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EPA's Region 6 Office

Serving: Arkansas, Louisiana, New Mexico, Oklahoma, Texas, and 66 Tribal Nations

EMS Planning

Laboratory EMS Information

SECTION 2 — PLANNING

The R6 Laboratory Management, EMS Coordinator and EMS Team Leads are responsible for annually or biannually plan of the EMS activities including re-identification of environmental aspects, legal and other environmental requirements, environmental objectives and targets, revise the EMS programs to meet the existing or new objectives and targets.

2.1 IDENTIFYING SIGNIFICANT ENVIRONMENTAL ASPECTS (SEAs)
Definitions

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).

Environmental Aspect: Element of an organization’s activities, products, or services that can have impacts on (interact with) the environment (ISO 14001).

The relationship between aspect and impact is largely one of cause and effect.

Purpose

Significant Environmental Aspects (SEAs) are determined through an open and participative process. The purpose of this procedure is to ensure that all environmental aspects and impacts from R6 Lab activities are accounted for and prioritized in the EMS.

Procedure

The R6 Lab personnel were asked to list the activities that impact the environment. The specific aspects that lead to environmental impacts are listed for each activity. Management, EMS Coordinator and members are responsible for determination of SEAs. 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 for R6 Lab are determined through an open process. EMS members are responsible for identifying activities, products and/or services associated with their functional area (i.e., office, lab) that impact or may impact the environment. Then EMS members as a whole identifies any further environmental aspects that may derive from other R6 Lab activities, products, or services. In each case the environmental impact(s) associated with the aspect are identified.

  2. EMS members share an initial list of activities, aspects, and impacts within their department and modify the list. EMS members then use the individual lists to create a consolidated list of aspects, and potential impacts for the facility as a whole.

  3. The EMS members who may call on additional knowledge or expertise from within the Agency reviews the list of activities, aspects, and potential impacts.

  4. The EMS members use two significance criteria for assessing potential impacts by considering

    • The probability an aspect would result in an impact

    • 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 members apply 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 members regularly (on an annual basis or in response to significant changes) to ensure that the information is current. The EMS members and lab personnel work together 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 understanding among staff of R6 Lab. Changes or modifications to the current list of aspects are updated and communicated on a continuing basis.

Impacts are analyzed by the EMS members and given a rating for two conditions: likelihood of occurrence and magnitude of the impact. The descriptors “high”, “medium”, and “low” are used to grade both conditions. The EMS members base 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:


Table of Descriptor pairs for EMS Impact determination
Determination Criteria High Significance Medium Significance Low Significance
Impact Descriptor Pairs - Likelihood , Magnitude H, H
M, H
H, M		 H, L
M, M
L, H		 L, L
M, L
L, M


For example, the full list of significance environmental aspects of the R6 Lab for FY08 is given below.


FY2008 Significant Environmental Aspects for R6 Lab
Significant Environmental Aspects Risk Significant
Waste Management (recycling) H, M Yes
Energy Conservation H, H Yes
Water Conservation H, M Yes
Electronic Stewardship H, M Yes
Green Buying (affirmative procurement) H, M Yes
Chemical Management H, M Yes

The aspect analysis is reviewed by the EMS members 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.


The EMS members of the R6 Lab have currently determined the following significant environmental aspects and their impacts.

Significant Environmental Aspects and their Impacts
Significant Environmental Aspects Associated Activities Associated Environmental Impacts
Waste Management Reduce/Recycle all waste Land, air, water, resources
Energy Conservation Reduce energy usage Air, resources
Water Conservation Reduce water consumption Water, air, resources
Electronic Stewardship Energy Star, EPEAT, recycle
Air, resources, land
Green Buying Affirmative procurements Various impacts
Chemical Management Chemical inventory, reduction of uses, etc. Air, resources

2.2 IDENTIFYING LEGALS AND OTHER REQUIREMENTS
Definitions

Laws and Regulations: Federal, state, and local laws and regulations that apply to or otherwise impact facility operations.

Other Requirements: Executive Orders, Agency policies, directives and guidance 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

SHEMD: The Safety, Health, and Environmental Management Division (SHEMD) within the HQ Office of Administrative Services. SHEMD provides regulatory compliance support to EPA facilities nationwide including the R6 Lab.

