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Management Review Environmental Management System (EMS) Finance & Administration Directorate

Management Review Environmental Management System (EMS) Finance & Administration Directorate Directorate EMS Committee EMS Representative: K. Mohring (SS) EMS Committee Members: D. Dale (PR); J. Laurie (ID); P. Pohlot (ECR-ES); J. Wilke (SS) EMS Project Manager: S. Briggs (ES)

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Management Review Environmental Management System (EMS) Finance & Administration Directorate

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  1. Management Review Environmental Management System (EMS) Finance & Administration Directorate Directorate EMS Committee EMS Representative: K. Mohring (SS) EMS Committee Members: D. Dale (PR); J. Laurie (ID); P. Pohlot (ECR-ES); J. Wilke (SS) EMS Project Manager: S. Briggs (ES) June 2, 2000

  2. Directorate Activities Budget Office Financial Services Division Information Services Division • Photography and Printing Office of the Assistant Director Procurement & Property Management Div • Scrap Yard, Warehousing Staff Services Division • Automotive Shops, Food Services, Housing

  3. EMS Objectives & Targets Objectives • Operate within regulatory requirements • Operate within internal operational requirements • Integrate pollution prevention & waste minimization in decision processes Targets • Prioritize and close EMP action items (10) • Close facility review disposition project items (24) • Evaluate pollution prevention opportunities (8)

  4. EMS Implementation Status • EMS Developed By Committee Representing All Organizations with Environmental Aspects and Input From Others • Directorate ESH Committee Needs to Begin Operations • Implementation Targets for June and July • ESH Committee Meetings • Begin Directorate Level Operations • Close-out Audit Findings and Observations

  5. EMS Implementation Issues • Setting Implementation Priorities • Management Reports, Tracking System for EMS Requirements and Tier I Findings, Employee Awareness Training, EMS Goals and Measurements, etc. • Preparation for July and October reviews

  6. EMS Audit 4/26/00 All Elements of ISO 14001 Audited Summary of Findings and Observations • Strong management commitment & involvement • High level of employee awareness • Ongoing effort to integrate the EMS with existing procedures • Issues requiring action - 2 findings, 5 observations Chief Auditor Has Been Asked to Review Changes Resulting From Findings & Observations

  7. Finding: EMS Audit Procedure Audit Plan Not Sufficiently Explicit • Plan must include an audit schedule • Responsibilities for audit completion • Requirements for conducting the audit and reporting results Corrected

  8. Finding: Process Evaluations Interrelationship Between EMP & OCF Entries Needs to be Clarified • Relationship among tasks, objectives and targets • Records that result from monitoring and operational controls should be listed • Training relationships should be linked to operational controls - detail training requirements on EMP form Corrected

  9. Observation: Policy Awareness There should be Better Employee Awareness of the Environmental Policy • Increase the number of environmental stewardship plaques Corrected

  10. Observation: Detail Aspects Analysis Display All Aspects on Aspects Analysis • The spreadsheet should be used to demonstrate that all aspects (significant & non - significant) were considered Corrected

  11. Observation: Aspects With Influence Address Aspects Over Which There Is Influence • Evaluate areas where PPM can direct procurements to vendors with good environmental records or that are ISO 14001 Registered • Procurements Currently Directed to Recycled Materials • Oils, toner cartridges, bulk paper, construction materials (pipe, plastics, fly ash) • Web based stationary procurements block out virgin products when a recycled product is available Corrected

  12. Observation: FRDP Open Items Integrate Open Facility Review Disposition Project Items in EMP or OCF Forms • Create one unified system Corrected

  13. Observation: Permits & Documentation Document Permits & Registrations as Part of the EMS • Gasoline vapor recovery systems • Underground tanks Consider Segregating Non-EMS Procedures • The procedures will be evaluated and segregated if practical Corrected

