Introduction

1. The EMS Process at Godfrey Point:The Experience So Farpresentation at the EPA-Region I/NEWMOA2005 Environmental Summitby:Dan DeMiccoP2 Unit, Division of Environmental PermitsNYS Department of Environmental ConservationSeptember 25, 2005

2. Introduction • Godfrey Point (GP) is a pilot for the Commissioner’s new Environmental Leadership (ELP) policy • By doing this we are learning about issues, problems, and opportunities in designing, implementing, and operating an EMS – will also help us understand problems and challenges facing non-DEC facilities • An EMS produces benefits by helping GP improve its environmental performance in various operational areas: e.g., compliance, impacts from facility operations, material inputs, impacts from products • Hopefully, at the same time GP can save some money

3. EMS Components/Steps • Obtain Management Commitment • Form a Team • Choose a Champion • Establish an Environmental Policy • Collect Facts & Produce Documentation • Conduct Planning & Choose Improvement Projects • Implement EMS • Perform Checking and Corrective Actions • Conduct Continual Improvement/Management Review • Produce and Maintain EMS Manual

4. Early 2003 - Commissioner expressed interest in conducting pilots at two DEC facilities – this meant our Division of Operations The Regional Director (RD) (HQ is in Watertown) volunteered and (with input from her staff) chose Godfrey Point Sign Shop (GP) on Oneida Lake, which became the pilot Cortland (Auto) Maintenance Center in Region 7 (Syracuse is the HQ) was considered, but its candidacy is uncertain at this point In August 2004, the Team met with the RD with the Regional Engineer to brief her and obtain her direct statement of support In March 2005, the Team, led by the RD, may an hour presentation to the Commissioner & DEC Exec Staff Management Commitment

5. June 2003 – initial (teleconference) team meeting held: Mike Turley - Director, Div of Operations Ron Novak, Region 6 - M2P2 Coordinator Brian Fenlon, Region 6 - Permits Administrator Frank LaFlair, Region 6 - Operations Supervisor John Iannotti, CO - Div of Operations John Vana, P2 Unit Except for Mike Turley, this became the Team along with: - Dave Liddy, GP facility manger - Dan DeMicco P2 Unit - Gary Vanderneut, Region 6 - Operations QC Supervisor Ron Novak chosen Champion – has key role making sure everything moves along, liasion betweem mgt & team, etc Form a Team/Designate a Champion

6. GAP Analysis • In August 2003 this was carried out, along with a site visit and interviews with staff • From the above, it was learned that: • - some current management practices fit well with an - EMS • - others were only partially in place • - others did not exist • - some existing ones needed to be rewritten

7. Environmental Policy • This was first discussed in September 2003 and finalized in March 2004 • The policy announces management’s commitment to continual environmental improvement (including implementing & maintaining an EMS) (see Attach A) • GP’s policy deals with compliance, risk reduction, P2, resource management, communication, and a commitment to continual improvement

8. EMS Manual • In September 2003, the Team began to write Standard Operating Procedures (SOPs) for each step of the EMS as that step was completed (for example, see Attach B) • As they are drafted and finalized, these are collected together to make the core of the EMS Manual (along with related descriptive and analytical material) • The EMS Manual will provide permanent guidance and reference material to GP staff as well as other stakeholders, including auditors

9. Fact Finding and Documentation (1) • Identify Environmental Aspects and Impacts • Definitions: • Aspects are elements of an organization or a process that can interact with the environment • Impacts are the respective impacts (adverse and beneficial) of the aspects • From Nov 2003 to April 2004, aspects and impacts were identified, as discussed below: • Identify Functions • These are related activities that can be grouped together into a function (a group of related activities) (Attach B)

10. Fact Finding and Documentation (2) • Produce Process Maps(Attach D) • These depict major steps (boxes) of the function or process steps move from left to right • Resource inputs and waste outputs are depicted respectively as vertical arrows entering or exiting the process steps • Maps assist in: • identifying P2 opportunities by depicting all major process steps and interactions • assessing impact of proposed process changes • Produce Input/Output Table (Attach E) • This table reports additional details about what is graphically depicted on the process maps, e.g., • volume of raw material, waste, and product output • related environmental impact data

11. Fact Finding and Documentation (3) • Identify Legal Requirements/Non-Compliance • The Champion put together a Legal Requirements Table the same time as the Aspects were being documented – organized by process step and by law/regulation/exec order (Attach F) • DEC Regional staff conducted compliance inspections in May & July 2004 – found a number of (mostly minor but one major) violations • All violations are considered top-priority projects • A number have already been brought into compliance or will be in the near future - for the latter, the Region has produced remedial action plans & schedules

12. Conduct Planning (1) • Identify Objectives and Targets • Prioritize Functions (Attach G) • In April 2005, the Team used the following criteria to rate environmental significance of functions: environmental risks (scope, severity, impact freq) and non-compliance risks • Impacts and risks were considered to worker health and safety, public health, ecosystem health, and resource consumption/waste generation • Produce Potential Projects Listing • In June, the Team brainstormed a list of potential projects only looking at the six most significant functions – this resulted in 57 potential projects

