SANDIA REPORT

SAND20009-2665 Unclassified Unlimited Release Printed April 2009 Supersedes SAND 2008-2306 Dated April 2008

Sandia National Laboratories, California Environmental Management System Program Manual

Prepared by Environmental Management Department Sandia National Laboratories Livermore, California 94550 Sandia is a multiprogram laboratory operated by Sandia Corporation, a Lockheed Martin Company, for the United States Department of Energys National Nuclear Security Administration under Contract DE-AC04-94AL85000. Pending approval for public release; further dissemination unlimited.

EMS Program Manual April 2009

Issued by Sandia National Laboratories, operated for the United States Department of Energy by Sandia Corporation. NOTICE: This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government, nor any agency thereof, nor any of their employees, nor any of their contractors, subcontractors, or their employees, make any warranty, express or implied, or assume any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represent that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government, any agency thereof, or any of their contractors or subcontractors. The views and opinions expressed herein do not necessarily state or reflect those of the United States Government, any agency thereof, or any of their contractors. Printed in the United States of America. This report has been reproduced directly from the best available copy. Available to DOE and DOE contractors from U.S. Department of Energy Office of Scientific and Technical Information P.O. Box 62 Oak Ridge, TN 37831 Telephone: Facsimile: E-Mail: Online ordering: (865) 576-8401 (865) 576-5728 [email protected] http://www.doe.gov/bridge

Available to the public from U.S. Department of Commerce National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 Telephone: Facsimile: E-Mail: Online order: (800) 553-6847 (703) 605-6900 [email protected] http://www.ntis.gov/ordering.htm

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SAND2009-2665 Unclassified Unlimited Release Printed April 2009

Supersedes SAND 2008-2306 Dated April 2008

Sandia National Laboratories, California Environmental Management System Program Manual

Environmental Management Department Sandia National Laboratories, California 7011 East Avenue Livermore, CA 94550

Abstract The Sandia National Laboratories, California (SNL/CA) Environmental Management System (EMS) Program Manual documents the elements of the site EMS Program. The SNL/CA EMS Program conforms to the International Standard on Environmental Management Systems, ISO 14001:2004and Department of Energy (DOE) Order 450.1.

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Contents
Summary of Document Changes ............................................................................................................... 7 Acronyms and Abbreviations .................................................................................................................... 8 1 Program Introduction ........................................................................................................................ 9 1.1 2 3 Integration with Corporate EMS Standards................................................................................. 9 1.2 SNL/CA EMS Program Mechanics ........................................................................................... 10 SNL/CA Environmental Policies..................................................................................................... 14 Structure, Responsibilities, and Authorities .................................................................................. 16 3.1 3.2 Management Structure............................................................................................................... 16 Key Responsibilities .................................................................................................................. 16

3.3 Authorities ................................................................................................................................. 16 4 Environmental Aspects .................................................................................................................... 21 5 4.1 Significant Environmental Aspects ........................................................................................... 22 Quality Assurance and Risk Management ..................................................................................... 23 5.1 5.2 5.3 6 Identifying and Managing Risk to Environmental Management Personnel .............................. 24 Identifying and Managing Environmental Program Risk .......................................................... 24 Identifying and Managing Risk Associated with Environmental Aspects ................................ 24

5.4 Quality Assurance Program Plan ............................................................................................... 25 Objectives and Targets .................................................................................................................... 29 6.1 Defining Objectives ................................................................................................................... 30 6.2 Defining Targets and Assigning Actions................................................................................... 31 Emergency Preparedness and Response ........................................................................................ 39 Environmental Programs ................................................................................................................ 40 8.1 8.2 8.3 8.4 8.5 Air Quality ................................................................................................................................. 40 Environmental Monitoring ........................................................................................................ 41 Environmental Planning and Ecology ....................................................................................... 41 Hazardous Materials Management ............................................................................................ 41 Pollution Prevention and Waste Minimization .......................................................................... 42

7 8

8.6 Waste Management ................................................................................................................... 42 Legal and Other Requirements ....................................................................................................... 43 9.1 9.2 Current Requirements ................................................................................................................ 43 Monitoring Requirements .......................................................................................................... 46

10

9.3 Recent Modifications to Requirements ..................................................................................... 47 Operational Control ......................................................................................................................... 49 10.1 Corporate Controls .................................................................................................................... 49 10.2 Local Controls ........................................................................................................................... 49 Document Control ............................................................................................................................ 54