  14. Audit Interviews Summary of Interviews • ID - Two line employees, one supervisor • SS - One line employee, two supervisors (one was a sub-contractor) • DI - Deputy Assistant Director for F&A Auditors’ Impressions of Interviewees • Aware and knowledgeable about EMS and consequences and precautions of their work • Demonstrated interest and commitment to environmental care • Awareness of environmental policy might have been better

  15. Internal Assessments Tier I Inspections • Approximately 60 each year • Types of findings by volume • Maintenance • Safety • Environmental • Internal corrective actions generally timely and effective • External corrective actions take more effort to resolve 90-Day Area Weekly Inspections Semi-Annual Inspection of All Apartment Units

  16. EMS Improvements Built on Existing Foundation of Individual (Division or Office) ES&H Programs Increased Employee Environmental Awareness Management Systems • Reduced internal procedures (elimination of many SEAPPMs) • Unified set of procedures Formalized Evaluation of Processes & Aspects Centralized Training Plan Higher Level and More Formal Reporting

  17. Photographic Operations Automatic Film Processors (3 In Bldg. 197B) Input - Photographic Chemistry (Fixer, Developer, Bleach, Water, Unprocessed Film) Output - Processed Film, Photochemical Waste Water Hazardous Waste Component - Waste Photochemical (Contains Silver)

  18. Photographic Operations Past Practice Photographic chemistry Extensively Filtered (Electrostatic & Cartridges) Filtered Chemistry & Rinse Water to Sanitary Waste Material Recycled For Silver Content Present Practice Filters Removed Rinse Water to Sanitary Waste Chemistry Collected & Disposed of As Hazardous Waste Waste Film Recycled

  19. Photographic Operations Pollution Prevention & Waste Minimization • Waste Collection System Installed ($40K) • Digital Photography • Capital Cost With High Return On Investment • Reduces Reliance On Conventional Wet Chemistry • Allowed Consolidated Operations - Less Space Required • Eliminated 5 Wet Film Processors • Purchased Equipment That Uses Premixed (and less) Chemistry

  20. Photographic Operations Hazardous Waste Reduction 80% FY ‘97 11.6K lbs. FY ‘98 10.6K lbs. FY ‘99 3.6K lbs. • Operational Controls • Water meters installed on processors • Rinse water monitored for silver & phenols

  21. Photographic Pollution Prevention Ongoing Pollution Prevention Efforts • Survey value of additional digitization • Segregate fixer from waste stream • Evaluate feasibility of sending developer sanitary • Evaluate evaporating water from fixer & recovering precious metal • Continue evaluating new products & technologies

  22. Printing Operations Input • Inks, fountain & roller solutions, paper, cleanup wipes, metal plates • Output • Printed paper, waste ink, wash-up solutions, cardboard, spent fountain solution, scrap paper • Industrial Waste • Waste soy based inks

  23. Printing Operations Past & Present Practices • Scrap paper - recycled • Cardboard - recycled • Metal plates - recycled • Soiled rags - commercial laundry • Spent wash-up solution - trash • Spent fountain solution - sanitary system Waste Ink • Past practice - trash • Present procedure - collected & disposed as industrial waste

  24. Printing Pollution Prevention Past Practice • Petroleum based inks • Alcohol based fountain solutions • Petroleum based wash-up solutions • Virgin papers • Present Practice • Soy based inks • Aqueous fountain solutions • Environmentally friendly wash-up solutions • Recycled papers - 20 to 30% post consumer waste • Ongoing Effort • Investigation of new dry film technologies & digital printing technologies

  25. Automotive Shop/Employee Svce Station • Activities with Environmental Aspects • Handling, storage and dispensing gasoline - five 8,000 gallon tanks • Generation and disposal of industrial waste • Parts cleaning - four systems

  26. Operational Controls - Gasoline Double-walled Underground Tanks • Interstitial monitoring • On-line inventory information GasBoy Dispensing System to Track Use Gasoline Pump Readings for Fuel Dispensed Daily Reconciliation of Gasoline Use and Delivery Records Procedure for Gasoline Delivery

