitor EMS performance, for example by
SEA, identifying the parameter measured ("key characteristic"), and specifying or pointing to the
calibration procedure.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
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J. EMS Procedure for Providing Internal Communications
Purpose
The purpose of this procedure is to establish methods and responsibilities for communicating
environmental information, including information about the EMS, throughout the Region 6 lab & field
operations. Ongoing awareness of the EMS is achieved using several modes of communication.
Scope
This procedure applies to all Region 6 lab & field operations employees and onsite contractors. Some
portions of this procedure may apply only to those employees with specific responsibilities that support
the functioning of the EMS. The U.S.EPA Region 6 lab & field operations Environmental Management
System (EMS) is designed to manage the environmental impacts that result from the operations at the
facility and, to a limited extent, off-site field activities. All of the operations conducted at the facility
located at 10625 Fallstone Road, Houston, Texas 77099 are considered within the scope of the EMS.
The activities of all of the occupants of the facility are subject to the policies and procedures described
in this manual. The Region 6 lab & field operations EMS is designed to conform to the international
standard ISO 14001 (1996). Environmental Management Systems - Specification With Guidance For
Use. This procedure applies to all EPA and contractor personnel working at the Region 6 lab & field
operations Region 6 facility.
Definitions
N/A
Approach
EMS Awareness sessions are conducted for all Individuals whose duty station is the Region 6 lab &
field operations. These sessions are designed to cover basic information about the general structure and
purpose of EMSs, as well as specific information regarding the Region 6 lab & field operations EMS.
All Region 6 lab & field operations staff are encouraged to participate by offering ideas to improve
environmental performance. Other forms of awareness communication include e-mail updates that
indicate EMS status.
1. The EMS Coordinator establishes lines of communication to ensure the regular collection of
data needed to continuously evaluate region 6 lab & field operations environmental
performance. This is done by ensuring that procedures for monitoring and measuring
performance include requirements for reporting such data, and specify how frequently, in what
format, and to whom such data is to be reported.
2. The EMS Coordinator may, alone or in consultation with the EMS Advisory Committee,
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regularly initiate efforts to communicate information about region 6 lab & field operations
environmental performance, including EMS performance, to relevant employees. Such
communication may range from short email notices to selected employees concerning one
aspect of the EMS to more detailed communications that may involve all the Region 6 lab &
field operations employees, such as rollout of new Environmental Management Plans.
3. The EMS Coordinator is responsible for regularly communicating information about region 6
lab & field operations environmental performance, including EMS performance, to top
management. This communication takes place in accordance with the requirements set forth in
R—Management Review.
4. Top management also communicates with all the Region 6 lab & field operations employees the
results of regular Management Reviews of the region 6 lab & field operations EMS, in
accordance with R—Management Review.
5. All employees are responsible for communicating information that could affect the
environmental performance of region 6 lab & field operations or the functioning of the region 6
lab & field operations EMS, in either a positive or negative manner. Employees shall use their
judgment in determining the most appropriate method of communication, including:
a. Reporting to their immediate supervisor or manager,
b. Reporting through the "suggestion box" on the region 6 lab & field operations EMS
intranet, or
c. Reporting directly to the Region 6 lab & field operations staff or contractors with
specific environmental responsibility, including (i) the EMS Coordinator, (ii) those with
designated responsibility under the region 6 lab & field operations Environmental
Management Plans, or (iii) staff within the OARM Safety, Health and Environmental
Management Division.
6. In the event of any serious environmental incident or threat, or any other incident with
potentially serious environmental implications, all employees shall follow the communications
procedures established under the Region 6 lab & field operations Emergency Preparedness and
Response Plan.
Records
All relevant records for the Region 6 lab & field operations EMS can be located on the Region 6 shared
directories, see records section in: S:\Environmental Management Systems\ "A. EMS Procedure for
Identifying Significant Environmental Aspects "
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K. EMS Procedure for Responding to External Interested Parties
Purpose
The purpose of this procedure is to ensure that the Region 6 lab & field operations receives, documents,
and responds to relevant information requests from external interested parties in a consistent and timely
fashion. This procedure addresses Region 6 lab & field operations correspondence to external parties.
Scope
All external inquiries regarding region 6 lab & field operations environmental performance or the
region 6 lab & field operations EMS shall be considered as being from an interested party. Each
inquiry will be handled in accordance with this procedure. The U.S.EPA Region 6 lab & field
operations Environmental Management System (EMS) is designed to manage the environmental
impacts that result from the operations at the facility and, to a limited extent, off-site field activities.
All of the operations conducted at the facility located at 10625 Fallstone Road, Houston, Texas 77099
are considered within the scope of the EMS. The activities of all of the occupants of the facility are
subject to the policies and procedures described in this manual. The Region 6 lab & field operations
EMS is designed to conform to the international standard ISO 14001 (1996). Environmental
Management Systems - Specification With Guidance For Use. This procedure applies to all EPA and
contractor personnel working at the Region 6 lab & field operations Region 6 facility.
Definitions
Interested party - Any person, organization, or group expressing interested in region 6 lab & field
operations environmental performance or the region 6 lab & field operations EMS.
Approach
EMS Team members may assist in responding to external interested parties concerning the Region 6
lab & field operations EMS program. Once a response is generated it SHALL be forwarded to the
Director of the Region 6 lab for dissemination. EMS Team members are NOT permitted to reply
directly to third party inquiries. A log of all external inquires will be maintained by the EMS
coordinator. All external communications from interested parties will be considered when defining
significant environmental aspects, establishing and reviewing environmental objectives and targets, and
during the annual management review
1. Inquiries from interested parties may reach the Region 6 lab & field operations in a variety of
ways. The following procedures cover the most likely methods that interested parties may use:
a. Telephone inquiries
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i. The region 6 lab & field operations switchboard operator is instructed on how to
identify inquiries related to region 6 lab & field operations environmental
performance or the region 6 lab & field operations EMS. The operator directs
any such calls to the EMS Coordinator.
ii. Any other the Region 6 lab & field operations employee who receives a
telephone inquiry related to region 6 lab & field operations environmental
performance or the region 6 lab & field operations EMS will forward the call to
the switchboard or to the EMS Coordinator. In lieu of this, the employee may
instruct the caller to call the switchboard and indicate they have a question about
the region 6 lab & field operations EMS.
b. Written correspondence
i. The Region 6 lab & field operations Mail Room is instructed on how to identify
inquiries concerning the region 6 lab & field operations EMS or region 6 lab &
field operations environmental performance. The Mail Room directs any such
correspondence to the EMS Coordinator.
ii. Any other the Region 6 lab & field operations employee who receives a written
inquiry related to region 6 lab & field operations environmental performance or
the region 6 lab & field operations EMS will forward the to the EMS
Coordinator or back to the mail room after marking "DELIVER TO EMS
COORDINATOR" on the envelope.
c. Email correspondence
i. Any the Region 6 lab & field operations employee who receives an email inquiry
related to region 6 lab & field operations environmental performance or the
region 6 lab & field operations EMS will forward the email to the EMS
Coordinator.
ii. The Region 6 lab & field operations internet EMS website instructs interested
parties to submit inquiries related to region 6 lab & field operations
environmental performance or the region 6 lab & field operations EMS to the
Agency using the email address voung.daniel@epa.gov. All email sent to this
address is automatically routed to the EMS Coordinator by the region 6 lab &
field operations email system.
2. The EMS Coordinator maintains a log of all external inquiries and logs all telephone, mail, and
email inquiries using this log. The log indicates the original date of the inquiry, the date
received by the EMS Coordinator, and how the inquiry was received (telephone, mail, email).
Copies of all mail and email correspondence shall be printed and maintained on file.
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3. The EMS Coordinator reviews each inquiry and determines whether and how to respond. The
EMS Coordinator makes a notation in the external inquiry log to indicate whether a response
was provided and the nature of any such response. In addition, The EMS Coordinator notes any
follow up communication with the external party in the log.
4. All external communications from interested parties will be considered when defining
significant environmental aspects, establishing and reviewing environmental objectives and
targets, and during the annual management review.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\ "A. EMS
Procedure for Identifying Significant Environmental Aspects "
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L. EMS Procedure for Providing External Communication of Significant Aspects
Purpose
The purpose of this procedure is to ensure that the Region 6 lab & field operations significant
environmental aspects are communicated to external interested parties. Several modes of
communication are used to communicate among the levels and functions of the Region 6 lab & field
operations and other stakeholders up-to-date on EMS activities.
Scope
This procedure is applicable to all significant environmental aspects at the Region 6 lab & field
operations as determined within the EMS. The U.S.EPA Region 6 lab & field operations
Environmental Management System (EMS) is designed to manage the environmental impacts that
result from the operations at the facility and, to a limited extent, off-site field activities. All of the
operations conducted at the facility located at 10625 Fallstone Road, Houston, Texas 77099 are
considered within the scope of the EMS. The activities of all of the occupants of the facility are subject
to the policies and procedures described in this manual. The Region 6 lab & field operations EMS is
designed to conform to the international standard ISO 14001 (1996). Environmental Management
Systems - Specification With Guidance For Use. This procedure applies to all EPA and contractor
personnel working at the Region 6 lab & field operations Region 6 facility.
Definitions
N/A
Approach
1. Region 6 lab & field operations communicates its significant environmental aspects to external
interested parties using the following means:
1.1. The Region 6 lab & field operations Internet EMS website lists the significant
environmental aspects for the Region 6 lab & field operations. An email address is
provided to allow external interested parties to submit questions or input regarding the
region 6 lab & field operations significant environmental aspects or other components of
the EMS.
1.2. The EMS Coordinator regularly corresponds with external parties to exchange
information about the Region 6 lab & field operations EMS, including the region 6 lab
& field operations significant environmental aspects.
Communication approaches may include:
• Written EMS procedures
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• Training events
• Newsletters
• Management briefings
• Meetings of EMS Team, EMS workgroups, Internal Auditor Group, Region 6 lab & field
operations Administrative Team Board
• Presentations at open meetings/conferences
Any written inquiries from external parties regarding environmental performance or other aspect of the
EMS are forwarded to the EMS Coordinator. The EMS Coordinator is responsible for coordinating a
response (e.g. in consultation with the Lab Director). A documented response is provided to the
external party in a timely manner.
The Region 6 lab & field operations EMS team provides important communications regarding the
environmental performance of the Region 6 lab & field operations facility systems and environmental
programs. It is the responsibility of the EMS Coordinator to ensure that information is disseminated to
EMS stakeholders.
2. Region 6 lab & field operations communicates its significant environmental aspects to external
interested parties using the following means:
2.1. The Region 6 lab & field operations Internet EMS website lists the significant
environmental aspects for Region 6 lab & field operations. An email address is
provided to allow external interested parties to submit questions or input regarding the
HOUSTON LAB significant environmental aspects or other components of the EMS.
2.2. The EMS Coordinator regularly corresponds with external parties to exchange
information about the Region 6 lab & field operations EMS, including the HOUSTON
LAB significant environmental aspects.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects"
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M. EMS Procedure for Communicating with Suppliers and Contractors
Purpose
The purpose of this procedure is to communicate relevant information about the region 6 lab & field
operations EMS, including EMS policies and procedure, to suppliers and contractors who do business
with the Region 6 lab & field operations. This procedure addresses communication with suppliers and
contractors supporting EMS implementation at the Region 6 lab & field operations.
Scope
All aspects of the region 6 lab & field operations EMS that affect or apply to work conducted by or
goods supplied by suppliers and contractors will be communicated to ensure the effectiveness of the
EMS. The U.S.EPA Region 6 lab & field operations Environmental Management System (EMS) is
designed to manage the environmental impacts that result from the operations at the facility and, to a
limited extent, off-site field activities. All of the operations conducted at the facility located at 10625
Fallstone Road, Houston, Texas 77099 are considered within the scope of the EMS. The activities of
all of the occupants of the facility are subject to the policies and procedures described in this manual.
The Region 6 lab & field operations EMS is designed to conform to the international standard ISO
14001 (1996). Environmental Management Systems - Specification With Guidance For Use. This
procedure applies to all EPA and contractor personnel working at the Region 6 lab & field operations
Region 6 facility.
Definitions
N/A
Approach
Region 6 lab & field operations personnel shall follow established EPA guidelines for all procurement
of EMS related items. This includes communication guidelines established by EPA Region 6 and
Headquarters requirements.
1. The EMS Team reviews all aspects of Houston's operations involving contractors or suppliers that
may interact with the EMS or affect environmental performance. This includes but is not limited
to:
1.1. Work performed by contractors or suppliers, or products or services provided by
contractors or suppliers, that may interact with Houston's Significant Environmental
Aspects,
1.2. Work performed by contractors or suppliers, or products or services provided by
contractors or suppliers, that could create an Environmental Aspect.
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2. To conduct this review, the EMS Team involves staff from the Region 6 lab & field operations
Contracting/Purchasing Office.
3. For those contractor or supplier activities or products identified as "environmentally sensitive" as a
result of this review, the Contracting/Purchasing office (with support from the EMS Team, as
needed) meets with the contracting official or project officer responsible for managing the
contractor or supplier and communicates these findings.
4. As part of this meeting, the group will develop a strategy for addressing the contractor or supplier
issue. Strategies may include:
4.1. Contacting the contractor or supplier to convey the concerns about the activity, product,
or service in question,
4.2. Providing the contractor or supplier with information to assist them in understanding and
addressing the issue,
4.3. Initiating a modification to a contract or purchase specification to address the issue.
Such modification could include a requirement for contractors or suppliers to take part
in the EMS awareness training.
5. To support building awareness about the EMS among contractors and suppliers, the EMS Team and
the Contracting/Purchasing office may provide copies of a printed brochure to contractors and
suppliers. The brochure explains the EMS and the roles and responsibilities of contractors and
suppliers in furthering the goals of the EMS.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects"
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N. EMS Procedure for Document Control
Purpose
The purpose of this procedure is to ensure that EMS documents are controlled so that only the latest
Authorized Version of the EMS documents are in use. The EMS Team and other stakeholders
periodically review all EMS documents. In general, the EMS Manual is written and revised by the
EMS Team and offered for comment to the entire Region 6 lab & field operations.
Scope
This procedure applies to all controlled documents in the EMS. Documents formally controlled
include: (1) EMS Manual, (2) EMS Procedures, (3) Operational Controls, and (4) Environmental
Management Program (EMP) Forms. The U.S.EPA Region 6 lab & field operations Environmental
Management System (EMS) is designed to manage the environmental impacts that result from the
operations at the facility and, to a limited extent, off-site field activities. All of the operations
conducted at the facility located at 10625 Fallstone Road, Houston, Texas 77099 are considered within
the scope of the EMS. The activities of all of the occupants of the facility are subject to the policies
and procedures described in this manual. The REGION 6 LAB & FIELD OPERATIONS EMS is
designed to conform to the international standard ISO 14001 (1996). Environmental Management
Systems - Specification With Guidance For Use. This procedure applies to all EPA and contractor
personnel working at the Region 6 lab & field operations Region 6 facility.
Definitions
Official version of EMS document.
Approach
1. All EMS documents are created using established templates to ensure consistency in their
appearance and format.
2. All EMS documents are dated to identify when they were created. This ensures that only the
most current versions are in use.
3. All EMS documents include a signature box to identify the individual responsible for the
document.
4. All EMS documents identify those Region 6 lab & field operations employees (by name or job
function) who must be informed of revisions made to the document, and provided current
versions of the document when changes are made. Notification of changes, and transmission of
revised documents, is done by email. All EMS documents provide to the Region 6 lab & field
operations employees are in non-editable PDF format.
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5. Official copies of EMS documents are those versions signed in ink by the author. Official
copies of all EMS documents are kept and maintained by the EMS Coordinator.
