Finally! – A Process that Looks at Environmental Risk Early

1. Finally! – A Process that Looks at Environmental Risk Early J. S. Irving Environmental Compliance Idaho National Laboratory

2. Life Cycle of a Project Idea Env. Risk RFP Env. Risk Proposal Env. Risk BusinessRisk Env. Risk ProjectMgmt. Env. Risk Work Control Closure

3. Project ManagementSystem • Conduct Preliminary Risk Assessment (evaluates ESH, Legal, Business, Security, etc. Risk) • Submit / Approve Project (Company & Program) • Contract Negotiations (Business Office, Authorizes Funds) • Project Work Authorization • Determine Level of Project Management … • Determine if activities is Maintenance, Sub Contract, Construction, R&D or Operation • Prepare Project Execution Plans (PEP) • Develop Cost / Schedule Office, Authorizes Funds) • Develop Work Plan • Determine Work & Environmental Hazards • Identify Applicable Mitigation & Controls • SME Review as Appropriate • Authorize to Perform Work INL’s New Approach Proposal Risk Evaluation & Preparation System PREPs Work Management System

4. Environmental Questions … • Will proposed work be performed in a location other than an office setting, where environmental hazards could be present or work control is required (e.g., experimental facility, nuclear facility, in the field)?

5. PREPS • Environmental Questions … • Will proposed work be performed in a location other than an office setting, where environmental hazards could be present or work control is required (e.g., experimental facility, nuclear facility, in the field)? • Does the work involve siting, constructing, modifying, or other changes to a building, support structure, or well?)

6. PREPS • Environmental Questions … • Will proposed work be performed in a location other than an office setting, where environmental hazards could be present or work control is required (e.g., experimental facility, nuclear facility, in the field)? • Does the work involve siting, constructing, modifying, or other changes to a building, support structure, or well?) • Will work involve siting, constructing, demolishing, closing, or abandoning a facility or structure?

7. PREPS -- Rational Project personnel need to identify what level of environmental review an activity will require such as an environmental assessment (EA) or environmental impact study (EIS). Most of our activities will fall within categorical exclusions (CX) and not require the cost, time, and effort that an EA or EIS would take. In addition, project personnel need to identify if an activity will require a notification or permit that may require resources and time to prepare and submit. Activities involving emissions, effluents, and waste (industrial, hazardous, mixed, and radioactive) may require permits, notifications, or plans approved by federal and state. Those permits may involve a long-lead time to prepare, submit, and approve. Contact John Irving, Environmental Compliance, for assistance in determining the correct level of environmental review.

8. Project Management • Prepare Project Execution Plans to identify … • environmental deliverables, reports, and activities • resources necessary to prepare environmental approvals, permits, reports, and documents • controls necessary to executing work in compliance with environmental requirements • performance measures to evaluate compliance with environmental requirements • close out activities to help verify environmental requirements met

9. Work Control • Hazard and Risk Planning System • At the core of the Work Management system is a hazard ID and mitigation tool called HaRPS which is used by all entities at the INL for hazard and risk planning and mitigation at the work activity level.

10. Example of Primary Questions • Does the work involve … • Structures, building facilities, or processes? • Generating industrial, radioactive, hazardous, or mixed waste or managing surplus property? • Airborne environmental concerns? • Chemicals, fertilizers, or regulated hazardous material? • Samples or sampling? • Potable water, waste water or storm water systems? Work Activities Controls & Mitigation Primary Questions Secondary Questions HaRPS

11. Example of Secondary Questions Potable water, waste water or storm water systems? • Does the work involve … • Drinking water or potable water systems? • Septic tanks or systems or other wastewater or sewage systems? • Storm water? • Wells? Work Activities Controls & Mitigation Primary Questions Secondary Questions HaRPS

12. Example of Work Activities Septic tanks or systems or other wastewater or sewage systems? • Does the work involve … • Discharging, or changing existing or adding new discharges of, wastewater to the City of Idaho Falls sewer system? • Constructing or modifying sewage or other wastewater systems? • Maintaining and repairing septic tanks or septic systems? • Abandoning or closing septic tanks. Work Activities Controls & Mitigation Primary Questions Secondary Questions HaRPS

13. Example of Control or Mitigation Abandoning or closing septic tanks. • Instruction … • Before abandoning or closing the septic tank, contact Environmental Support Personnel to determine if the septic tank is a CERCLA operable unit and if so, coordinate the activity with them. Work Activities Controls & Mitigation Primary Questions Secondary Questions HaRPS

14. Env. Risk Env. Risk Env. Risk Env. Risk Env. Risk Env. Risk Life Cycle of a Project Idea RFP Proposal BusinessRisk ProjectMgmt. Work Control Closure