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11.1 11.2

Corporate Documents ................................................................................................................ 54 Technical Work Documents ...................................................................................................... 54

11.3 Environmental Program Documents ......................................................................................... 55 12 Competence, Training, and Awareness .......................................................................................... 56 12.1 13 14 Sandia-directed Operations........................................................................................................ 56 12.2 Contractor-directed Operations ................................................................................................. 58 Environmental Monitoring and Measurement .............................................................................. 59 13.1 EMS Metrics .............................................................................................................................. 60 Evaluating Compliance with Environmental Requirements ........................................................ 61 14.1 15 IDT Process ............................................................................................................................... 61 14.2 Self-assessments and Audits ...................................................................................................... 61 EMS Internal Audit and Self-Assessment ...................................................................................... 63 15.1 16 Internal EMS Audits .................................................................................................................. 64 15.2 EMS Program Self-Assessments ............................................................................................... 64 Nonconformity, Corrective, and Preventive Action ...................................................................... 66 16.1 16.2 17 18 19 20 Audit and Assessment Tracking ................................................................................................ 66 Corrective and Preventive Action.............................................................................................. 66

16.3 Validating Effectiveness of Actions .......................................................................................... 67 Management Review ........................................................................................................................ 68 EMS Documentation ........................................................................................................................ 69 Records .............................................................................................................................................. 71 Communications ............................................................................................................................... 72 20.1 Internal Communications .......................................................................................................... 72

20.2 External Communications ......................................................................................................... 72 Appendix A - EMS Targets for 2009 ....................................................................................................... 75 Appendix B - Environmental Program Reports .................................................................................... 80 Appendix C - ES&H Quality Assurance ................................................................................................. 81 Appendix D - SNL/CA Communication Plan Supplement ................................................................. 105 References ................................................................................................................................................ 111

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Tables
Table 1 Summary of Changes to EMS Program Manual, April 2009 .......................................................... 7 Table 2 SNL/CA EMS Key Personnel, 2009 .............................................................................................. 17 Table 3 SNL/CA Environmental Aspects ................................................................................................... 21 Table 4 SNL/CA Environmental Aspects ................................................................................................... 22 Table 5 Change in Significant Environmental Aspects Between 2008 and 2009 ....................................... 22 Table 6 SNL/CA EMS Objectives .............................................................................................................. 30 Table 7 Primary Environmental Requirements Associated with Environmental Aspects .......................... 43 Table 8 New and Modified Environmental Requirements, 2008/2009 ...................................................... 47 Table 9 Environmental Permits and Compliance Documents, 2009 .......................................................... 52 Table 10 EMS Monitoring Activities.......................................................................................................... 59 Table 11 List of EMS Metrics .................................................................................................................... 60 Table 12 SNL/CA Environmental Assessment and Audit Types ............................................................... 62

Figures
Figure 1 EMS Program Cycle ..................................................................................................................... 11 Figure 2 Annual EMS Calendar, 2009 ........................................................................................................ 12 Figure 3 SNL/CA EMS Management Structure ......................................................................................... 17 Figure 4 SNL/CA EMS Authorities and Responsibilities........................................................................... 18 Figure 5 Environmental Management Department QA Process ................................................................. 23 Figure 6 Aspect Ranking Example - Normal Operations ........................................................................... 26 Figure 7 Aspect Ranking Example - Off-Normal Event ............................................................................. 26 Figure 8 Environmental Aspect Ranking Results, 2008 ............................................................................. 27 Figure 9 SNL/CA Aspect Ranking Summary ............................................................................................. 28 Figure 10 Cycle of Setting and Evaluating EMS Objectives and Targets .................................................. 29 Figure 11 Water Discharges Objectives, Targets, and Actions .................................................................. 32 Figure 12 Air Emissions Objectives, Targets, and Actions ........................................................................ 34 Figure 13 Land Use Objectives, Targets, and Actions................................................................................ 35 Figure 14 General Transportation Objectives, Targets, and Actions .......................................................... 37 Figure 15 Hazardous Waste Objectives and Actions .................................................................................. 38 Figure 16 SNC/CA ES&H Review Process ................................................................................................ 51 Figure 17 Assessments Supporting SNL/CAs EMS Program ................................................................... 63 Figure 18 EMS Documentation .................................................................................................................. 70 Figure 19 EMS Communications Calendar, 2009 ...................................................................................... 73 Figure 20 External Communication Decision Memo ................................................................................. 74