6. All official copies of EMS documents include a version tracking page that identifies the date of
the revisions, and the nature of the revisions.
7. When revisions are made to any EMS document, one copy of the superceded version is selected
by the EMS Coordinator and filed for two years or as otherwise required by law. After two
years, files shall be copied electronically for future reference.
8. All current versions of EMS documents are posted to the Region 6 lab & field operations EMS
Intranet site in non-editable PDF format. The EMS Coordinator is responsible for providing
PDF versions of all documents to the EPA EMS webmaster. All region 6 lab & field operations
staff are instructed where to find EMS documents on the Region 6 lab & field operations EMS
Intranet site during Awareness Training Sessions, and through other EMS communications.
The key EMS documents include:
I-MS Document
Document
Control Code
Document Purpose
EMS Manual
EM-xx
To describe the overall structure and function of the
EMS
Environmental
Management Program
Forms
EMP-xx
To document the specific content of the EMS
components relative to each identified significant
aspect
Corrective Action Forms
CA-xx
To initiate a process of investigating the need for
changes to EMS procedures
Internal Audit Plans
IAP-xx
To define audit scope, criteria and logistics
Procedures
EP-xx
To standardize specific procedures to be followed
Records
no specific code
To document that the actions specified in the EMS
Manual and EMS Programs are followed and that
operational controls are effective
The electronic versions of current EMS documents are maintained on a local area network directory
that is accessible to all Region 6 lab & field operations staff. The main folder is titled Environmental
Management Systems. Sub-folders under the main folder are clearly labeled (e.g., EMS Procedures or
EMS Manual). Obsolete documents are removed from the folder and archived by the EMS Coordinator
according to EPA record control procedures. Identify where these procedures are located. Any hard
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copies made of controlled EMS documents shall be stamped "copy" and shall be destroyed when
obsolete.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects"
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0. EMS Procedure for Records Management
Purpose
The purpose of this procedure is to ensure that EMS records are properly identified, retained and
maintained. A document control system is utilized to ensure that only the most recent versions of the
EMS Manual and the EMS Procedures are available for reference.
Scope
This procedure applies to all records generated as a result of the EMS. Records are essential to
document the development, operation, and performance of the EMS. Examples of records include:
meeting minutes, training records, audit reports, contract language, complaints, maintenance records,
etc. The U.S.EPA Region 6 lab & field operations Environmental Management System (EMS) is
designed to manage the environmental impacts that result from the operations at the facility and, to a
limited extent, off-site field activities. All of the operations conducted at the facility located at 10625
Fallstone Road, Houston, Texas 77099 are considered within the scope of the EMS. The activities of
all of the occupants of the facility are subject to the policies and procedures described in this manual.
The Region 6 lab & field operations EMS is designed to conform to the international standard ISO
14001 (1996). Environmental Management Systems - Specification With Guidance For Use. This
procedure applies to all EPA and contractor personnel working at the Region 6 lab & field operations
Region 6 facility.
Definitions
N/A
Approach
The specific records associated with each significant environmental aspect are listed on the EMP Forms
including the location and the owner of each record. In general the EMS Coordinator maintains the
system level EMS records (e.g., EMS policy, aspect analysis data, EMS Team meeting minutes) and
the Facility and SHEM Managers maintain the facility level records (e.g., building performance data,
facility O&M contractor training). The disposition of EMS records follows the EPA record control
policies.
1. All EMS records will be identified as such with a notation or cover page.
2. Records shall be legible, identifiable, and easily retrieved for review.
3. Records shall be maintained for all projects that have active environmental management
programs. At a minimum, this includes: training records, internal audit records, and
management review records.
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Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects"
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P. EMS Procedure for Addressing Non-Conformance, and Conducting Corrective and
Preventative Actions
Purpose
The purpose of this procedure is to define responsibility and authority for handling and investigating
EMS nonconformance's, for taking action to mitigate any impacts caused by EMS nonconformance,
for initiating and completing corrective and preventive action, and for reporting trends in
nonconformance to management during management review. The necessary competencies are
described in the EMP Forms.
Scope
Nonconformance is any deviation from established policy, procedures, programs and other
arrangements related to the EMS. Nonconformance may include regulatory noncompliance or
noncompliance with other requirements. Note that not all incidents of noncompliance are necessarily
incidents of nonconformance.
This procedure does not apply to nonconformance that is identified during an internal or external EMS
audit. Procedures for handling and responding to nonconformance discovered during an EMS audit are
defined in Q—Auditing and Compliance.
The U.S.EPA Region 6 lab & field operations Environmental Management System (EMS) is designed
to manage the environmental impacts that result from the operations at the facility and, to a limited
extent, off-site field activities. All of the operations conducted at the facility located at 10625 Fallstone
Road, Houston, Texas 77099 are considered within the scope of the EMS. The activities of all of the
occupants of the facility are subject to the policies and procedures described in this manual. The
Region 6 lab & field operations EMS is designed to conform to the international standard ISO 14001
(1996). Environmental Management Systems - Specification With Guidance For Use. This procedure
applies to all EPA and contractor personnel working at the Region 6 lab & field operations Region 6
facility.
Definitions
EMS nonconformance: Any non-conformance with written the Region 6 lab & field operations EMS
procedures, the EMS Policy, Environmental Management Programs, or Operational Controls developed
under the EMS.
Approach
In general, actual competencies are tested against required knowledge, skills, and abilities when an
Individual is hired for a given job. To the extent necessary, competencies are further developed
through formal training and/or on-the-job training. By hiring competent staff and contractors EMS
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systems will reduce non-conformance of EMS objectives and targets. EMS Team and Committee
Members shall implement corrective and preventative actions while tracking and implementing their
respective Environmental Aspect.
The results of checks of the EMS are used to ensure that controls are operating properly and the EMS is
functioning and continually improving. When nonconformances are detected, the SHEM Manager, the
Facility Manger or the EMS Coordinator initiates corrective action. Procedure should authorize all
employees to report nonconformances or suspected nonconformances. When the SHEM or Facility
Manger detects the need for corrective action, they initiate and document the corrective action using
work assignments, written procedures, workgroup meetings and/or training. The EMS Team provides
recommendations to the Region 6 lab & field operations Administrative Team for corrective actions.
The supervisors and/or the SHEM Manager are responsible for coordinating completion of agreed
corrective actions within their organizations.
Preventive actions are documented in the OCFs for each significant environmental aspect. Examples of
preventive actions include alarm systems, regular inspections, maintenance of monitoring equipment,
and environmental audits.
1. All employees are authorized and required to report any suspected nonconformance in the EMS
to the EMS Coordinator. Reporting of suspected nonconformance may be done by e-mail,
phone call, conversation, or letter.
2. Although employees are encouraged to identify themselves when reporting suspected
nonconformance (to assist in verifying evidence of nonconformance) employees may also
report suspected nonconformance anonymously via the "Report an EMS Nonconformance"
button on the Region 6 lab & field operations EMS intranet page.
3. The EMS coordinator records information about the suspected nonconformance using the
corrective action form shown below as Attachment 1.
4. The EMS Coordinator may investigate the suspected nonconformance or assign the task of
investigation to someone else (e.g., a member of the internal auditing team).
5. The investigator will take actions necessary to:
a. Determine the circumstances surrounding the suspected nonconformance,
b. Evaluate the scope and severity of the nonconformance,
c. Assess any implications (environmental or otherwise) of the nonconformance,
d. Initiate any immediate response necessary,
e. Determine the root cause, and
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f. Decide on any corrective actions that need to be taken.
6. In Region 6 lab & field operations to determine the necessary corrective action, the investigator
may consult with others including the EMS Coordinator, EMS Team, EMS Internal Audit
Team, EMS Advisory Committee, or Management.
7. All recommended corrective action is subject to verification by the EMS Coordinator or his/her
designee. The individual responsible for verification shall make observations in the designated
section of Attachment 1.
8. Copies of all supporting information collected during a nonconformance investigation are kept
on file by the EMS Coordinator and retained along with Attachment I.
9. Serious procedural gaps, evidence of systemic nonconformance, or other findings suggesting
major deficiencies in the EMS as a whole are brought to the immediate attention of the EMS
Coordinator. The EMS Coordinator investigates such findings and, in consultation with the
EMS Team, the Internal Audit Team, and/or the EMS Advisory Committee, prepares a report to
management. The report includes recommendations for corrective actions and any other action
that may be warranted. Corrective actions that may require significant resource allocations
include an estimate of the type and amount of resources required.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
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Q. EMS Procedure for Conducting Internal EMS and Compliance Status Audits
Purpose
The purpose of this procedure is to establish a process for periodically determining whether the EMS
conforms to planned arrangements for environmental management. The EMS audit determines
whether the EMS has been properly designed, implemented, maintained, and is functional.
Environmental Management System audits are not compliance audits. They are system audits to verify
the workings of the management system. If compliance data is examined, it is for the purpose of
verifying that the environmental programs are sufficient to achieve compliance with legal requirements.
Systems audits are used to ensure conformance to ISO 14001:1996 and to identify continual
improvement opportunities. Two types of EMS audits are conducted at the Region 6 lab & field
operations: internal and external third-party audits.
Scope
This procedure applies to all elements of the region 6 lab & field operations EMS. The region 6 lab &
field operations EMS audit scope includes all activities, products, and services that are within the
defined scope of the region 6 lab & field operations EMS. The U.S.EPA Region 6 lab & field
operations Environmental Management System (EMS) is designed to manage the environmental
impacts that result from the operations at the facility and, to a limited extent, off-site field activities.
All of the operations conducted at the facility located at 10625 Fallstone Road, Houston, Texas 77099
are considered within the scope of the EMS. The activities of all of the occupants of the facility are
subject to the policies and procedures described in this manual. The Region 6 lab & field operations
EMS is designed to conform to the international standard ISO 14001 (1996). Environmental
Management Systems - Specification With Guidance For Use. This procedure applies to all EPA and
contractor personnel working at the Region 6 lab & field operations Region 6 facility.
Definitions
N/A
Approach
1. Audit Team and Team Leader
1.1. As part of the EMS implementation, Houston Lab established an Internal EMS Audit
Team. The internal EMS audits are led by the Audit Team Leader, who is
recommended by the EMS Coordinator and is approved by the EMS Advisory
Committee.
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1.2. The Audit Team Leader is supported by a team of qualified personnel from various parts
of the Region 6 lab & field operations. The Audit Team Leader is responsible for
recruiting Audit Team members, who must then be approved by the EMS Advisory
Committee. To assure objectivity, the Audit Team should include personnel not directly
responsible for the area(s) being audited.
1.3. Audit Team members should have formal training in EMS auditing, or possess specific
skills or knowledge of pertinent technical issues, regulations, management systems,
and/or facility processes and products.
1.4. All personnel acting as Audit Team members should have received adequate training in
the requirements of respective standard and internal auditing techniques prior to
performing an audit. Auditor orientation and training should include, as a minimum, the
following activities:
¦ Review of the relevant ISO 14001 standard and pertinent elements to be audited,
¦ Defining of the auditor(s) role, responsibilities, and auditing techniques,
¦ Determining the scope of the audit and review of relevant documents and procedures,
¦ The method of documenting the audit and nonconformance.
1.5. Training may be accomplished through either:
¦ The successful completion of an internal auditing course or lead auditor course by a
recognized third party,
¦ Internal auditor training provided by personnel who have successfully completed an
internal auditor or lead auditor training course.
2. Audit standard
2.1. The EMS Audit Team Leader, in consultation with the EMS Coordinator, EMS Team,
EMS Advisory Committee, and top management determines the criteria to be used as the
audit standard.
3. Audit plan
3.1. The EMS Audit Team, under direction of the Audit Team Leader, develops an overall
audit plan for the Region 6 lab & field operations. The audit plan covers the following
elements:
¦ The specific areas, functions, procedures, and activities to be audited,
¦ Personnel qualified to perform the audits,
¦ Audit schedule, duration, and frequency,
¦ Audit processes and techniques,
¦ Development and implementation of corrective action to resolve cited audit
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discrepancies.
4. Audit schedule and frequency
4.1. An audit schedule is developed and conveyed to the audit team via an audit plan
prepared by the Audit Team Leader. The audit frequency is based on the status and
importance of the system elements defined in the EMS manual, as determined by:
¦ Significant Environmental Aspects or risks and hazards,
¦ Concerns raised by interested parties,
¦ Results of third party and internal audits,
¦ Concerns raised during Management Reviews,
4.2. All applicable system elements shall be audited a minimum of once annually.
4.3. Audit frequency and scheduling includes auditing all areas of the Region 6 lab & field
operations against all elements of the audit standard. Audit frequency and scope for the
various areas of the Region 6 lab & field operations will be determined by the Audit
Team Leader and communicated to the audit team.
5. Audit process
5.1. For each audit, an Audit Team Leader is identified.
5.2. The Audit Team Leader is responsible for
¦ Assigning audit responsibilities to the audit team members,
¦ Developing the audit plan,
¦ Conducting audit team meetings,
¦ Conducting opening and closing meetings with the auditee(s),
¦ Resolving differences of opinion among audit team members,
¦ Maintaining communications with the auditee(s) throughout the audit,
¦ Preparing the final audit report,
¦ Communicating the findings of the audit report to top management in association with
R—Management Review.
5.3. The audit plan consists of requirements for the following elements:
¦ Audit team identification
¦ Pre-audit review
¦ Opening meeting
¦ Data collection
¦ Data review and analysis
¦ Closing meeting
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¦ Reporting
¦ Audit program evaluation
5.4. Each section of the EMS Manual is considered a system of elements. Auditors normally
review a minimum of three randomly chosen sets of supporting records and other
supporting documentation for conformance with the EMS Manual section.
5.5. The EMS audit is conducted primarily through the review of records, observations of
operations, and interviews with personnel. EMS audits may involve sampling
compliance data to ascertain whether compliance programs are achieving their intended
objectives.
¦ Interviews. Interviews are conducted in the employee's normal work area, if possible,
so that actual processes can be observed and any records or related data are available for
review.
¦ Records review. The records review is typically conducted prior to actual interviews,
while physical inspections with follow up reviews are conducted following the findings
of previous steps.
¦ Physical inspection and observation. A physical inspection of the facility, process, or
designated areas of the facility is conducted.
5.6. Information obtained from interviews, Record reviews, and physical inspection and
observation is documented.
5.7. Upon completion of the audit, the audit team meets with relevant management
representative(s) and departmental supervisors to advise them of the audit results.
6. Audit findings
6.1. EMS audit findings are based on objective evidence that is properly corroborated and
authenticated. Audit findings are not based on hearsay or opinions.
6.2. Each audit team member is responsible for obtaining an objective review of his/her audit
findings from another audit team member. The goal is to ascertain whether another
independent auditor comes to the same conclusions when presented with the facts.
6.3. All final findings must represent the consensus opinion of the entire Audit Team.
6.4. At the conclusion of the audit, the Audit Team reviews their consensus findings verbally
with the EMS Team during an exit briefing. This briefing is an opportunity for
questions and clarifications between the Audit Team and the EMS Team.
7. Audit reporting
7.1. The Internal EMS Audit Team submits completed audit documents to the Audit Team
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Leader, who prepares the Final Audit Report. The Final Audit Report includes the
following sections:
¦ Introduction and scope, describing what was covered in the audit
¦ Description of areas reviewed and related activities
¦ Assessment date(s)
¦ Audit team members and areas of responsibility
¦ Individuals interviewed and respective areas of responsibility
¦ Audit findings
7.2. The final Audit Report is submitted by the EMS Coordinator to top management for
appropriate action according to Management Review.