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 R6 Lab. This support focuses primarily but not exclusively on mandates established through various Presidential Executive Orders.

Purpose

The legal and other requirements that apply to the EMS are a combination of federal and state statutes, federal executive orders, and EPA policies. The purpose of this procedure is to identify all environmental laws, regulations, and other requirements that apply to the R6 Lab. This helps ensure that the lab 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.

Procedure

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 compliance with federal executive orders, and EPA policies.

The registry of legal and other requirements is maintained and reviewed annually by the Safety Health and Environmental Management Manager (SHEM). The EMS Coordinator has responsibility for conducting environmental compliance activities, relies on information gained through the network of national EPA and other sources to ensure that the appropriate compliance requirements are identified.

In addition, EPA SHEMD performs a tri-annual compliance audit with assistance from an independent contractor. The SHEM based on the findings of the tri-annual audits coordinates corrective actions.

If necessary, EMS Teams, the Facility Manager and/or the EMS Coordinator initiate and complete required corrective actions.

The followings illustrate how an EMS Team identifies the legal and other requirements that apply to the R6 Lab.

  • For regulatory requirements, the EMS Team relies on the regulatory compliance expertise based in SHEMD. The EMS Team provides SHEMD with the final list of the R6 Lab activities, environmental aspects and associated impacts. SHEMD reviews these lists and develops a preliminary list of legal and regulatory requirements that apply to the R6 Lab.

  • For other requirements, the EMS Team relies on the expertise of SFPB. The EMS Team provides SFPB with the final list of the Region 6 lab activities, environmental aspects and associated impacts. SFPB reviews these lists and develops a preliminary list of legal and regulatory requirements that apply to the R6 Lab.

  • 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 technical staff involved in developing new mandates; 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.

  • 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.

  • SHEMD and SFPB are responsible for keeping the R6 Lab aware of any changes in applicable legal and other requirements. Following review by OGC, the list is revised and updated.

EMS regulatory drivers were researched and developed for all aspects. Below are some federal drivers:

Summary of Regulatory Requirements

This summary covers air, water, hazardous waste management, and other environmental requirements likely to apply to the EPA’s Environmental Services Branch Region 6 Laboratory in Houston, Texas. This summary of regulatory requirements is based on a review of the previous EPA SHEMD compliance audit for the laboratory, and current Texas environmental regulations.

 

Table summary of regulatory requirements for R6 Lab
AIR QUALITY
Texas Commission Environmental Quality (TCEQ) monitors air quality to ensure that the whole state meets and maintains national air quality health standards. TCEQ is responsible for emissions from both stationary and mobile sources, as well as ambient air quality standards.
Agency Applicable Regulation Key Points
TCEQ