13. Conduct Planning (2) • Produce Prioritized Projects Listing(Attach H) • In July, the Team used the “bubble up/bubble down” methodology to obtain group consensus on the priority sequence of the 57 potential projects Produce Paired-Down Projects Listing • In August, the Team selected the top 25% of the projects and paired down the list resulting in perhaps 7 or 8 high priority projects (in addition to the non-compliance remedial projects) • Establish Objectives and Targets • For each project, this required the Team to be more specific about the Objectives it attends to achieve, e.g., reduction of air pollution, and to specify the related Target(s), e.g., “% reduction of use and/or release of chemical “x” by January 2006” • Targets allowed the Team to better focus its improvement efforts, track the project’s progress, and report on results

14. Implement EMS/Improvement Projects • From early 2005 to now, team has been simultaneously implementing both EMS and Improve Projects • Full EMS Implementation still requires: • - Checking and Corrective Action SOP(s) • - Continual Improvement/Management Review SOP • - Completed EMS Manual (see Slide 8, above) • Improvement Projects Implementation: • - Compliance, e.g. • Labeling fill ports of petroleum and oil bulk storage tanks • Aquisition of “swimming pool” (berm) for fuel deliveries • - Voluntary, e.g., • “Top coating” of signs eliminated • Mercury lamp switch out • Substitute non-VOC for VOC paint (but see slide 19, below) • Many others (see above) in process

15. Summary/What’s Next? • GP was in generally good shape to begin with, but we still found areas that could be improved • Have use GP as a: • Testing ground for learning about EMS (and apply lessons to other facilities) • Learn about EMS implementation and operation issues, constraints, problems, and opportunities • Create a “model facility” totally in compliance and practicing continual P2 • Evaluation reports to be done after full EMS implementation occurs and one year after it is in operation

16. Lessons Learned/Emerging Issues (1) • Team participation and buy-in of the full team is crucial form the beginning - and at every step • Need to make explicit assumptions, limitations, and strengths of prioritization techniques, e.g., for • functions (collection of processes) versus processes • improvement projects • impact, risk, or cost-benefit assessments of chemical “x” versus chemical “y”, pollution prevention vs resource conservation options • Need for more and better decision-support (D-S) technical information and/or expertise (i.e., expert people) • pertinent information and/or expertise does not exist, is incomplete, or hard to find • accuracy and quality of information or expertise is unknown or not rated in comparison to other information

17. Lessons Learned/Emerging Issues (2) • For environmental analysis & impact D-S information and expertise that exists, there is a need for prompt and more efficient (usually electronic) access • this includes ability to access only a minimal amount of non-pertinent information • A number of needed D-S methodologies do not exist, are undeveloped, or are not robust • in this context “robust” means that most available D-S methodologies cannot provide the user with easy-to-use, - understand, and - documented comprehensive, multi-dimensional analyses, e.g., • - “life cycle” • - “multi-media” • - “total cost assessment” • - cost/benefit • - “cost-effectiveness”

18. Lessons Learned/Emerging Issues (3) • Three GP examples illustrating issues referred to above: • - Input-Output Table analysis (see slide 10) • For prioritization (comparative impact and/or risk assessment) of the chemicals, researched available databases and publications • Used volume of chemicals from GP purchasing & use records and as calculated from the (less than optimal) MSDS sheets info • Strengths: many of these databases provide information on chemicals from national databases; have clearly written, fairly concise data dictionaries which explains characteristics of the chemicals & limitations of the information • However, it would be helpful to have more user friendly databases available that would assist EMS teams which do not have chemical and risk assessment expertise or access to experts to make more informed decision about prioritization the use of one chemcal versus another

19. Lessons Learned/Emerging Issues (4) • Substitution of enamel-based primers for latex-based ones • GP staff, concerned about glycol releases which possibly put GP out of compliance, substituted enamel-based primers for latex-based ones, which eliminated glycol for those uses • but this increased the amount of GP VOC emissions which created increased future environmental impacts and risk of future worker health impacts • Would be helpful to have more DS information readily available on these kinds of trade-offs

20. Lessons Learned/Emerging Issues (5) • - Wood product utilization/forest conservation • Team desired to encourage the use of “sustainable” forest products • GP is already using “sustainable” products from New Zealand (NZ), which presumably provides environmental benefits for NZ & perhaps even for others (e.g., could act as a “sink” for global warming chemicals) • But (even leaving aside whether energy shipping impacts are properly factored into the NZ lumber environmental impacts) there may be preferable sustainable and non-sustainable products for GP to use because, e.g., • from NYS’s frame of reference, the alternatives may last longer (1) decreasing the amount of resource consumption because new signs would have to be ordered more frequently or (2) they result in a increase of local pollution in NYS since the NZ signs are deteriorating in use at an increased rate • The point is - there is a not readily accessible, comprehensive tools to assist in optimal decision-making in this arena

21. Questions/Contact Information • ? Questions? • You can contact me (Dan DeMicco) at: • Mail: NYS DEC; P2 Unit- Div of Environmental Permits; 625 Broadway, Albany NY 4th Floor - South 12233-8010 • Phone: (518) 402-9486 • Internet: @ dwdemicc@gw.dec.state.ny.us