8. Corrective Action
8.1. The responsibility for corrective action to address EMS internal audit findings lies with
the EMS Coordinator. The EMS Coordinator may consult with the EMS Team, EMS
Advisory Committee, or top management in Region 6 lab & field operations to develop
corrective action recommendations. Corrective action implementation and follow-up
will be as specified under Handling Nonconformance's.
Staff of the Region 6 lab & field operations conducts internal audits. Internal auditors receive formal
EMS audit training. The internal audit program is based on FDIS ISO 19011:2002. The EMS
Coordinator is responsible for forming the internal audit group and ensuring the auditors receive
training. An Audit Team Leader is identified. The Team Leader is responsible for drafting an audit
plan and submitting it to the EMS Coordinator. The audit plan specifies the logistics, scope, objectives
and criteria for the audit. The Audit Team conducts the audit and submits a written report to the EMS
Team. The EMS Team reviews the report and constructs a corrective action response, which includes
recommendations and resource estimates for corrective actions. The EMS Coordinator for
consideration and implementation decisions presents the corrective action response to the Region 6 lab
& field operations Administrative Team. It is the responsibility of the EMS Coordinator and the EMS
Team to ensure that needed corrective actions are completed in a timely manner. All audit plans, audit
reports and corrective action plans are retained as EMS records.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\ "A. EMS
Procedure for Identifying Significant Environmental Aspects "
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R. EMS Procedure for Conducting Management Review
Purpose
To specify the procedure for top management review of the EMS to ensure its continuing effectiveness,
suitability and adequacy and to provide for its continual improvement. The Region 6 lab & field
operations Administrative Team at least once per year conducts planned formal reviews of the EMS.
During these reviews the EMS Coordinator and the EMS Team provide the REGION 6 LAB & FIELD
OPERATIONS Administrative Team with information on performance of the EMS and it's ability to
meet the commitments stated in the Region 6 lab & field operations EMS Policy.
Scope
Management will review the results of the EMS to provide for its continual improvement. The
U.S.EPA Region 6 lab & field operations Environmental Management System (EMS) is designed to
manage the environmental impacts that result from the operations at the facility and, to a limited extent,
off-site field activities. All of the operations conducted at the facility located at 10625 Fallstone Road,
Houston, Texas 77099 are considered within the scope of the EMS. The activities of all of the
occupants of the facility are subject to the policies and procedures described in this manual. The
Region 6 lab & field operations EMS is designed to conform to the international standard ISO 14001
(1996). Environmental Management Systems - Specification With Guidance For Use. This procedure
applies to all EPA and contractor personnel working at the Region 6 lab & field operations Region 6
facility.
Definitions
N/A
Approach
1. Management will conduct an annual EMS review. The EMS Coordinator will prepare the necessary
input to be considered in the review. Items to be included in the information presented may include
the following:
1.1 .EMS Audit results
1.2.Monitoring and Measurement of environmental indicators
1.3. Achievement of objectives and targets in the EMS
1.4.Regulatory compliance status
1.5.Correction and prevention of non-conformances in the EMS
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1.6. Any other relevant information on the EMS.
2. Upon review of the above information, management shall make a determination on the continuing
effectiveness of the EMS implementation and specifically on its ability to achieve the objectives
and targets. Management will also consider whether the system continues to be adequate and
suitable for its intended purpose.
3. Having made these determinations, management will then give directions on any necessary
changes to the EMS to ensure its continual improvement. These may be direct changes to the
environmental policy, objectives and other elements of the environmental management system.
The EMS Coordinator provides data on progress toward meeting targets and objectives. The EMS
Team is responsible for compiling performance data for the review (e.g., Energy Conservation,
recycling data, waste management). The results of the management review including any needed
changes to policy, procedures, and/or resource allocation are documented in meeting minutes and
subsequent changes to EMS documents. In addition, the EMS Coordinator provides EMS updates
during quarterly Region 6 lab & field operations Administrative Team meetings to maintain an ongoing
awareness.
4. Management will conduct an annual EMS review. The EMS Coordinator will prepare the necessary
input to be considered in the review. Items to be included in the information presented may include
the following:
4.1 .EMS Audit results
4.2.Monitoring and Measurement of environmental indicators
4.3. Achievement of objectives and targets in the EMS
4.4.Regulatory compliance status
4.5.Correction and prevention of non-conformances in the EMS
4.6. Any other relevant information on the EMS.
5. Upon review of the above information, management shall make a determination on the continuing
effectiveness of the EMS implementation and specifically on its ability to achieve the objectives
and targets. Management will also consider whether the system continues to be adequate and
suitable for its intended purpose.
6. Having made these determinations, management will then give directions on any necessary
changes to the EMS to ensure its continual improvement. These may be direct changes to the
environmental policy, objectives and other elements of the environmental management system.
Also, management will communicate the results of the review to all employees.
Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: S:\EnvironmentalManagementSystems\
"A. EMS Procedure for Identifying Significant Environmental Aspects "
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Section 5 — EMS Programs and Controls
Introduction
This section includes documentation or references that allow the user to locate relevant documentation
associated with the following EMS areas.
A. EMS Audit Program: Describes the EMS Audit program conducted at the Region 6 Laboratory
in Houston, Texas. This includes:
Audit program scope
Audit program objectives
Roles, authorities, and responsibilities
Audit or qualification and training
Auditor schedule
B. Environmental Management Programs (EMPs): Are action plans designed to achieve the
Region 6 Laboratory EMS objectives and targets.
C. Operational Controls (OCs): Describes the OCs implemented for operations, activities,
processes, products, and services with environmental aspects the Region 6 Laboratory.
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A. EMS Audit Program
Purpose
Systems audits are used to ensure conformance to ISO 14001:1996 and to identify continual
improvement opportunities. EMS audits are conducted at the Region 6 lab & field operations using
internal and external third-party audits.
Scope
The U.S.EPA Region 6 lab & field operations Environmental Management System (EMS) is designed
to manage the environmental impacts that result from the operations at the facility and, to a limited
extent, off-site field activities. All of the operations conducted at the facility located at 10625 Fallstone
Road, Houston, Texas 77099 are considered within the scope of the EMS. The activities of all of the
occupants of the facility are subject to the policies and procedures described in this manual. The
Region 6 lab & field operations EMS is designed to conform to the international standard ISO 14001
(1996). Environmental Management Systems - Specification With Guidance For Use. This procedure
applies to all EPA and contractor personnel working at the Region 6 lab & field operations Region 6
facility.
Definitions
N/A
Approach
Staff of the Region 6 lab & field operations conducts internal audits. Internal auditors receive formal
EMS audit training. The internal audit program is based on FDIS ISO 19011:2002. The EMS
Coordinator is responsible for forming the internal audit group and ensuring the auditors receive
training. An Audit Team Leader is identified. The Team Leader is responsible for drafting an audit
plan and submitting it to the EMS Coordinator. The audit plan specifies the logistics, scope, objectives
and criteria for the audit. The Audit Team conducts the audit and submits a written report to the EMS
Team. The EMS Team reviews the report and constructs a corrective action response, which includes
recommendations and resource estimates for corrective actions. The EMS Coordinator for
consideration and implementation decisions presents the corrective action response to the Region 6 lab
& field operations Administrative Team. It is the responsibility of the EMS Coordinator and the EMS
Team to ensure that needed corrective actions are completed in a timely manner. All audit plans, audit
reports and corrective action plans are retained as EMS records.
Documentation
Copies of all audits will be filed in the EMS Coordinator's office and be available for review by the
Region 6 lab & field operations Administrative Team.
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Records: All relevant records for the Region 6 lab & field operations EMS can be located on the
Region 6 shared directories, see records section in: "A. EMS Procedure for Identifying Significant
Environmental Aspects "
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B. Environmental Management Programs (EMPs)
Introduction
This manual contains the Environmental Management Programs developed to achieve objectives and
targets.
Environmental management programs (EMPs) are in place for each significant environmental aspect.
EMPs are designed to manage the activities that substantially contribute to the impacts of the
significant aspects and to achieve EMS targets and objectives. At any given time the EMP is
comprised of existing program components and/or new program components that will result from
targets. The details of the EMPs including Individual responsibilities and operational controls are
documented in the EMP Forms. The EMS Coordinator is responsible for maintaining the EMP Forms.
List of EMPs:
1. EMP Air Emission
2. EMP Chemical Management
3. EMP Energy Conservation
4. EMP Water Conservation
5. EMP Waste Reduction
6. EMP Noise Reduction (not included, determined NOT to be a SAE)
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EMP 1.0 Air Emission
Knviron mental Management Program l'orm
Significant Environmental Aspect:
Air Emissions (from stationary sources)
Document Control Code: EMP-01.00
Date: September 9. 2003
Objcclivc(s):
a.
b.
c.
d.
To maintain compliance with Federal, State and local regulations concerning air emissions.
[Note: Per agreement with the REGION 6 LAB & FIELD OPERATIONS Administrative Team, objectives b, c, and d below have been
deferred.]
Ascertain the amount and type of pollutants (baseline data) that are released to the environment through air emissions.
Evaluate baseline data on the amount and type of pollutants that are released to the environment through air emissions, then develop
strategies (if possible or feasible) to reduce facility/laboratory air emissions.
Increase awareness and involvement of REGION 6 LAB & FIELD OPERATIONS employees to specific facility/laboratory activities that
have been identified to reduce the release of pollutants to the air.
Target(s):
a.
b.
c.
d.
100% compliance with all applicable air emission regulations.
[Note: Per agreement with the REGION 6 LAB & FIELD OPERATIONS Administrative Team, objectives b, c, and d below have been
deferred.]
Gather and formalize baseline data on the amount and type of pollutants being released to the air within one year of initial meeting
between EMS Team and EMP Workgroup.
Determine whether opportunities exist to implement strategies to reduce facility/laboratory air emissions within six months of finalizing
the baseline air emissions data.
Increase the awareness and involvement of REGION 6 LAB & FIELD OPERATIONS employees by conducting activities such as posting
information, conducting training sessions and holding brown bag lunches on selected facility/laboratory activities that result in the release
of pollutants to the air within six months of finalizing strategy to reduce air emissions.
Reason for Significance:
a.
b.
c.
Legal and Other Requirements
Appears on the REGION 6 LAB & FIELD OPERATIONS "High Significance Report"
Existing Program
Potential Environmental Impacts:
a.
b.
Release of pollutants
Regulated
Specific Legal and Other Requirements:
a.
Federal Code, Clean Air Act (CAA) 42 U.S.C. 7412, § 112(r), "Prevention of Accidental Releases." Owner or operator of a facility at
which a regulated substance is present in more than the threshold quantity must prepare, register, and implement a Risk Management Plan.
(Regulated substances and quantities listed in 40 CFR part 68. Verify REGION 6 LAB & FIELD OPERATIONS does not have chemicals
in excess of part 68 thresholds.)
b.
EPA regulation, 40 CFR Part 68, Subpart F, "Regulated Substances for Accidental Releases" (under CAA § 112(r)). Regulated toxic and
flammable substances and threshold quantities required under § 112(r) of the CAA are listed in Tables 1, 2, 3, and 4 of 40 CFR 68.130.
c.
EPA regulation, 40 CFR Part 60, Subpart Dc, "Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating
Units." Implemented through Region 6 lab & field operation's EPA/TX State Permits 02-9-0613N (Standby Diesel Generator) and 02-5-
0473, 02-5-0474, 02-50475N (3 Dual-fired Boilers). Keep records of low-sulfur fuel purchases, fuel usage, hours of operation, amount of
fuel combusted. Permit includes TX (COMAR) requirements listed below.
d.
EPA regulation, 40 CFR Part 82, Subpart F, under authority of CAA, "Recycling and Emissions Reduction" Maintain, service, repair, and
dispose of appliances without releasing class I or class II substances used as a refrigerant.
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Kn> iron mental Management Program Form
e.
Executive Order 13148, "Greening of the Government Through Leadership in Environmental Management." § 201. Environmental
Management. Through development and implementation of environmental management systems, each agency shall ensure that strategies
are established to support environmental leadership programs, policies, and procedures and that agency senior level managers explicitly
and actively endorse these strategies. §s 206, 505, 703. Reductions in Ozone-depleting Substances. Each agency shall develop a plan to
phase out the procurement of Class I ozone-depleting substances; maximize use of safe alternatives; phase out Class I ozone-depleting
substance applications; preclude disposal of ozone-depleting substances removed or reclaimed from its facilities or equipment. § 305.
Policies, Strategies, and Plans. By March 31, 2002, each agency shall ensure it facilities develop a written plan that sets forth the facility's
contribution to the goals and requirements established in this order. The plan should reflect the size and complexity of the facility. Where
pollution prevention plans or other formal environmental planning instruments have been prepared for agency facilities, an agency may
elect to update those plans to meet the requirements and goals of this §. § 307. Annual Reports. Each agency shall submit an annual
progress report to the Administrator on implementation of this order. § 402. Facility Compliance Audits. Within 12 months of the date of
this order, each agency with an established regulatory environmental compliance audit program may elect to conduct EMS audits in lieu of
regulatory compliance audits at selected facilities within 6 months of development of EMS program. § 505. Reductions in Ozone-
Depleting Substances. To attain the goals of § 206 of this order, each agency shall ensure that its facilities maximize the use of safe
alternatives to ozone-depleting substances; evaluate the present and future uses of ozone-depleting substances; and develop a plan to phase
out the procurement of Class I ozone-depleting substances for all non-excepted uses by December 31, 2010.
f.
Executive Order 13101, "Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition" § 101, 102, 401.
Prevent pollution whenever feasible; acquire environmentally preferable products. Consider the following factors in acquisition planning:
use of biobased products; use of recovered materials; reuse of product; life cycle cost; recyclability; use of environmentally preferable
products; waste prevention (including toxicity reduction or elimination); and ultimate disposal. Program and acquisition managers should
take an active role in these activities. § 402. Develop and implement affirmative procurement programs. Agencies shall ensure that their
affirmative procurement programs require 100 percent of their purchases of products to meet or exceed the EPA guideline unless written
justification is provided that a product is not available competitively within a reasonable time frame, does not meet appropriate
performance standards, or is only available at an unreasonable price. § 502 (c). Once the EPA in the Comprehensive Procurement
Guidelines has designated items containing recovered materials, agencies shall modify their affirmative procurement programs to require
that, to the maximum extent practicable, their purchases of products meet or exceed the EPA guidelines.
Performance Indicators:
a.
b.
c.
d.
No regulatory findings for air emissions being listed on any internal or external compliance inspection report.
Note: Per agreement with the REGION 6 LAB & FIELD OPERATIONS Administrative Team, performance indicators b. c. and d
below have been deferred.
Final report containing the baseline data on the amount and type of pollutants being released to the air from the REGION 6 LAB & FIELD
OPERATIONS completed within one year of initial meeting between EMS Team and EMP Workgroup.
Final report containing existing opportunities to implement strategies to reduce facility/laboratory air emissions completed within six
months of finalizing the baseline air emissions data.
Documentation of training sessions, brown bag lunches, etc. being conducted within one year of finalizing the baseline air emissions data.
Program Description:
a.
The REGION 6 LAB & FIELD OPERATIONS currently maintains an air emissions program for its emergency power generator and
various CFC containing devices as part of its overall facility operation and maintenance program.
b.
Components of the program include: Regulatory reviews, monthly NOx emissions calculations, annual combustion analyses, visible
emission prohibitions, equipment inspections, annual preventive maintenance, personnel certifications and training requirements, fuel
specifications & content requirements, annual internal and triennial external audits.
c.
In addition, the REGION 6 LAB & FIELD OPERATIONS currently has established procedures for recovering solvents used during
sample preparations or the analysis of samples, instead of allowing them to escape up the laboratory fume hoods.
d.
However, REGION 6 LAB & FIELD OPERATIONS does not maintain equipment-specific procedures for solvent recovery due to
mission-related objectives.
e.