31 TAC , Chapter 117

Industrial Boilers

 Chapter 117.203 details an exemption for “any commercial, institutional, or industrial boiler or process heater with a maximum rated capacity of less than 40 millions BTU/hr. Current regulations state Permit by Rule rather than exempt.
TCEQ 31 TAC, Chapter 117.478
Emergency Generators		 Sets exclusionary rules for potential emissions from emergency generators using combustion engines. Chapter 117.478(c) prohibits starting or operating any stationary diesel or dual-fuel engine in HGA for testing or maintenance between 6 am and noon. Rule limits hours of operation to 52 per year for testing or maintenance. New record-keeping in Chapter 117.479(i) requires runtime meters for diesel engines plus other record-keeping requirements.
USEPA 40 CFR Part 82
Ozone Depleting Compounds		 Federal regulatory standard for stratospheric ozone protection. Details requirements for servicing HVAC systems including capture of residuals, training and certification of technicians.
WATER QUALITY
TCEQ is responsible for protecting public water for a wide range of uses. TCEQ is responsible for discharges from point sources of pollution through individual permits that set limits on pollutants discharged. TCEQ is also responsible for addressing non-point sources of pollution which are diffuse or unconfined sources of pollution where wastes or contaminants can be conveyed to surface or ground water.
Agency Applicable Regulation Key Points
TCEQ 30 TAC, Chapter 315
Pretreatment Standards for Industrial Discharges		 The purpose of these rules is to prescribe limitations on discharge of wastes, requirements and procedures for obtaining pretreatment discharge permits from local authorities. The rules in this chapter are designed to implement the provisions of the CWA, regarding the pretreatment of industrial discharges into publicly owned treatment works (POTWs). They establish responsibilities of state, local governments and industries to implement Pretreatment Standards to control pollutants which pass through or interfere with treatment processes in POTWs that may contaminate sewerage sludge, or otherwise have an adverse impact on the POTWs, its workers, or the environment. The pretreatment permit will include at least the following: effluent limitations, monitoring and reporting requirements, compliance schedule, and any other special conditions such as calibration requirements for monitoring devices.
HAZARDOUS WASTE MANAGEMENT
The State of Texas has been granted authority by EPA to implement the state’s hazardous waste program. The TCEQ administers the hazardous waste management program for the State of Texas. The regulations for the State of Texas hazardous waste management program incorporate by reference, hazardous waste management regulations of the federal program, included in 40 CFR Parts 260 to 266, 268, 270, 273 and Subpart A and B of 124.
Agency Applicable Regulation Key Points
TCEQ 30 TAC, Chapter 335, Hazardous Waste Establishes standards for large, small and conditionally exempt generators of hazardous waste. Provisions of the chapter include accumulation times, container and tank management standards, and record keeping requirements.
TCEQ 30 TAC, Chapter 335
Polychlorinated Biphenyls (PCBs)		 Establishes requirements for the storage, treatment, disposal and marking prior to disposal of PCB and PCB items. Also includes reporting and record keeping requirements. Incorporates by reference, PCB management regulations of the federal program, included in 40 CFR Part 761 as of July 1, 1989 and amendments to 40 CFR Part 761 in 54 FR 52716 of December 21, 1989.
TCEQ Texas Health and Safety Code, Chapter 371, Subchapter A
Management of used oil		 Provides used oil management standards for generators and transporters of used oil, and those burning used oil for energy recovery. Covers mixtures and residues of used oil and other wastes. Used oil includes, but is not limited to, used motor oil, gear oil, greases, machine cutting and coolant oils, hydraulic fluids, brake fluids, electrical insulation oils, heat transfer oils and refrigeration oils. Used oil does not include used oil mixed with hazardous waste. Used oil must be stored following applicable state and local Fire Marshal regulations, and containers and tanks used to store used oil shall be closed, covered or located under cover to prevent rainwater from coming in contact with the used oil.
TCEQ 30 TAC, Chapter 335.41, Subpart H, Division 5. Standard for Universal Waste Management Establishes universal waste management standards for handlers, transporters and destination facilities. Universal waste is listed in 40 CFR 273.1 and TAC, Title 31, Chapter 335; and subject to the universal waste requirements of 40 CFR Part 273. The State of Texas has adopted the federal regulations for universal waste.
TCEQ 30 TAC, Chapter 327
Regulations Pertaining to Spill Prevention and Control of Petroleum Products		 Texas has adopted EPA Oil Pollution Prevention Section (40CFR Part 112) regarding the aggregate storage of 1,320 gallons or single container capacity in excess of 600 gallons. For these cases the facility must develop a SPCC Plan. Chapter 327 includes reportable quantities of petroleum products. For example, the reportable quantity of petroleum products on to land is 25 gallons.
TCEQ 30 TAC, Chapter 335, Subchapter Q. Pollution Prevention: Source Reduction and Waste Minimization Subchapter Q requires large and small quantity generators of hazardous waste to develop a 5-year waste minimization plan that is updated annually or as needed. For small quantity generators, the plan must include a description of the facility, a list of all hazardous wastes generated and the volume of each, a list of all reportable TRI releases and volume of each, a prioritized list of pollutants and contaminants to be reduced, a statement of reduction goals, information on environmental and human health risks, implementation milestones for individual project development, an implementation schedule for future goal, a certification signature by the owner/operator/manager.
2.3 DETERMINING OBJECTIVES AND TARGETS
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)

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 (ISO 14001)

Purpose

The purpose of this procedure is to establish objectives and targets for all or some of the R6 Lab SEAs. These objectives and targets form the basis for continuous improvement process, and are supported by the Environmental Management Program established for each objective and target.