  27. Operational Controls -Industrial Waste • Used Motor Oil Collected & Recycled • Oil stored in above & below ground tanks • Picked- up by vendor at nominal cost Used Oil Filters Drained and Crushed Then Shipped Off-Site by HWM Used Antifreeze Recycled Oil Soaked Speedi-dri Shipped Off-Site by HWM

  28. Operational Controls - Parts Cleaning Long-Term Use of Safety-Kleen • Collected and recycled by vendor • Only virgin product accepted • Evaluating System One Parts Cleaner • Uses high flash point kerosene cleaned internally and reused • Waste product mixed with waste oil

  29. Monitoring Historical Processes Monitoring Well Results - Automotive Shop • No ground water contamination from hydraulic oil leak or fuel spill south of Bldg. 326 • NYS has closed hydraulic spill file (no further action required) • Level of TCA is above drinking water standard • Monitoring will continue and action plans developed as appropriate ESH Committee Will Monitor Activity

  30. Monitoring Historical Processes Monitoring Well Results - Employee Service Station • Historically low levels of carbon tetrachloride have been observed • Remediation ongoing west of the site • Oil breakdown products recently observed • Monitoring and sampling will continue • ESD personnel have determined that an evaluation of dry wells should be conducted ESH Committee Will Monitor Activity

  31. Pollution Prevention Measures Government Fleet • Reduced service intervals from 3 to 6 months • Converting fleet to alternate fuel - CNG • Use recycled motor oil Both Service Stations • Recycle lead acid batteries • Scrap metal & used tires part of BNL disposition programs (PR & EP) • No chlorine based solvents

  32. Pollution Prevention Opportunities Installation of CNG Fueling Station • Operational Within 12 Months • Access to Local Fleets -State, County, Keyspan Evaluating • Expanding the Use of “System One” Parts Cleaner • Use of Vegetable Oil Based Fluids for Hydraulic Lifts Lift Program • Continue to Replace Lifts With Above Ground Electric Units

  33. Chemical Storage Stored on Safety Spill Pallets Eyewash and Emergency Shower Units Available Training Requirements • Personal protective equip. • Hazard communication • Spill procedures

  34. Metal Recycling FY 1998 64 Tons FY 1999 47 Tons • Scrap Monitored Prior To Acceptance • Segregated by Metal Type • Recycling • Eliminates dumping fees • Provides revenue

  35. Food Services Food Contractor Personnel Receive Environmental Training Commercial Refrigeration Contractor Recycles Freon Plastic and Metal Containers Recycled Evaluating Newspaper Rack for Used Newspapers

  36. Housing Area Thirty Seasonal Cottages Discharge Liquid Waste to Cesspools • Exempted from UIC program because fewer than 10 individuals inhabit the units Town Recycling Program in Place for Plastic, Metal and Paper Housing Employee Training • Hazard communication • Chemical compatibility

  37. Senior Management Evaluation Purposes Include Ensuring • Identification of areas for improvement • Assignment of responsibilities • Resources available for implementation

  38. Record of Decision Is the EMS Program effective in achieving environmental policy commitments • Compliance assurance • Pollution prevention • Continual improvement • Community outreach • Clean-up Is the EMS Program effective in achieving environmental objectives and performance measures?

  39. Record of Decision cont. Is the EMS Program Adequate to Identify • Significant environmental aspects & impacts • Needs for resource allocations • Required information systems • Organizational expertise and procedural requirements

  40. Record of Decision cont. Are Objectives and Performance Measures and the EMS System Suitable in Terms of • Environmental impacts and current conditions • Stakeholder concerns • Current and future regulatory requirements • Business interests and technological capability • Internal organizational or process changes • Are additional performance measures required

  41. Record of Decision cont. Recommended Revisions to • Environmental policy or commitments? • Objectives and performance measures? • Elements of EMS?

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