The REGION 6 LAB & FIELD OPERATIONS air emissions program also considers indoor pesticide applications. Pesticides are applied
by a pesticide applicator that must follow Federal, state, and local requirements.
Operation Control: (See Operational Controls Form, separate page)
Budget (Resources): Target: Facility Manager = 5 hours/year SHEM Manager = 5 hours/year Air Team =150 hours/year
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Structure. Authorities. Responsibilities
Tasks
Responsible Person/Group
a. Regulatory review and updates
b. Fuel purchase, specifications & content requirements
c. NOx emissions calculations
d. Annual combustion analyses
e. Equipment inspections
f. Annual preventive maintenance, Corrective actions
a. Air Team Leader
b. Enforcement Team Leader
c. Air Team Leader
d. Air Team Leader
e. Building Engineer
f. Building Engineer
Record(s):
Responsible Person and Record Location
a. Certificate of fuel quality, Fuel usage, hours of operation
b. Equipment inspection and survey reports, Preventive maintenance records
c. Monthly NOx emission calculations
d. Annual boiler/generator combustion analysis
e. visible emissions inspection
f. Regulatory review, Internal/external inspection reports
a. Enforcement Lead
b. Building Engineer
c. Building Engineer
d. Air Team Lead
e. Building Engineer
f. EMS Lead Auditor
Document(s):
a. Air permits
b. SOPs for REGION 6 LAB & FIELD OPERATIONS
c. Position Description: SHEM Manager
d. Position Description: Facility Manager
e. Chemical Hygiene Plan
a. Facility Manager
b. QA Lead
c. Branch Chief
d. Branch Chief
e. SHEM Manager
Competence of persons responsible on basis oftraining. education or experience:
Title:
a. SHEM
Manager
b. Facility
Manager
Competence:
a. Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment
b. Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment
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EMP 2.0 Chemical Management
Knviron mental Management Program l'orm
Significant Environmental Aspect:
Chemical Management
Document Control Code: EMP-02.00
Date: September 21. 2007
Objcclive(s):
To maintain compliance with Federal, State and local regulations concerning chemical management, chemical inventory, and hazardous
waste management.
[Note: Per agreement with the Region 6 Lab & Field Operations Administrative Team, objectives b, c, and d below have been deferred.]
Ascertain the amount and type of pollutants (baseline data) that are released to the environment through chemical usage.
Evaluate baseline data on the amount and type of pollutants that are released to the environment through chemical usage, then develop
strategies (if possible or feasible) to reduce facility/laboratory chemical usage.
Increase awareness and involvement of Region 6 Lab & Field Operations employees to specific facility/laboratory activities that have been
identified to reduce the release of chemical pollutants to the environment.
Target(s):
100% compliance with all applicable air emission regulations.
[Note: Per agreement with the Region 6 Lab & Field Operations Administrative Team, objectives b, c, and d below have been deferred.]
Gather and formalize baseline data on the amount and type of pollutants being released within one year of initial meeting between EMS
Team and EMP Workgroup.
Determine whether opportunities exist to implement strategies to reduce facility/laboratory chemical usage within six months of finalizing
the baseline chemical usage data.
Increase the awareness and involvement of Region 6 Lab & Field Operations employees by conducting activities such as posting
information, conducting training sessions and holding brown bag lunches on selected facility/laboratory activities that result in the release
of chemical pollutants to the environment within six months of finalizing strategy to reduce air emissions.
Reason for Significance:
a. Legal and Other Requirements
b. Appears on the Region 6 Lab & Field Operations "High Significance Report"
Existing Program
Potential Environmental Impacts:
Release of pollutants
Regulated
Specific Legal and Other Requirements:
Executive Order 13148, "Greening of the Government Through Leadership in Environmental Management." § 201. Environmental
Management. Through development and implementation of environmental management systems, each agency shall ensure that strategies
are established to support environmental leadership programs, policies, and procedures and that agency senior level managers explicitly
and actively endorse these strategies. §s 206, 505, 703.
Executive Order 13101, "Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition" § 101, 102, 401.
Prevent pollution whenever feasible; acquire environmentally preferable products. Consider the following factors in acquisition planning:
use of biobased products; use of recovered materials; reuse of product; life cycle cost; recyclability; use of environmentally preferable
products; waste prevention (including toxicity reduction or elimination); and ultimate disposal. Program and acquisition managers should
take an active role in these activities. § 402. Develop and implement affirmative procurement programs.
Performance Indicators:
No regulatory findings for chemical usage being listed on any internal or external compliance inspection report.
Note: Per asreement with the Resion 6Lab & Field Operations Administrative Team, performance indicators b. c. and d below have been
deferred.
Final report containing the baseline data on the amount and type of chemical pollutants being released to the environment from the Region
6 Lab & Field Operations completed within one year of initial meeting between EMS Team and EMP Workgroup.
Final report containing existing opportunities to implement strategies to reduce facility/laboratory chemical usage completed within six
months of finalizing the baseline air emissions data.
Documentation of training sessions, brown bag lunches, etc. being conducted within one year of finalizing the baseline chemical usage
data.
Program Description:
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Kn> iron mental Management Program Form
a. Components of the program include: Regulatory reviews, monthly NOx emissions calculations, annual combustion analyses, visible
emission prohibitions, equipment inspections, annual preventive maintenance, personnel certifications and training requirements, fuel
specifications & content requirements, annual internal and triennial external audits.
b. In addition, the Region 6 Lab & Field Operations currently has established procedures for recovering solvents used during sample
preparations or the analysis of samples, instead of allowing them to escape up the laboratory fume hoods.
c. However, Region 6 Lab & Field Operations does not maintain equipment-specific procedures for solvent recovery due to mission-related
objectives.
d. The Region 6 Lab & Field Operations air emissions program also considers indoor pesticide applications. Pesticides are applied by a
pesticide applicator that must follow Federal, state, and local requirements.
Operation Control: (See Operational Controls Form, separate page)
Budget (Resources): Target: Facility Manager = 5 hours/year SHEM Manager = 5 hours/year Chemical Management Team =150 hours/year
Structure. Authorities. Responsibilities
Tasks
Responsible Person/Group
a. Regulatory review and updates
b. Equipment inspections
c. Annual preventive maintenance, Corrective actions
a. Chemical Team Leader
b. Chemical Team Leader
c. Chemical Team Leader
Record(s):
Responsible Person and Record Location
a. Equipment inspection and survey reports, Preventive maintenance records
b. Visible emissions inspection
c. Regulatory review, Internal/external inspection reports
a. Building Engineer
b. Building Engineer
c. Chemical Team Lead
Documcnt(s):
a. Chemical/hazardous waste permits
b. SOPs for REGION 6 LAB & FIELD OPERATIONS
c. Position Description: SHEM Manager
d. Position Description: Facility Manager
e. Chemical Hygiene Plan
a. Facility Manager
b. QA Lead
c. Branch Chief
d. Branch Chief
e. SHEM Manager
Competence of persons responsible on basis of training, education or experience:
Title:
c. SHEM
Manager
d. Facility
Manager
Competence:
c. Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment
d. Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment
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EMP 3.0 Energy Conservation
Environmental Management Program Form
Significant Environmental Aspect:
Encrjjv Conservation
Control Code: EMP-03.00
Dale: Septembers. 2003
Objcctivc(s):
Reduce Energy Conservation and meet Executive Orders.
Increase awareness of Houston lab employees to reduce the electrical demands of the facility.
Targcl(s):
Reduce Houston labs energy demand to contribute to the EO for the Agency's commitment of 30% reduction from bfase year by 2010.
Identify energy use areas and ways to reduce consumption within 6 months of system review surveys.
Maintain and promote awareness and involvement of HOUSTON LAB staff regarding the impacts related to consumption of electricity
through activities such as annual reports, staff meetings, reports to the HOUSTON LAB Administrative Team, e-mail, and posting
information.
Reason for Significance:
Legal and Other Requirements
Existing Program
Appears on the Houston lab "High Significance Report',
Potential Environmental Impacts:
a. Use of natural resources (including air pollution during generation)
b. Executive order
Specific Legal and Oilier Requirements:
Executive Order 13221, "Energy Efficient Standby Power Devices." Section 1. Energy-Efficient Standby Power Devices. Each agency, when
it purchases commercially available, off-the-shelf products that use external standby power devices, or that contain an internal standby power
function, shall purchase products that use no more than one watt in their standby power consuming mode. If such products are not available,
agencies shall purchase products with the lowest standby power wattage while in their standby power-consuming mode.
Executive Order 13123, "Greening the Government Through Energy Efficient Management" (sets goals for the Agency). Section 203.
Industrial and Laboratory Facilities. Through life-cycle cost-effective measures, each agency shall reduce Energy Conservation by 20 percent
by 2005 and 25 percent by 2010 relative to 1990. Section 403(b). Energy Star and Other Energy Efficient Products. Agencies shall select,
where life cycle cost-effective, Energy Star and other energy efficient products when acquiring energy-using products.
Executive Order 13148, "Greening of the Government Through Leadership in Environmental Management." Section 201. Environmental
Management. Through development and implementation of environmental management systems, each agency shall ensure that strategies are
established to support environmental leadership programs, policies, and procedures and that agency senior level managers explicitly and
actively endorse these strategies.
Performance Indicators:
a. Monthly electric meter readings by local utility
b. Electricity consumption tracking by Facility Management office
c. Daily fume hood report, monthly report to organizational managers
d. Major systems equipment run logs (air handling units, boilers, chillers, cooling tower, exhaust fans)
e. Number and type of employee awareness activities performed (annual reports, staff meetings, reports to the Houston lab Administrative
Team, e-mail, and posting information)
Program Description:
a. The Facilities Management Services Branch (FMSB) monitors the Houston lab Energy Conservation.
b. Monthly utility bills are tracked and plotted using Lotus 1-2-3 or excel.
c. EPA headquarters tracks all EPA facilities through quarterly energy reports.
d. In conjunction with EPA headquarters organizations and the HOUSTON LAB Administrative Team, ESBL addresses specific energy issues.
e. Specific energy reducing measures identified through system reviews are then instituted after review of cost-benefit comparisons.
f. Houston lab staffs are sent regular e-mails that highlight electricity consumption trends and that discuss current efforts underway to reduce
consumption.
g. Staffs are reminded to use energy efficient work habits, such as turning off computer monitors when they leave the building.
h. Electricity consumption graphs are posted in a common area (e.g., main lunch room).
Operation Control: (See Operational Controls Form, separate page)
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Budget (Resources):
a. Target a: Lab modification 206.
b. Target b: Facility Manager 4 hrs/year.
Structure. Authorities. Responsibilities
Tasks
Responsible Person/Group
a. Identify electrical demands to include items identified in system
review surveys
b. Identify potential savings
c. Monitor effect of changes
d. Maintain awareness among HOUSTON LAB staff
Facility Manager
Facility Manager, EPA HQ, consultants, OM&R contractor,
Houston lab Administrative Team, EMS Team
Facility Manager, EPA HQ
Facility Manager, EMS Coordinator, EMS Team
Rccord(s):
Person Responsible and Record Location:
Monthly utility bills
a.
Facility Manager
158
Preventive maintenance logs
b.
Building Engineer
218
Monthly utility costs on electronic spreadsheet
c.
Facility Manager
158
Records of awareness activities performed (training course sign-up
d.
EMS Coordinator
158
sheets, brown-bag lunch announcements, e-mails that raise awareness
e.
Building Engineer
218
and other correspondence including recommendations from periodic
f.
Building Engineer
218
outside evaluations)
g-
Building Engineer
218
Fume hood report and report to organizational managers
h.
Building Engineer
218
Major systems equipment run logs (AHUs, boilers, chillers, cooling
i.
Building Engineer
218
tower, exhaust fans)
j-
Building Engineer
218
Room exhaust and supply tables
k.
Building Engineer
218
Log of building DDC operation modifications
Shift logs
Air balance tables.
Procedure for occupied/unoccupied temperature set points.
Documcnl(s):
Person Responsible and Document Location:
a. Houston Lab architectural building designs and specifications
b. As built documentation and drawings
c. Testing, Adjusting, and Balancing Report (Air balance tables)
d. Quarterly energy reports
Facility Manager
Building Engineer
Facility Manager
EMS Coordinator
158
218
158
158
Competence of persons responsible on basis of training, education or experience:
Title:
a. Facility
Manager
b. Building
Engineer
Competence:
a. On-the-job training, facility management courses, experience, contracting/project officer training; factors in Position
Description describe knowledge required by the position, supervisory controls, guidelines, complexity, scope and
effect, personal contacts, purpose of contacts, physical demands and work environment
b. >5 years operations and maintenance supervision; factors in Contract SOW describe knowledge required by the
position, supervisory controls, guidelines, complexity, scope and effect, personal contacts, purpose of contacts,
physical demands and work environment
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Environmental Management Program Form
Significant Environmental Aspect:
Encr^v use by Houston Lab occupied by EPA
Control Code: EMP-03.01
Date: September 9. 2003
Obicclivc(s):
Demonstrate through Cleaner and Greener benchmarking (a program of Leonardo Academy Inc.,) that our Region 6 lab & field operations building
is energy efficient. The Cleaner and Greener Environment Program helps individuals, organizations, and businesses have a direct impact on reducing
pollution, http://www.cleanerandgreener.org/emission_reductions.htm
Target(s):
a. The EMS Program Manager will work with building management to benchmark and label the Houston Lab building by February 28, 2004.
Reason for Significance:
a. EPA is requesting that GSA or HQ facilities provide new major office/lab leases (60,000 gross square feet or more) that meet the Energy Star
requirements by 2010.
b. The Energy Star label indicates that a building is in the top 25% of all commercial office buildings in the U.S. for energy performance.
Potential Environmental Impacts:
a. Reduce carbon dioxide Greenhouse Gases (C02) emissions
b. Reduce dependence on materials extracted from the Earth
c. Reduce Volatile Organic Compounds (VOC) emissions
d. Reduce Nitrogen Oxides (Nox) emissions
e. Reduce Carbon Monoxide (CO) emissions
f. Reduce Sulfur Dioxide (S02) emissions
g. Reduce Particulates (PM10) emissions
h. Reduce Mercury (Hg) emissions
Specific Legal and Other Requirements:
a. Executive Order 13221, "Energy Efficient Standby Power Devices" Section 1. Energy-Efficient Standby Power Devices. Each agency, when it
purchases commercially available, off-the-shelf products that use external standby power devices, or that contain an internal standby power
function, shall purchase products that use no more than one watt in their standby power consuming mode.
b. If such products are not available, agencies shall purchase products with the lowest standby power wattage while in their standby power-consuming
mode.
Performance Indicators:
a. Monthly electric meter readings by local utility
b. Electricity consumption tracking by Facility Management office
c. Major systems equipment run logs (air handling units, boilers, chillers, cooling tower, exhaust fans)
d. Number and type of employee awareness activities performed (annual reports, staff meetings, reports to the HOUSTON LAB Administrative
Team, e-mail, and posting information)
Program Description:
The Facilities Management Services Branch (FMSB) monitors the HOUSTON Lab's Energy Conservation.
Monthly utility bills are tracked and plotted using Lotus 1-2-3 or excel.
EPA headquarters tracks all EPA facilities through quarterly energy reports.
In conjunction with EPA headquarters organizations and the HOUSTON LAB Administrative Team, FMSB addresses specific energy issues.
Specific energy reducing measures identified through system reviews are then instituted after review of cost-benefit comparisons.
Operation Control: (See Operational Controls Form, separate page)
Budget (Resources):
Target a: Lab modification 206.
Target b: Facility Manager 4 hrs/year
Target c: Reduce energy usage by 3% per year.