Procedure

The SEA Teams construct objectives and targets for each SEA. 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 specific performance data, and the opinions of the others as to where the greatest environmental performance improvements can be made. Consideration is also given to the R6 Lab 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 Teams construct an estimate of the resources needed to achieve the targets and the dates to meet the objectives. The objectives, targets, resource estimates, and estimated completion dates are presented to the R6 Lab Management for decisions regarding which targets to implement. The Management 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 Teams are 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 R6 Lab uses volunteer workgroups and existing workgroups (e.g., Waste Management Team and Chemical Management Team) in many instances to achieve targets.

In general, the outputs (e.g., strategies, proposals) from EMS Teams are submitted to R6 Lab Management for review. The EMS Teams present recommendations to the Management 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 an 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 their SEA, 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 R6 Lab 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.

  3. Each member of the EMS team shares the list within their department and collects additional ideas specific to that department.

  4. The EMS teams together compile a comprehensive list of objectives and targets for the R6 Lab (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 R6 Lab 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 a biannual 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.

Table of Objectives and Targets for R6 Lab EMS
Environmental Aspect Objective Target Current available resources
Proposed additional resources

Waste Management Promote & expand upon waste reduction/
recycling programs 		No deviation from CHP, SPCCP & OEP All personnel Checklist/Evaluation forms to track lab compliance
    100% Regulatory Compliance SHEM
once a year 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 current recycle Building janitors assists with recycling activities, recycle company gives amount.
Energy Conservation Reduce energy consumption Reduce as much as possible All personnel Building Engineer
    Promote awareness Region 6 Management  
Chemical Management Reduce use of chemical resources Combine as many runs as you can so you can reduce the amount of standards used. All lab personnel Inventory software.
    Innovative equipments, methods to reduce amount of chemical use. Same  
    Promote awareness

Same

  
Water Conservation Reduce water consumption Reduce water consumption All personnel Encourage Building Engineer to:
1) utilize faucet restrictors, low flush toilet systems
2) Xeri landscaping
3) Reduce sprinkler usage
    Promote awareness Region 6 Management  
Green Buying Affirmative procurements Obtain “Green” supply sources Minimal Nationalwide list of “Green” supplies.
2.4 ENVIRONMENTAL MANAGEMENT PROGRAMS (EMPs)

Definitions

Environmental Management Program: is an action plan, or series of action, prepared, implemented and tracked for achieving specific environmental objectives and targets.

Procedure

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. The completion date to meet the objectives is also included in the EMP. EMS Team Leads are responsible for maintaining their EMP documents.


  1. Specific EMPs are established for each environmental objective and target.

  2. EMPs are documented, and specifically identify:

    • Objective and target associated with the EMP

    • An indicator for tracking progress on achieving the EMP

    • A time schedule

    • Identification of specific actions or an action plan to achieve the EMP

    • Identification of resources and individuals and/or teams

  3. EMPs should be reviewed and possibly modified whenever the following occur:

    • Houston Lab activities, products, or services are changed (i.e., installation of new equipment or implementation of a new program)

    • Environmental objectives and targets are modified or added

    • Relevant legal or other requirements are changed or introduced (e.g., new Executive Order requirements)

    • 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.

The R6 Lab employees are encouraged to suggest and contribute to the 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 Management approve all EMPs.

The EMS Team Leads and Coordinator are responsible for tracking progress on all EMPs.

2.5 OPERATIONAL CONTROLS (OCs)
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 measuring equipment or instruments used to maintain operations within a specified operating range.

Purpose

An OC is a procedure to control activities, products, or services associated with each EMP. In addition, metrics measurement is also a vital part of an operational control in order to obtain the targets of an EMP.

Procedure

There following steps describe the approach used to develop operational controls for R6 Lab:

  1. The EMS Team reviews the objective and target related metrics that may require operational controls. The need for operational controls is assessed with the following objectives in mind:

    • Avoiding activities that could have a negative impacts on the metrics;

    • Preventing R6 Lab from achieving its objectives and targets; and

    • Preventing any deviations from the R6 Lab environmental policy.
  2. The EMS Team chooses their team members, equipments and/or methods for control and measurement of the metrics.

  3. The EMS Team recognizes that many practices, procedures, guidance, etc that have impacts on their objectives and targets.
  4. The EMS Team communicates to all R6 Lab employees (and contractors and suppliers) whose activities are related to the objectives and targets.

  5. Reports, metrics associated with each operational controls must be kept and accessible to relevant employees.

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