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Structure, Authorities, Responsibilities
Tasks
Responsible Person/Group
a. Identify electrical demands to include items identified in system review surveys
b. Identify potential savings
c. Monitor effect of changes
d. Maintain awareness among HOUSTON LAB staff
a. Building Engineer
b. Facility Manager
c. Building Engineer
d. Facility Manager
Rccord(s):
a. Monthly utility bills
b. Preventive maintenance logs
c. Monthly utility costs on electronic spreadsheet
a. Building Engineer
b. Facility Manager
c. Building Engineer
Documcnl(s):
a. HOUSTON LAB architectural building designs and specifications
a. Building Engineer
Competence of persons responsible on basis of training, education or experience:
Title:
a. Facility Manager
Competence:
a. On-the-job training, facility management courses, experience, contracting/project officer training; factors in Position
Description describe knowledge required by the position, supervisory controls, guidelines, complexity, scope and
effect, personal contacts, purpose of contacts, physical demands and work environment
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Environmental Management Program Form
Significant Environmental Aspect:
Air pollution and fuel consumption from EPA fleet vehicles
Control Code: EMP-03.02
Dale: Scplcmbcr9. 2003
Objcclivc(s):
a. Reduce air pollution from EPA fleet vehicles
b. Reduce gasoline use by EPA fleet vehicles
Target(s):
Enforcement Team will gather information about hybrid vehicles by April 30, 2005.
By May 31, 2005, representatives from Enforcement Team and the EMS Team, will meet with the local GSA Fleet manager to discuss options for
acquiring hybrid and other innovative alternative fuel vehicles for the Region 6 Houston Lab fleet during FY 2006 and beyond.
During Calendar Year 2005, the Region 6 lab & field operations will reduce gasoline consumption from fleet vehicles by 5% below CY 2004 levels
on their way to meeting the Executive Order 13149 FY 2005 goal of a 20% reduction.
Additionally, the Region 6 lab & field operations will increase their use of alternative fuels (natural gas and E85) by 5% over 2004 levels as a step
toward running our Alternative Fuel Vehicles most of the time on alternative fuels (Energy Policy Act and EO 13149).
By May 31, 2005, Enforcement Team will draft a memo addressed to all Region 6 lab & field operations EPA employees and submit it to the EMS
SLT Champions. This memo will promote the 5% goals and greater use of public transportation for local meetings.
By May 31, 2005, Enforcement Team will develop and hang a poster advertising the 5% goals, along with information on public transportation
options for the most common local destinations. He will coordinate with the Administrative Team to develop and display poster sized charts in
tracking gasoline, natural gas and E85 usage with comparison to the goals. The charts will be updated on a monthly basis during 2005.
Starting in the spring, 2005, Enforcement Team and other interested employees will plan and present events to promote public transportation and
fleet vehicle alternative fuel usage in conjunction with the Bike to Work Week in June, 2005.
Reason for Significance:
a. Legal and other requirements
b. EPA vehicles are currently filled with gasoline almost 100% of the time.
c. Fueling vehicles with petroleum-based fuels requires dependence on materials extracted from the Earth
d. Alternative fuel vehicles release lower amounts of air pollutants.
e. Air pollution from motor vehicles causes human health effects.
f. EPA vehicles are driven every workday.
Potential Environmental Impacts:
a. Air pollution
b. Carbon dioxide emissions leading to global warming
c. Environmental impacts from fuel production
Specific Legal and Other Requirements:
EPA Executive Order 13101 Green Fleet goals for 2005 and 2010
Petroleum fuel consumption reduction goals for 2005 in Executive Order 13149, Sections 201 and 202 Section 201. Reduced Petroleum Fuel
Consumption. Each agency operating 20 or more motor vehicles within the United States shall reduce its entire vehicle fleet's petroleum
consumption by at least 20 percent by the end of FY 2005, compared with FY 1999 petroleum consumption levels. Section 202. Performance
Strategies. Agencies have numerous options for developing a strategy to meet the petroleum reduction levels established in section 201 of this
order. Measures include: the use of alternative fuels in light, medium, and heavy-duty vehicles; the acquisition of vehicles with higher fuel
economy, including hybrid vehicles; the substitution of cars for light trucks; an increase in vehicle load factors; decrease in vehicle miles traveled;
and a decrease in fleet size.
Energy Policy Act of 1992, Public Law 102-486, Sections 501 and 2001
Pc rforma nee I ndica to rs:
a. Monthly logs of fuel usage
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Program Description:
a. Enforcement Team, Enforcement Lead at the facility, manages the Houston Lab's fleet vehicle program.
Operation Control: (See Operational Controls Form, separate page)
Budget (Resources):
a. Complete study for options of acquiring hybrid and other innovative alternative fuel vehicles
Structure. Authorities. Responsibilities
Tasks
Responsible Person/Group
a. Complete study
a. Enforcement Lead
Rccord(s):
a™~Studyandbldproposalsfbrvehlcles^^T*a~~^EnfbrcementLeaT*
Documcnt(s):
a. Fuel mileage records | a. Enforcement Lead"
Competence of persons responsible on basis of training, education or experience: NA
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EMP 4.0 Water Conservation
Environmental Management Program Form
Significant Environmental Aspect:
Water Consumption
Document Control Code: EMP-4.00
Date: May 19. 2004
Objective(s):
a. Monitor water consumption as a component of the overall energy management program to ensure optimal balance of Energy
Conservation
b. Establish laboratory procedures to ensure that lab equipment including autoclaves, DI water system, and dishwashers are operated in a
manner that minimizes water consumption.
c. Increase employee awareness and involvement regarding policies and procedures used to optimize the use of water.
Target(s):
Establish a mechanism for the review of water consumption in conjunction with changes to heating, ventilation, and air conditioning
(HVAC) management (e.g., air handling volumes, heating conditions, installation of smaller boiler) within 6 months of initial meeting
between EMS Team and EMP Workgroup. Correlate consumption of water with the energy reduction program to ensure that
consumption of water does not increase substantially as HVAC management changes are implemented.
Water Team write or edit Standard Operating Procedures or equivalent that specify how to use autoclaves, DI water system, and other
equipment with minimal water consumption within 90 days of initial meeting between EMS Team and EMP Workgroup. Conduct
meeting to discuss best practices within 60 days of initial meeting between EMS Team and EMP Workgroup.
Maintain and promote awareness and involvement of REGION 6 LAB & FIELD OPERATIONS staff regarding the impacts related to
water consumption through activities such as annual reports, staff meetings, reports to the REGION 6 LAB & FIELD OPERATIONS
Administrative Team, e-mail, and posting information.
Reason for Significance:
a. Appears on the REGION 6 LAB & FIELD OPERATIONS "High Significance Report"
b. Legal and other requirements
c. Existing program
Potential Enviromnental Impacts:
Use of natural resources
Specific Legal and Other Requirements:
Executive Order 13148, "Greening of the Government Through Leadership in Environmental Management" Section 201.
Environmental Management. Through development and implementation of environmental management systems, each agency shall
ensure that strategies are established to support environmental leadership programs, policies, and procedures and that agency senior
level managers explicitly and actively endorse these strategies.
Executive Order 13123, "Greening the Government Through Energy Efficient Management" Section 207. Water Conservation.
Through life-cycle cost-effective measures, agencies shall reduce water consumption and associated energy use in their facilities to
reach the goals set under section 503(f) of this order.
EPA, 40 CFR Part 141, SDWA, "National Primary Drinking Water Regulations" applies to public water system as defined in 40 CFR
141.2
EPA, 40 CFR Part 142, SDWA, "National Secondary Drinking Water Regulations" applies to public water system as discussed in 40
CFR 142.3
Performance Indicators:
Workgroup formed and meetings conducted to establish a review mechanism for water consumption. Recommendations are forwarded
to the Facility Manager and EMS Team
Meeting conducted to discuss best practices. SOPs for operation of lab equipment in place and followed.
Water consumption tracking by Facility Management Office.
Number and type of awareness activities performed.
Program Description:
Operation of the HVAC system and operation laboratory equipment such as autoclaves, DI water system, and dishwashers consumes
large volumes of water. The HVAC system is the largest point of use of water. The REGION 6 LAB & FIELD OPERATIONS is
currently optimizing the HVAC system to minimize electricity consumption. Water consumption may fluctuate as the system is
optimized. Other HVAC optimization efforts affect water consumption. For example, the Facility Manager programs the cooling
system so that both chilling towers are running only when necessary. A report mechanism will be developed to track water
consumption as the system is optimized. The Facility Manager provides performance data (volume of water consumed) to the REGION
6 LAB & FIELD OPERATIONS on a regular basis. Data is available for only two readings: total water consumed and cooling tower
water consumption. Approximately 50% of all water consumed is used in the cooling towers (based on FY00 and FY01 numbers).
Water consumption is recorded using in-line flow meters. The Facility Manager maintains records of consumption.
There are three significant points of water use in the laboratories: autoclaves, dishwashers, and the DI water system. Each laboratory
organization maintains written procedures for equipment operation that will specify how to use the equipment efficiently so as to reduce
water consumption. For example, the procedures will direct analysts to run the dishwashers only when full and to use the shortest rinse
cycles possible. Periodic maintenance is conducted on the equipment to ensure optimal function.
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Environmental Management Program Form
Opcraiion Control: (See Operational Controls Form, separate page)
Budget (Resources):
Target a.- 1 Group Leader 6 hrs.
3-5 person Wkgp. 4-1 hour meetings = 20 hrs.
Total = 26 hrs. for this target and target b. for Fuel Consumption
Target b.- 1 person each Water Team 40 hrs.
Total = 80 hrs.
Target c.- Building Engineer - 2 hrs./quarter = 8 hrs./year
Included in budget for target c of Fuel Consumption (heating oil, natural gas)
Structure. Authorities. Responsibilities
Tasks
Responsible Person/Group
a. Maintain and operate HVAC system
b. Provide consumption data
c. Workgroup to establish review mechanism
d. Write/review operating procedures for laboratory equipment
e. Operation of Lab equipment
f. Promote awareness
a. Facility Manager, ESAT Contractor
b. Group leader (to be determined)
c. As assigned by Managers
d. Lab Staff
e. Facility Manager
f. EMS Coordinator, EMS Team
Rccord(s):
a. Weekly water usage reports
b. Monthly utility bills
c. Monthly preventive maintenance logs
d. Records of awareness activities performed (training course sign-up
sheets, brown-bag lunch announcements, e-mails that raise
awareness)
e. Maintenance and repair records
f. Monthly utility costs on electronic spreadsheet
a. Water Team Lead 107
b. SHEM Manager 158
c. Water Team Lead 107
d. Water Team Lead 107
e. Water Team Lead 107
f. SHEM Manager 158
Documcnt(s):
a. SOPs for laboratory equipment (autoclaves, dishwashers, DI water
system, water system)
b. ESAT Annual Work Plan
c. SOPs for EPA Houston Lab
a. Water Team Lead 107
b. Water Team Lead 107
c. Water Team Lead 107
Competence of persons responsible on basis of training, education or experience:
Title:
a. Facility
Manager
b. ESAT Project
Manager
c. Laboratory
staff
Competence:
a. Must be hired under that capacity or his/her designee. On the job training, facility management courses,
experience, contracting/project officer training; Position Description describes knowledge required by the
position, supervisory controls, guidelines, complexity, scope and effect, personal contacts, purpose of contacts,
physical demands and work environment
b. >5 years operations and maintenance supervision; Contract SOW describes knowledge required by the position,
supervisory controls, guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical
demands and work environment
c. Staffs that operate autoclaves, dishwashers, and the DI water system are expected to have read and understood
the operating procedures that pertain to their jobs.
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EMP 5.0 Waste Reduction
Environmental Management Program Form
Significant Environmental Aspect:
Waste Generation/Minimization
Document Control Code: EMP-5.00
Date: September 9, 2003
Objcclive(s):
a. To maintain compliance with Federal, State and local regulations concerning waste disposal.
b. To maintain, follow and practice the emergency preparedness, spill response and containment procedures as specified in the Region 6 lab
& field operations Chemical Hygiene Plan (CHP), Spill Prevention, Control and Countermeasures Plan (SPCC) and Occupant
Emergency Plan (OEAP).
c. To perform root cause analysis of waste release (e.g., spills) incidents to find opportunities to prevent future releases within 30 days.
d. To gather and evaluate baseline data on the amount and types of hazardous and non-hazardous wastes generated, recycled and/or
disposed of, then develop strategies (if possible or feasible) to reduce the amount of waste generated and/or disposed of, or increase the
amount of waste recycled and/or reused.
e. Maintain and promote the awareness and involvement of Region 6 lab & field operations employees to specific facility/laboratory
opportunities that have been identified to reduce the generation of wastes, or increase the amount of wastes recycled and/or reused.
Target(s):
a. 100% compliance with all waste disposal regulations.
b. To perform annual updates/reviews, quarterly drills with no deviations from the CHP, SPCC, and OEAP.
c. Complete root cause analyses of waste releases (e.g., spills) and provide strategies to prevent future releases within 30 days.
d. Determine base amounts for recycled materials, hazardous wastes and non-hazardous wastes generated and disposed of by the facility,
within 6 months of initial meeting between EMS Team and EMP Workgroup. Determine whether opportunities exist to reduce facility
wastes (both hazardous and non-hazardous wastes) by employing source reduction, substitution, recycling and reuse, then develop
strategies (if possible or feasible) to reduce facility/laboratory waste generation, within 6 months of baseline data accumulation.
e. Increase awareness and involvement of REGION 6 LAB & FIELD OPERATIONS staff regarding their impacts related to waste
generation through activities such as training courses, holding brown-bag lunches, reports to the REGION 6 LAB & FIELD
OPERATIONS Administrative Team, e-mail notifications, and posting information.
Reason for Significance:
a. Appears on the Region 6 lab & field operations "High Significance Report"
b. Legal and other requirements.
c. Existing program.
Potential Environmental Impacts:
a. Release of pollutants
Specific Legal and Other Requirements:
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Environmental Management Program Form
a. OSHA, 29 CFR Part 1910.120 Hazardous Waste Operations and Emergency Response. Cleanup, corrective actions, voluntary cleanup,
TSD facilities, emergency response.
b. EPA, 40 CFR Part 243, RCRA, "Guidelines for the Storage and Collection of Residential, Commercial, and Institutional Solid Waste."
EPA, 40 CFR Part 246, RCRA, "Source Separation for Materials Recovery Guidelines." 246.200: High-grade paper generated by office
facilities of over 100 office workers must be separated at the source of generation, separately collected, and sold for the purpose of
recycling. EPA, 40 CFR Part 260, RCRA, "Hazardous Waste Management System: General." Provides definitions of terms, general
standards, and overview information applicable to parts 260 through 265 and 268. EPA, 40 CFR Part 261, RCRA, "Identification and
Listing of Hazardous Waste." Identifies those solid wastes, which are subject to regulation as hazardous wastes under parts 262 through
265, 268, and parts 270, 271, and 124 of this chapter and which are subject to the notification requirements of section 3010 of RCRA.
c. EPA, 40 CFR Part 262, RCRA, "Standards Applicable to Generators of Hazardous Waste." 262.10(c) A generator who treats, stores, or
disposes of hazardous waste on-site must only comply with the following sections of this part with respect to that waste: Section 262.11
for determining whether or not he has a hazardous waste, §262.12 for obtaining an EPA identification number, §262.34 for accumulation
of hazardous waste, §262.40 (c) and (d) for record keeping, 262.43 for additional reporting additional reporting. EPA, 40 CFR Part 266,
RCRA, "Standards for the Management of Specific Hazardous Wastes and Specific Types of Hazardous Waste Facilities." Products
produced for the general public's uses that are used in a manner that constitutes disposal and that contain recyclable materials are not
presently subject to regulation.
d. EPA, 40 CFR Part 268, RCRA, "Land Disposal Restrictions." Identifies hazardous wastes that are restricted from land disposal and
defines those limited circumstances under which an otherwise prohibited waste may continue to be land disposed. EPA, 40 CFR Part
270, RCRA, "General Application Permit Requirements." basic EPA permitting requirements, such as application requirements,
standard permit conditions, and monitoring and reporting requirements
e. EPA, 40 CFR Part 273, RCRA, "Standards for Universal Waste Management." 273.1(a) Requirements for managing batteries,
pesticides, thermostats, and lamps. EPA, 40 CFR Part 761, TSCA, "Polychlorinated biphenyls (PCBs) Manufacturing, Processing,
Distribution in Commerce, and Use Prohibitions." Subpart A, "General" Establishes prohibitions of, and requirements for, the
manufacture, processing, distribution in commerce, use, disposal, storage, and marking of PCBs and PCB Items. Subpart B,
"Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions." 761.35 Storage for Reuse. Subpart C, "Marking of PCBs
and PCB items." 761.40 Marking Requirements. 761.45 Marking Formats. Subpart D, "Disposal Requirements." 761.50 Applicability.
761.60 Disposal Requirements. 761.61 PCB Remediation Waste. 761.64 PCB Disposal of wastes generated as a result of research and
development activities authorized under 761.30(j) and chemical analysis of PCBs. 761.65 PCB Storage for Disposal. 761.79 PCB
Decontamination Standards and Procedures. Subpart G, "PCB Spill Cleanup Policy." 761.125 Requirements for PCB Spill Cleanup.
Reporting, disposal, and precleanup requirements apply to all spill of PCBs at concentrations 50 ppm or greater which are subject to
TSCA decontamination requirements. 761.205 Notification of PCB Waste Activity. Subpart J, "General Records and Reports." Subpart
K, "PCB Waste Disposal Records and Reports"
f. 49 CFR 172.101, "Purpose and Use of Hazardous Materials Table". Hazardous Materials Table designates the materials listed as
hazardous materials for transportation. For each listed material, the table identifies the hazard class or specifies that the material is
forbidden in transportation, and gives the proper shipping name or directs the user to the preferred proper shipping name. In addition, the
Table specifies or references requirements for labeling, packaging, quantity limits aboard aircraft and vessels.
Performance Indicators:
a. No regulatory findings for waste generation being listed on any internal or external compliance inspection report.
b. Annual review of CHP, SPCC, OEAP, training records of employees and inventories of materials and supplies for spill cleanup and
containment. Quarterly evacuation drills and biennial mock spill response exercises with Fire Department Haz-Mat teams.
c. All root cause analyses of waste releases (e.g., spills) and provide strategies to prevent future releases completed within 30 days.
d. Final report containing baseline amounts for recycled materials, hazardous wastes and non-hazardous wastes generated and disposed of
by the facility, within 6 months of initial meeting between EMS Team and EMP Workgroup.
e. Final report containing opportunities identified to reduce facility hazardous and non-hazardous wastes (by employing source reduction,
substitution, recycling and reuse) and potential strategies (if possible or feasible) to reduce facility/laboratory waste generation, within 6
months of baseline data accumulation.
f. Documentation of training sessions, brown bag lunches, etc. being conducted within one year of finalizing the baseline within one year
of baseline data accumulation.
Program Description:
a. The Region 6 lab & field operation is a consolidated facility housing offices and extensive chemical and microbiological laboratories
from several different EPA organizations.
b. The office activities result in the generation of non-hazardous solid wastes, while the laboratory activities result in the generation of
diverse chemical and microbiological wastes of varying quantities and toxicities, as well as additional non-hazardous solid wastes.
c. The Region 6 lab & field operations, classified as a small quantity generator by the State of Texas, is allowed to accumulate hazardous
waste on site for no more than 180 days.
d. The Region 6 lab & field operation SHEM Manager is also the facility's Hazardous Waste Manager.
Operation Control: (See Operational Controls Form, separate page)
Budget (Resources):
SHEM Manager 5 hours/year
Laboratory Staff 40 hours/year
Waste Team Leader 120 hours/year
Waste Disposal Contract - $5K/yr
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Knv
iron mental Management Progr;
im Form
Slriicllliv. \m|Iki|'I|ICs. Responsibilities
Tasks
Responsible Person/Group
a.
Regulatory Review and Regulatory Updates
a.
SHEM Manager
b.
Hazardous Waste (HW) Management
b.
SHEM Manager
c.
Non-hazardous / Solid Waste Management
c.
SHEM Manager
d.
Recycling Program Management
d.
Recycle Team
e.
Annual CHP, SPCC, OEAP revisions
e.
SHEM Manager
f.
Emergency Preparedness and Response Programs
f.
SHEM Manager
g-
Record Keeping
g-
SHEM Manager, Facility Manager
h.
Removal of Hazardous Wastes
h.
SHEM Manager
Spil
Reporting:
a.
Identify and report a spill of hazardous material
a.
Occupants/ Employee
b.
Secure immediate spill area
b.
SHEM Manager
c.
Upon notification of a spill or release, determine if evacuation is necessary, notify
c.
SHEM Manager
appropriate emergency services, coordinate spill clean-up, external reporting
d.
EMS Coordinator/EMS Team
d.
Increase awareness and involvement of REGION 6 LAB & FIELD OPERATIONS
staff regarding their impacts related to waste generation
Rccord(s):
a.
Hazardous waste manifests
a.
SHEM Manager
158
b.
DOT Drum Inventory Forms
b.
SHEM Manager
158
c.
Certificates of Disposal / Treatment
c.
SHEM Manager
158
d.
Contract Invoices / EPA Receiving Reports
d.
SHEM Manager
158
e.
Waste Committee Meeting Minutes
e.
Recycle Team 153
f.
Accumulation Area Logbooks
f.
SHEM Manager
158
g-
Waste Profiles
g-
SHEM Manager
158
h.
Contractor Field Report Forms
h.
SHEM Manager
158
i.
Restricted Waste Notification &
Certification Forms (Land Ban forms)
i.
SHEM Manager
158
j-
Non-Hazardous Waste Manifests
j-
SHEM Manager
158
k.
PCB Waste Logbook & Tracking Forms
k.
SHEM Manager
158
1.
Internal/external inspection reports
1.
SHEM Manager
158,
m.
Accumulation area inspection logbooks
m.
SHEM Manager
158
n.
Records of awareness activities performed (training course sign-up sheets, brown-
n.
Recycle Team 153
bag lunch announcements, e-mails that raise awareness)
0.
Recycle Team 153
0.
Inventory of recycled materials, including aluminum cans, glass bottles (clear and
P-
SHEM Manager
158
brown), batteries, wood pallets, paper, and cardboard
P-
Training records
Documcnl(s):
a.
Chemical Hygiene Plan (CHP)
a.
SHEM Manager
158
b.
Occupant Emergency Plan (OEAP)
b.
SHEM Manager
158
c.
Spill Prevention, Controls and Countermeasures (SPCC) Plan
c.
SHEM Manager
158
d.
Regulatory Permits (RCRA ID and TSCA / PCB Notification)
d.
SHEM Manager
158
e.
Janitorial contract, statement of work, and work orders
e.
Building Engineer
218
f.
Grounds maintenance contract
f.
Recycle Team 153
g-
Hazardous waste removal contract, statement of work, and work orders
g.
SHEM Manager
158
h.
Waste handling procedures, SOPs, flow charts
h.
SHEM Manager 158
Competence of persons responsible on basis of training, education or experience:
Title:
Competence:
a.
SHEM Manager
a. Factors in Position Description describe knowledge required by the position, supervisory
controls,
b.
Facility Manager
guidelines, complexity, scope and effect, personal contacts, purpose of contacts,
physical
c.
Hazardous Waste Contractor
demands and work environment
d.
Janitorial Contractor
b. Factors in Position Description describe knowledge required by the position, supervisory
controls,
e.
Recycle Team
guidelines, complexity, scope and effect, personal contacts, purpose of contacts,
physical
demands and work environment
c. Factors in Contract SOW describe knowledge required by the position, supervisory
controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts,
physical
demands and work environment
d. Factors in Contract SOW describe knowledge required by the position, supervisory
controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts,
physical
demands and work environment
e. Factors in Position Description describe knowledge required by the position, supervisory
controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts,
physical
demands and work environment
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C. Operational Controls (OCs)
Introduction
This manual describes the Operational Controls that have been established to control activities,
products, and services and the sources of environmental aspects within them.
Operational controls are in place for those activities associated with identified significant
environmental aspects. New operational controls can result from the completion of objectives
and targets. Aspect-specific operational controls are listed on specific forms called Operational
Control Forms (OCF). The OCFs are included in this manual. Internal procedures and other
relevant documents are listed on the OCFs.
EPA staff, grantees, and on-site contractors are given explicit instructions on operational control
procedures during meetings and training sessions. Training records specific to operational
controls that are conducted by on-site contractors are maintained by the Project Officer that is
responsible for the contract (e.g., hazardous waste removal contractors, analytical services
contractors). The SHEM Manager maintains training records specific to operational controls that
are conducted by EPA staff or grantees.
List of OCs:
1. OC Air Emission
2. OC Energy Conservation
3. OC Water Conservation
4. OC Waste Reduction
5. OC Chemical Management
6. OC Noise Reduction
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OC Air Emission
Operational Controls Form
Significant l.n\ imniiK'iiCil Aspect: Document Com ml ( ode: 1 All'-ol uu
\ 11" 1 !llllssk)|ls
Dale:
5: i :n<)4
Acli\il\ Croup l ';icilil\ ()|VT;ilioii ;iiid \I;iiiiIcii;iiicc
Activities (and corresponding written controls, where
applicable):
a. Operation and Maintenance of Boilers.
b. Operation and Maintenance of Emergency Generator.
c. Operation and Maintenance of CFC Containing Devices.
d. Reduction of indoor air pollution intake.
e. Obtain Green Energy source supplies.
Operational Controls such as technological, operational, p
roccdural:
a. Installs exhaust Gas Analysis (EGA) sensors on boilers.
h. Preventive maintenance.
b. Reduce lawn mowing air emission into lab intake .
i. Triennial NOx reduction training
c. Start monitoring or install boiler-reading logs.
j. Procure fuel oil with low sulfur content.
d. Monthly NOx emission calculations.
k. Annual internal audits
e. Annual combustion analyses.
1. Monitor indoor air quality
f. Equipment inspections.
m. Triennial external audits
g. Convert lab grounds to Xeriscape design.
Maintenance plan(s) to
r the operational controls:
a. Review procedures periodically
e. Review annual combustion reports
b. Calibrate and/or verify sensors/meters periodically
f. Conduct annual and triennial audits
c. Review reading logs
g. Review training certificates
d. Review monthly NOx calculation reports
h. Review fuel usage and content reports
Actions to be taken if controls fail:
a. Training
b. Procure and/or install corrective services or hardware
c. Evaluate additional controls
Record(s):
Responsible Person and Record Location:
a. Certificate of fuel quality
a.
Building Engineer
b. Fuel usage, hours of operation
b.
Building Engineer
c. NOx reduction training records
c.
Air Team Lead
d. Equipment inspection and survey reports
d.
Air Team Lead
e. Preventive maintenance records
e.
Building Engineer
f. Monthly NOx emission calculations
f.
Air Team Lead
g. Annual boiler/generator combustion analysis
g-
Building Engineer
h. visible emissions inspection
h.
Air Team Lead
i. Regulatory review
i.
Building Engineer
j. Internal/external inspection reports
.1-
Air Team Lead
k. Universal CFC license
k.
Building Engineer
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls)
Title
Responsibility
EMS Lead Auditor
Regulatory review and updates
Building Engineer
Fuel purchase, specifications & content requirements
Personnel certifications and training requirements
Program management
NOx emissions calculations
Annual combustion analyses
Equipment inspections & surveys
Annual preventive maintenance
Corrective actions
Competence of operators on the basis of training, education or experience:
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Operational Controls Form
Title
Competence (Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.)
SHEM
Manager
Facility
Manager
o Attendance at annual national EPA SHEM Conferences, Networking with other SHEM, Managers, CFR updates, EPA
Headquarters updates & correspondences, EPA, DOD and private regulatory publications, Regulatory E-mail updates
o Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.
Attendance at annual national EPA Facility Manager Conferences. Networking with other Facility Managers. CFR
updates. EPA Headquarters updates & correspondences. Regulatory E-mail updates.
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Operational Controls Form
Significant Environmental Aspect:
Air Emissions
Document Control Code: HMI-MM.ul
Date: 5/21/2004
Activity Group: Analysis of samples/prep (except instrument;)! analysis)
Activities (and corresponding wrillen conlrols, where applicable): Analysis of samples/preparalion
Operational Controls such as technological, operational, procedural (and corresponding written controls, where
applicable):
a. Written procedures for handling solvents (Chemical Hygiene Plan sections addressing fume hoods).
Maintenance plan(s) for the operational controls:
a. Review CHP and SOPs periodically
Actions to be taken if controls fail:
Training, reeducation, communication
Evaluate additional controls
Rccord(s):
Responsible Person and Record Location:
Training records as needed
Quality Assurance Officer Room 134
Responsibilities: (a. to ensure controls are in place; b. to ensure controls keep working; c. to take action
when controls fail; d. to create and keep records relative to operational controls)
Title
Responsibility
SHEM Manager
Lab Lead
Ensure controls are in place, create and keep relevant records.
Take action when controls fail.
Competence of operators on the basis of training, education or experience:
Title
Competence
SHEM
Manager
EMS Lead
Auditor
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
^om£lexit^^co£^mi^ffect^ersona^oirtacts^ur£os^fcoirtacts^h^sicaMemmid^mi^wo^^nvironmei^
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Operational Controls Form
Significant 1-1 it \ i i'o it in on I ill Aspect:
\11" I Emissions
Document Control C'cxlo: I All'-ol u2
Date: 5 : I :ui)4
Activity Group: Use of pesticides inside for pest control
Activities (and corresponding written controls, where applicable): Use of pesticides inside for pest control
Operational Controls: (such as technological, operational, procedural and corresponding written controls.
where applicable):
Applicator must be licensed and bonded (janitorial contractor/subcontractor must meet Federal/State/local requirements as stated in
janitorial contract SOW)
Applicator must notify Facility Manager prior to applications (verbal notification)
Applicator reports EPA registration number of chemical, amount, and location applied (pesticide application receipts)
Maintenance plan(s) for the operational controls:
a. REGION 6 LAB & FIELD OPERATIONS reviews performance of janitorial contractor
b. Janitorial contractor reviews performance of the pesticide subcontractor
Actions lo he laken if controls Tail:
a. Training, re-education, communication
b. Evaluate additional controls
c. Replace pesticide subcontractor
d. Follow contractual procedures to address performance of contractor or subcontractor
e. File complaint to pesticide licensing officials, if necessary
Rccord(s):
Responsible Person and Record Location:
a. Pesticide application receipts
b. Other applicable records
Facility Manager Room 158
Responsibilities: (a. lo ensure controls arc in place: b. lo ensure controls keep working: c. lo lake action when
controls fail: d. lo create and keep records relative lo operational controls)
Title
Responsibility
Facility Manager
Building Engineer
Ensure controls are in place, create and keep relevant records.
Responsible for oversight of the janitorial contract, which allows subcontract for pesticide application.
Take action when controls fail.
Competence of operators on the hasis of training, education or experience:
Title
Competence
Facility
Manager
Building
Engineer
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.
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OC Energy Conservation
Operational Controls Form
Operational Control For Significant Environmental Aspect:
Energy Conservation (electricity)
Document Control Code: EMP-02.00
Date: 5/2.1/2004
Activity Group:
Operation and Maintenance of Heating, Ventilation, and Cooling systems
Activities (and corresponding written controls, where applicable):
Operation & Maintenance of HVAC equipmen
Operational Controls such as technological, operational, procedural (and corresponding written controls, where
applicable):
a. Building direct digital control (DDC) system
b. Sequence of operations for specific periods of the day
c. Nighttime setback for air handling
d. Occupied operation, re-balance and test air flows, tune condenser loop water temperatures, heating loop temperatures
e. Conduct preventive maintenance on boilers, chillers, fan motors, fume hoods, other electrical equipment
f. Maintain equipment such as boilers, chiller, and fan motors in top running condition via filter changes, belt replacements, lube and oil
changes to maximize efficiency
g. Maximize cooling tower conditions. Maximize free cooling.
h. Monitor fume hood sashes through DDC system
i. Track monthly utility costs using an electronic spreadsheet
Maintenance plan(s) for the operational controls:
a. Periodic review of DDC system's sequence of operations
b. Weekly review of operation through PM procedures
c. Monthly PM such as filter changes, lubrication
Actions to be taken if controls fail:
a. Invoke penalty clauses of incentive contract with ES AT contractor; requirement to maintain system in peak operation
b. Request emergency funding to replace capital equipment
c. Call on external advisors to recommend course of action
d. Reevaluate monitoring strategy
Records:
^Pcrson^cs^onsibl^in^^ccord^ooitio^
a.
Preventive maintenance logs
a.
Building Engineer
218
b.
Fume hood report and report to organizational managers
b.
Building Engineer
218
c.
Major systems equipment run logs (AHUs, boilers, chillers, cooling tower,
c.
Building Engineer
218
exhaust fans)
d.
Building Engineer
218
d.
Room exhaust and supply tables
e.
Building Engineer
218
e.
Log of building DDC operation modifications
f.
Building Engineer
218
f.
Monthly utility costs on electronic spreadsheet
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls
Title
Responsibility
Facility Manager
Ensure controls are in place, create and keep relevant records. Take action when controls fail. Maintain qualified
contractors and subcontractors. Take action when controls fail.
Competence of operators on the basis of training, education or experience:
Title
Competence
Facility Manager
Building Engineer
On-the-job training, facility management courses, experience, contracting/project officer training; factors
in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work
environment
>5 years operations and maintenance supervision; factors in Contract SOW describe knowledge required
by the position, supervisory controls, guidelines, complexity, scope and effect, personal contacts, purpose
of contacts, physical demands and work environment.
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Operational Controls Form
Operational Control For Significant Environmental Aspect:
Energy Conservation (electricity)
Document Control Code: EMP-02.01
Date: 5/21/2004
Activity Group:
Use of Office and Lab equi
^uipment
Activities (and corresponding written controls, where applicable):
a. Use of laboratory and facility equipment (e.g., autoclaves, copiers, dishwashers, fume hoods, lighting, PCs, printers)
b. Handling, storage, and use of microbial agents
c. Analysis of samples/prep
d. Use of in-house analytical instrumentation
Operational Controls such as technological, operational, procedural (and corresponding written controls, where
applicable):
Purchase green technologies (e.g., automatic sleep conditions for copiers, printers and monitors)
Sensor switches for room lights
Awareness posting and education
Maintenance plan(s) for the operational controls:
a. Weekly review of data and monthly processing of information to make adjustments for the next period.
Actions to be taken if controls fail:
Revisit assumptions by critical support groups (internal and external)
Add identified projects to B&F submissions
Reevaluate monitoring strategy
Records
Person Responsible and Record
Location:
a. Monthly utility bills
b. Preventive maintenance logs
c. Trend data (electricity consumption graphs)
d. Records of awareness activities performed (training course sign-up sheets, brown-bag
lunch announcements, e-mails that raise awareness and other correspondence
including recommendations from periodic outside evaluations)
a. Facility Manager 158
b. Building Engineer 218
c. Energy Team 154
d. Building Engineer 218
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls
Title
Responsibility
Building Engineer
Facility Manager
Supervision of contract work staff
Facility Manager
Competence of operators on the basis of training, education or experience:
Title
Competence
Facility Manager
Building Engineer
On-the-job training, facility management courses, experience, contracting/project officer training; factors
in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work
environment
>5 years operations and maintenance supervision; factors in Contract SOW describe knowledge required
by the position, supervisory controls, guidelines, complexity, scope and effect, personal contacts, purpose
of contacts, physical demands and work environment
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Operational Controls Form
Significant Environmental Aspect:
Energy Conservation
Document Control Code: EMI-Mj2.(j2
Date: 5/21/2004
Activity Group: Facility Operation and Maintenance of HVAC and Electrical Infrastructure Systems
Activities (and corresponding written controls, where applicable):
HVAC and electrical systems equipment manuals and SOP documentation.
a. Operation and Maintenance of Mechanical Central Plant and facility infrastructure equipment.
b. Operation and Maintenance of Electrical Distribution Systems and utility equipment.
c. Operation and Maintenance of CFC Containing Devices.
d. Reduction of contaminants including dirt and moisture into main outside air intake or out of exhaust ventilation.
e. Reduction of exhaust, effluent or by-products of energy consuming equipment of facility operations, maintenance.
f__ObtainGreenEner^sourc£^u££lies^id2denti^^easforener^us£reduction^^^^^^^^^^^^^^^^^^^_
Operational Controls such as technological, operational, procedural:
a. Perform quarterly performance testing on main Mechanical
Central Plant equipment.
b. Central Plant equipment reading logs.
c. Daily equipment and maintenance inspections.
d. Annual combustion analyses.
e. Scheduled infrastructure equipment preventative
maintenance including BAS, DDC Systems.
f. Replace electrical UPS System ASAP.
Procure Emergency Generator fuel with low sulfur content and
monitor storage tank fuel quality.
Annual fume hood maintenance inspections and certifications, daily
fume hood alarm monitoring
Monitor electrical power quality, track utility usage, establish
monitoring program and management tools training
Triennial internal and annual external audits
Maintenance plan(s) for the operational controls:
a. Review procedures periodically
b. Calibrate and/or verify sensors/meters periodically
c. Review equipment reading logs
d. Update infrastructure improvement, B&F and energy
conservation recommendations and report to SHEMP
Manager.
e. Review annual combustion analysis reports
f. Conduct annual and triennial audits
g. Review training certificates
h. Review fuel usage and content reports
Actions to be taken if controls fail:
a. Training, communication
b. Procure and/or install corrective procedures, services or hardware
c. Evaluate additional controls
Rccord(s):
Responsible Pcrson(s) and Record Locations:
a. Fuel usage, hours of operation
b. Stationary Engineering License renewals
c. Equipment inspection and survey reports
d. Preventive maintenance records
e. Electrical maintenance licenses and permits
f. Annual boiler/generator combustion analysis
g. visible emissions inspection
h. Regulatory review
i. Internal/external inspection reports
j. Universal CFC license
a. Building Engineering, Room 218
b. SHEM Program Manager, EMS Coordinator Room 158
c. Library 140
d. Quality Assurance Officer, Room 134
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls
Title
Responsibility
SHEMP
Manager
Building
Engineer
Regulatory review and updates
Fuel purchase, specifications & content requirements. Personnel certifications and training. Requirements Program
management. NOx emissions calculations. Annual combustion analyses. Equipment inspections & surveys. Annual preventive
maintenance. Corrective actions.
Competence of operators on the basis of training, educat ion or experience:
Title
Competence (Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.)
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SHEM
Manager
Facility
Manager
Operational Controls Form
Attendance at annual national EPA SHEM Conferences. Networking with other SHEM Managers. CFR updates. EPA
Headquarters updates & correspondences. EPA, DOD and private regulatory publications. Regulatory E-mail updates.
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines, complexity,
scope and effect, personal contacts, purpose of contacts, physical demands and work environment. Attendance at annual
national EPA Facility Manager. Conferences. Networking with other Facility Managers. CFR updates. EPA Headquarters
updates & correspondences. Regulatory E-mail updates
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OC Water Conservation
Operational Controls Form
Significant Environmental Aspect:
Water Consumption
Document Control Code: EMP-3.00
Date: 5/21/2004
Activity Group:
Operation and maintenance of the REGION 6 LAB & FIELD OPERATIONS
Activities (and corresponding written controls, where applicable):
a. Use of water in cooling towers and other components of the HVAC system
b. Facility Operation and Maintenance
Operational Controls such as technological, operational, procedural (and corresponding written controls, where
applicable):
Monitor water usage with an in-line flow meter (located at chiller and main water intake line)
a. Track monthly utility costs using an electronic spreadsheet
b. Preventive maintenance on boilers, chillers, and fan motors, fume hoods, other electrical equipment (ESAT annual work plan, SOPs for
EPA Houston Lab tabs 3, 7, 8)
c. Maintain and adjust boilers, chillers, fan motors and other equipment associated with the HVAC system to optimize efficiency (Bell
Operation and Maintenance Manuals)
d. Maintain and adjust equipment associated with the facility to optimize efficiency (Bell Operation and Maintenance Manuals)
Maintenance plan(s) for the operational controls:
a. Review procedures periodically
b. Review water usage
Actions to be taken if controls fail:
a. Reevaluate strategy
b. Purchase and/or install corrective services or hardware
c. Evaluate additional controls
Rccord(s):
Person Responsible and Record Location:
a.
Weekly water usage reports
a.
Water Team Lead
107
b.
Monthly utility bills
b.
SHEM Manager
158
c.
Monthly preventive maintenance logs
c.
Water Team Lead
107
d.
Region 6 lab & field operations Office of Policy and
d.
SHEM Manager
158
Management Year End Report
e.
Water Team Lead
107
e.
Records of awareness activities performed (training course
f.
Water Team Lead
107
sign-up sheets, brown-bag lunch announcements, e-mails that
raise awareness)
^laiirtenmicejmdre£airrecordj^^^^^^^^^^^^^^^^^^
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls
Title
Responsibility
Facility Manager
Building Engineer
Take periodic measurements and compare to historical usage.
Maintenance of boilers, chillers, fan motors and other equipment associated with the HVAC system
Competence of operators on the basis of training, education or experience:
Title
Competence
Facility
Manager
Building
Engineer
Experience operating laboratories. Experience with construction and operating contracts as Project Officer. Conversant
regarding technology. On-the-job training. Position Description describes knowledge required by the position, supervisory
controls, guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work
environment
>5 years experience in operation supervision. 1st class engineers license; Contract SOW describes knowledge required by the
position, supervisory controls, guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical
demands and work environment
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OC Waste Reduction
Operational Controls Form
Significant Environmental Aspect:
Waste Reduction
Document Control Code: EMP-4.00
Date: 5/21/2004
Activity Group:
Hazardous Waste Disposal
Activities (and corresponding written controls, where applicable):
a. Hazardous waste management.
b. Calibration and maintenance of lab equipment.
c. Change oil in pumps
d. Sample/ sample container disposal.
e. Use of pesticides outside (Grounds maintenance contract)
f. Use of solvents.
g. Facility operation and maintenance.
h. Operation and maintenance of heating/air conditioning (refrigerants)
i. Safety practices/program (PPE, spill clean up, safety showers)
j. Sample collection in field
Operational Controls such as technological, operational, procedural (and corresponding written controls, where
applicable):
a. Hazardous waste disposal procedures
b. Hazardous waste contract requirements (Statement of work in hazardous waste contract)
c. All waste must be stored in the satellite accumulation areas
d. Restricted access 90-day accumulation areas
e. Secondary containment required for all hazardous materials.
f. Waste committee meetings and procedures.
g. Annual internal inspection by Region 6 SHEM Managers
h. Triennial external inspection by EPA HQ (SHETX)
i. Annual laboratory safety refresher training
Maintenance plan(s) for the operational controls:
a. Review procedures and contract deliverables periodically
b. Weekly inspections of accumulation areas
c. Review of inspection reports and audit findings by REGION 6 LAB & FIELD OPERATIONS personnel and R6 and HQ staff
d. Investigate spill or hazardous material incidents to prevent & institute new procedures
e. Review training records periodically
Actions to be taken if controls fail:
a. Investigate and install additional controls
b. Provide retraining as necessary
c. SHEM Manager implements corrective action changes through Waste Committee and organizational management components
d. Appropriate communications to effected REGION 6 LAB & FIELD OPERATIONS Staff
Rccord(s):
Person Responsible and Record Location:
a. Hazardous waste manifests
b. DOT Dram Inventory Forms
c. Certificates of Disposal / Treatment
d. Contract Invoices / EPA Receiving Reports
e. Waste Committee Meeting Minutes
f. Accumulation Area Logbooks
g. Waste Profiles
h. Contractor Field Report Forms
i. Restricted Waste Notification & Certification Forms (Land Ban
forms)
j. PCB Waste Logbook & Tracking Forms
k. Annual Waste Report to the State of Texas
1. Internal/external inspection reports
m. Accumulation area inspection logbooks
n. Records of awareness activities performed (training course sign-up
sheets, brown-bag lunch announcements, e-mails that raise
awareness)
o. Training records
p. Pesticide usage report
a. SHEM Manager
b. SHEM Manager
c. SHEM Manager
d. SHEM Manager
e. SHEM Manager
f. SHEM Manager
g. SHEM Manager
h. SHEM Manager
i. SHEM Manager
j. SHEM Manager
k. SHEM Manager
1. SHEM Manager
m. SHEM Manager
n. EMS Coordinator
o. SHEM Manager
p. Facility Manager
158
158
158
158
158
158
158
158
158
158
158
158
158
158
158
158
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Operational Controls Form
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls
Title
Responsibility
a. SHEM Manager
b. Hazardous Waste
Removal Contractor
c. Janitorial Contractor
d. Waste Team
e. Laboratory Staff
f. Organizational
Management
a. Ensures controls are in place and working. Maintains relevant records. Investigates and precipitates
corrective actions when controls fail.
b. Packages, transports and disposes of hazardous wastes in accordance with the contract specifications and
applicable regulations.
c. Packages, transports and disposes of solid wastes in accordance with the contract specifications and
applicable regulations.
d. Ensures controls are in place and working. Maintains relevant records. Investigates and precipitates
corrective actions when controls fail.
e. Follow all applicable controls, procedures and practices for handling and disposing of hazardous wastes.
f. Ensures controls are in place and working. Participates in investigations and corrective actions when
controls fail. Responsible to ensure that all other responsibilities are being fully met.
Competence of operators on the basis of training, education or experience:
Title
Competence
a. SHEM Manager
b. Facility Manager
c. Hazardous Waste Removal
Contractor
d. Janitorial Contractor
e. Organizational Waste
Coordinators
f. Laboratory Staff
a. Factors in Position Description describe knowledge required by the position, supervisory controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical
demands and work environment. Attendance at annual national EPA SHEM Conferences.
Networking with other SHEM Managers. CFR updates. EPA Headquarters updates &
correspondences. EPA, DOD and private regulatory publications. Regulatory E-mail updates.
b. Factors in Position Description describe knowledge required by the position, supervisory controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical
demands and work environment. Attendance at annual national EPA Facility Manager
Conferences. Networking with other Facility Managers. CFR updates. EPA Headquarters updates
& correspondences. Regulatory E-mail updates.
c. Factors in Contract SOW describe knowledge required by the position, supervisory controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical
demands and work environment.
d. Factors in Contract SOW describe knowledge required by the position, supervisory controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical
demands and work environment.
e. Factors in Position Description describe knowledge required by the position, supervisory controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical
demands and work environment.
f. Attendance at annual training courses
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Operational Controls Form
Significant Environmental Aspect:
Waste Reduction
Document Control Code EMP-4.01
Date: 5/21/2004
Activity Group:
Non-hazardous Waste Disposal
Activities (and corresponding written controls, where applicable):
a. Analysis of Samples/Preparation
b. Calibration and maintenance of lab equipment
c. Changing oil in pumps
d. Construction
e. Lab neutralization usage
f. Manage nonhazardous waste (Janitorial contract statement of work)
g. Sample/Sample Container Disposal
h. Use of pesticides outside (Grounds maintenance contract/subcontract statement of work)
i. Use of Solvents
j. Eating in lunchroom/food preparation
k. Facility cleaning (cleaning products and equipment)
1. Facility maintenance and operation
m. Handling, Storage, and Use of Biological Agents
n. Maintenance of government owned vehicles and boats, including mobile lab
o. Operation and maintenance of heating/air conditioning (refrigerants)
p. Safety Practices/Program such as PPE, spill clean up, safety showers
q. Sample collection in field
r. Use of autoclaves, dishwashers, in-house laboratory analytical and safety & health instrumentation
Operational Controls such as technological, operational, procedural (and corresponding written controls, where
applicable):
a. Solid waste disposal procedures and contract requirements (Interagency Service Agreement)
b. Recycle bins for paper, aluminum, glass and some plastics placed in strategic areas
c. Inspection of recycled materials
d. Waste committee meetings and procedures
e. Annual internal inspection by Region 6 SHEM Managers
f. Triennial external inspection by EPA Headquarters
g. Annual laboratory safety training
h. Storm drain system and catch basin are designed to contain an uncontrolled spill.
Maintenance plan(s) for the operational controls:
a. Review procedures and contract deliverables periodically
b. Review of inspection reports and audit findings by REGION 6 LAB & FIELD OPERATIONS personnel and R6 and HQ staff.
c. Investigate incidents to prevent & institute new procedures
d. Review training records periodically
e. Periodic reminders to staff about recycling and solid waste program
Actions to be taken if controls fail:
a. Investigate and install additional controls
b. Provide retraining as necessary
c. SHEM Manager implements corrective action changes through Waste Committee, Facility Manager and organizational management
components
d. Appropriate communications to affected REGION 6 LAB & FIELD OPERATIONS staff
Rccord(s):
Person Responsible and Record Location:
a. Waste Committee Meeting Minutes
b. Contract invoices / EPA receiving reports
c. Non-Hazardous Waste Manifests
d. Internal/external inspection reports
e. Records of awareness activities performed (training course
sign-up sheets, brown-bag lunch announcements, e-mails that
raise awareness)
f. Inventory of recycled materials, including aluminum cans,
glass bottles (clear and brown), batteries, wood pallets, paper,
and cardboard
g. Pesticide usage report
a.
Recycle Team
152
b.
SHEM Manager
158
c.
SHEM Manager
158
d.
Recycle Team
152
e.
EMS Coordinator
158
f.
Recycle Team
152
g-
Facility Manager
158
Responsibilities:
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Operational Controls Form
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls
Title
Responsibility
a. SHEM Manager
b. Facility Manager
c. Janitorial Contractor
d. Organizational Waste
Coordinators
e. Laboratory Staff
f. Organizational
Management
a. Ensures controls are in place and working. Maintains relevant records. Investigates and precipitates
corrective actions when controls fail.
b. Ensures controls are in place and working. Maintains relevant records. Investigates and precipitates
corrective actions when controls fail.
c. Packages, transports and disposes of solid wastes in accordance with the contract specifications and
applicable regulations.
d. Ensures controls are in place and working. Maintains relevant records. Investigates and precipitates
corrective actions when controls fail.
e. Follow all applicable controls, procedures and practices for handling and disposing of solid wastes.
f. Ensures controls are in place and working. Participates in investigations and corrective actions when
controls fail. Responsible to ensure that all other responsibilities are being fully met.
Competence of operators on the basis of training, education or experience:
Title
Competence
a. SHEM Manager
b. Facility Manager
c. HazardousWaste
Removal Contractor
d. Janitorial Contractor
e. Organizational Waste
Coordinators
f. Laboratory Staff
a. Factors in Position Description describe knowledge required by the position, supervisory controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical demands and
work environment. Attendance at annual national EPA SHEM Conferences. Networking with other
SHEM Managers. CFR updates. EPA Headquarters updates & correspondences. EPA, DOD and private
regulatory publications. Regulatory E-mail updates.
b. Factors in Position Description describe knowledge required by the position, supervisory controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical demands and
work environment. Attendance at annual national EPA Facility Manager Conferences. Networking with
other Facility Managers. CFR updates. EPA Headquarters updates & correspondences. Regulatory E-
mail updates.
c. Factors in Contract SOW describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work
environment.
d. Factors in Contract SOW describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work
environment.
e. Factors in Position Description describe knowledge required by the position, supervisory controls,
guidelines, complexity, scope and effect, personal contacts, purpose of contacts, physical demands and
work environment.
f. Attendance at annual training
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Operational Controls Form
Significant Environmental Aspect:
Environmentally Preferable Purchasing
Document Control Code EMP-4.02
Date: 5/21/2004
Activity Group:
Waste Management
Activities (and corresponding written controls, where applicable):
(that produce/abate the aspect):
a. Purchase of Office products
Operational Controls such as technological, operational, procedural (and corresponding written controls, where
applicable):
a. Purchase of Office products: Region 6 Purchasing Staff and Purchase Card Holders are required to follow the Agencies EPP
Guidelines and Region 6's Procurement Plan. (See procurement specifications in EPA Procurement Guidelines and Region 6's
Affirmative Procurement Plan)
b. Purchase of Office products: Annual report describing procurement practices at Region 6. (See Annual Region 6EPP report)
c. Purchase of Office products: Quarterly briefing from Affirmative procurement Team describing the Regional Offices procurement
trends.
Maintenance plan(s) for the operational controls:
Changes in the procurement trend of Region 6 identified though the Region 6 EPP Annual Report or Affirmative Procurement Team
briefings will result in a preliminary assessment to determine if there is a clear cause and if this change increases or decreases the impact of
the significant aspect. The change and potential impact is communicated to the EMS team to determine what actions should be taken to
correct the issue if necessary. (All operational controls are reviewed in the annual internal EMS audit.)
Actions to be taken if controls fail:
(See above)
Rccord(s):
Person Responsible and Record Location:
Records of monitoring and measuring
Person Responsible and Record Location:
Significant Aspect Lead is responsible for Operational Control
records
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls
Title
Responsibility
Purchasing Staff
Purchase Card
Holders
Affirmative
Procurement Team
Significant Aspect
Lead
Purchase Office product for Region 6 in accordance with EPA and Regional Policy
Purchase Office product for Region 6 in accordance with EPA and Regional Policy
Set up and retention of duplex settings by LAN administrator.
Maintain understanding of Regional Office Procurement Practices develop the Region 6 Annual
Procurement Report.
Schedule EPP training for Purchasing staff and coordinate quarterly Affirmative Procurement Status
updates.
Competence of operators on the basis of training, education or experience:
Title
Competence
a.
b.
Purchasing Staff
Purchase Card
Holders
Affirmative
Procurement Team
Significant Aspect
Lead
Management Representatives have deemed the Purchasing Staff competent to carry out these
responsibilities by virtue of experience and education
Management Representatives have deemed the Purchase Card Holders competent to carry out these
responsibilities by virtue of experience and education
Management Representatives have deemed the Affirmative Procurement Team competent to carry out
these responsibilities by virtue of experience and education
Management Representatives have deemed the Significant Aspect Lead competent to carry out these
responsibilities by virtue of experience and education
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OC Chemical Management
Operational Controls Form
Significant Ln\ ironnicntal Aspect:
Chemical Management
Document Control Code: (JC-04
Date: 5/21/2004
Activity Group: Analysis of samples/prep (except instrumental analysis)
Activities (and corresponding written controls, where applicable):
Analysis of samples/preparation
Operational Controls such as technological, operational, procedural (and corresponding written controls, where
applicable):
a. Written procedures for handling solvents (Chemical Hygiene Plan sections addressing fume hoods).
Maintenance plan(s) for the operational controls:
a. Review CHP and SOPs periodically
Actions to be taken if controls fail:
a. Training, reeducation, communication
b. Evaluate additional controls
Record(s):
Responsible Person and Record Location:
Training records as needed
Quality Assurance Officer Room 134
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls)
Title
Responsibility
SHEM Manager
Lab Lead
Ensure controls are in place, create and keep relevant records.
Take action when controls fail.
Competence of operators on the basis of training, education or experience:
Title
Competence
SHEM
Manager
EMS Lead
Auditor
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
^^comj^lexit^jicoj^andeffectjj^ersona^ontacts^j^i^^
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OC Noise Reduction
Operational Controls Form
Significant Environmental Aspect:
Noise Emissions
Document Control Code: EMP-05.00
Date: 9/21/03
Activity Group: Facility Operation and Maintenance
(Note: following 8 months of monitoring this aspect has been found to NOT be a Significant Environmental Aspect & WILL
NOT BE TRACKED further)
Activities (and corresponding written controls, where applicable):
a. Noise monitoring of ALL labs.
b. Noise monitoring of ALL office spaces.
c. Noise monitoring of ALL other workspaces.
d. Noise monitoring of annual fume hood certification to ensure 70-dBA standard met.
Operational Controls such as technological, operational, procedural:
a. Monitors fume hoods.
b. Reduce noise emission from L/N sources.
c. Preventive maintenance.
Airflow monitoring of fume hoods.
Annual internal audits.
EMS Noise Team meeting.
Maintenance plan(s) for the operational controls:
a. Review procedures periodically
b. Calibrate and/or verify sensors/meters periodically
c. Review reading logs
a. Conduct annual and triennial audits
b. Review training certificates
Actions to be taken if controls fail:
Training
Procure and/or install corrective services or hardware
Evaluate additional controls
Record(s):
Responsible Person and Record Location:
Noise logs.
Fume hood calibration records.
a. Facility Manager
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and keep records relative to operational controls
Title
Responsibility
Facility Manager
Building Engineer
Regulatory review and updates
Schedule annual fume hood certification.
Competence of operators on the basis of training, education or experience:
Title
Competence
SHEM
Manager
Facility
Manager
Attendance at annual national EPA SHEM Conferences. Networking with other SHEM Managers. CFR updates. EPA
Headquarters updates & correspondences. EPA, DOD and private regulatory publications. Regulatory E-mail updates.
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.
Attendance at annual national EPA Facility Manager Conferences. Networking with other Facility Managers. CFR
updates. EPA Headquarters updates & correspondences. Regulatory E-mail updates.
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Operational Controls Form
Significant Environmental Aspect:
Document Control Code: HMl->-(i5.ul
Noise Emissions
Date: 9/21/03
Activity Group:
Analysis of noise
e
vels within workspace.
Aclivilies (ant
corresponding wrillen conlrols, where applicable):
Analysis of sampl
/preparation
Operational Controls such as technological, operational, procedural (and corresponding written controls, where
applicable):
a. Written proc
edures for noise protection when/if require
d.
Maintenance plan(s) for the operational controls:
a. Review CHF
and SOPs periodica
iy
Actions to be taken if controls fail:
a. Training, reeducation, communication
b. Evaluate additional controls
Rccord(s):
Responsible Person and Record Location:
Training records as needed
SHEM Manager room 158
Responsibilities:
a. to ensure controls are in place;
b. to ensure controls keep working;
c. to take action when controls fail;
d. to create and
keep records relative to operational controls
Title
Responsibility
SHEM Manager
Lab Lead
Ensure controls are in place, create and keep relevant records.
Take action when controls fail.
Competence of operators on the basis of training, education or experience:
Title
Competence
SHEM Manager
Quality Assurance
Officer
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.
Factors in Position Description describe knowledge required by the position, supervisory controls, guidelines,
complexity, scope and effect, personal contacts, purpose of contacts, physical demands and work environment.
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Section 6—EMS Records
Introduction
Section 6 contains or references all documentation that acts as a record of actions completed
under the EMS, including carrying out the procedures.
All relevant records for the Region 6 lab & field operations EMS can be located on the Region 6
shared directories, see records section in: S:\EnvironmentalManagement Systems\ "A. EMS
Procedure for Identifying Significant Environmental Aspects "
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Section 7—EMS Definitions
Introduction
Section 7 contains definitions of terms that might be useful to Individuals coming to the EMS for
the first time, or other common EMS terms for which a definition would be useful.
Term
Definition
EMS Coordinator
The Houston Lab SHEM Manager holds this position.
Responsible for establishment of the overall EMS program as
well as Management appointee to ensure continued EMS
implementation. Once the Houston Lab receives EMS "self-
declaration" status the EMS Coordinators role is to receive
reports from SEA team leads and compile the annual EMS
report to SHEM HQ's.
Air Emissions Team
Lead
Responsible for implementation of EMP/OC and other
applicable functions within this SEA. Provides an annual
report of SEA activities to EMS Coordinator annually.
Chemical
Management Team
Lead
Responsible for implementation of EMP/OC and other
applicable functions within this SEA. Provides an annual
report of SEA activities to EMS Coordinator annually.
Energy Usage Team
Lead
Responsible for implementation of EMP/OC and other
applicable functions within this SEA. Provides an annual
report of SEA activities to EMS Coordinator annually.
Waste Reduction
Team Lead
Responsible for implementation of EMP/OC and other
applicable functions within this SEA. Provides an annual
report of SEA activities to EMS Coordinator annually.
Water Reduction
Team Lead
Responsible for implementation of EMP/OC and other
applicable functions within this SEA. Provides an annual
report of SEA activities to EMS Coordinator annually.
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Section 8 —EMS References
Introduction
Section 8 contains documents or references that allow the user to locate documents that relate to
the EMS. These include documentation that can be used by an Individual to better understand
EMS concepts or practices.
Reference:
A copy of the four training modules for EMS Implementation is located in the Region 6 lab &
field operations SHEM Manager office. Other references are located electronically within the
EMS folder and website.
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Section 9—Appendices
Introduction
Section 9 contains documents or references that allow the user to locate documents generated by
the EMS (excluding records or other information already included previously.)
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Appendix 1: Process Maps
Environmental Management Systems
R«glon 6 Laboratory, Houston, T»xas
Step 4 -- Identifying Significant Environmental Aspects
ma Mftii' »
Air
Emissions
3£)
Improve air omofiftg
building ®r intake
~
Reduce vefttcl*
k>
Reduce lab waste lhat
creates aor pollution
l reprove outdoor-ati
qualify m B'v- R4®©fi 15
area
±
Obtain Green Energy
source supplies
Covert lab grourvds to
Xeriscape landscaping |
nreaae recycling en lab
by 5% to reduce
leicenerated paper
<3
Determine
effectiveness
ot actions
tawe«
Reduce iab energy
usage (bat creates air
pollution
Reduce lab energy
demand by 10% by
2010
1®
RadUce lab nose that
creates air pollution &
noise tsrivnis&ioris
Coven lab
>'eriscape
to elirrnnai
notse err
grounds to
andscaping
e mowing
mssions
T1 = Date / Time
Need Identified
X1 « Date / Tim*
Indoor air quality
examined
X2 = Date / Tims
Outdoor air quality
examined
X3 = Date / Time
Waste generation
creating air quality
concerns identified
X4 = Date t Time
Energy
consumption
leading to poor air
quality identified
XS = Date t Time
Noise emmtsisstons
reatted to air quality
identified
Y1 = Date / Time
Region 6 lab
implements
environmental
aspect
Formulae:
Y1 - T1 - Cycle
Time
X1 -X2- Time to
identify poor air
quality indices
X3 - X4 = Time to
determine additional
air quality concern s
X5 = Time to
identify other non-
direct concerns
Note: Att times
related to this EMS
aspect are
calculated per
Region 6 building
tease through
2010.
Ill
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