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Summary of Document Changes

Significant changes made to the April 2009 edition of the EMS Program Manual are marked with a sidebar within the document and summarized in Table 1.
Table 1 Summary of Changes to EMS Program Manual, April 2009 Section Page Change Updated references and summary of information throughout document to reflect change in Various Corporate Business Rules System to new Corporate Policy System 1.1 9 Updated to reflect changes in DOE Order 450.1A. Added statement that EMS Manual information represents a point in time, with most up to 1.2 10 date information provided on the department website. 3.3 18 Replaced Authorities and Responsibilities letter with updated version. 4.0 21 Updated the significant aspects for 2009. 4.1 22 Updated Table 4 with new ranking scores for 2009 4.1 22 Updated Table 5 with new significant aspects. 6.2 32 - 39 Replaced Fast Track action sheets for significant aspects. 10.1 49 Updated and added footnote about upcoming changes in CBR system. 10.2.1 50 Added footnote about upcoming changes to work planning and control process. 10.2.3 53 Added Army Corp permit for Arroyo Improvements to Table 10 10.2.4 54 Added text about new environmental specifications and environmental permit. 11.2 55 Updated status of obsolete document control issues. 12.1.1 57 Added Work Authorization Form to training section 12.1.3 58 Added information about ES&H Visitor briefing card to visitor awareness section 15.1.1 65 Updated 2008 audit information 15.2.1 65 Updated 2008 assessment information Updated audit and assessment tracking with new information from updated assessment 16.1 67 procedure 16.2 67 Updated corrective and preventive action process to match procedure. 16.3 68 Updated validation process to match procedure. 17 69 Updated with results of 2008 management reviews. 19 72 Added Web File Share electronic records option 20 74 Updated communications calendar

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Acronyms and Abbreviations

BAAQMD CARB CBR System CEDT System CFR CPR CPS CPSR CWRCB DOE EMS EP Rep EPCRA ES&H IDT ISMS ISO M&O Contract MSDS NEPA PHS QA QAPP RCRA SHEAC SME SNL SNL/CA SNL/NM USC Bay Area Air Quality Management District California Air Resources Board Corporate Business Rules System Corporate Education, Development, and Training System Code of Federal Regulations corporate process requirement corporate policy statement corporate policy statement requirement California Water Resources Control Board Department of Energy Environmental Management System Environmental Programs Representative Emergency Planning and Community Right to Know Act environment, safety, and health Interdisciplinary Team Integrated Safety Management System International Organization for Standardization management and operating contract material safety data sheet National Environmental Policy Act primary hazard screening quality assurance Quality Assurance Program Plan Resource Conservation and Recovery Act Safety, Health & Environment Action Committee subject matter expert Sandia National Laboratories Sandia National Laboratories, California Sandia National Laboratories, New Mexico United States Code

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1 Program Introduction
Sandia National Laboratories, California (SNL/CA) has maintained functional environmental programs to assist with regulatory compliance for more than 30 years. During 2005, these existing programs were rolled into a formal environmental management system (EMS) that expands beyond the traditional compliance focus to managing and improving environmental performance and stewardship practices for all site activities. An EMS is a set of inter-related elements that represent a continuing cycle of planning, implementing, evaluating, and improving processes and actions undertaken to achieve environmental policy and goals. The SNL/CA EMS Program conforms to the International Standard for Environmental Management Systems, ISO 14001:2004 (ISO 2004). The site received ISO 14001 certification in September 2006. SNL/CAs EMS Program is applicable to the Sandia, Livermore site only. Although SNL/CA operates as one organizational division of the overall Sandia National Laboratories, the EMS Program is site-specific, with site-specific objectives and targets. SNL/CA (Division 8000) benefits from the organizational structure as it provides corporate level policies, procedures, and standards, and established processes that connect to and support elements of the SNL/CA EMS Program. Additionally, SNL/CAs EMS Program benefits from two corporate functional programs (Facilities Energy Management and Fleet Services Environmental programs) that maintain responsibility for energy management and fleet services for all Sandia locations. Each EMS element is further enhanced with site-specific processes and standards. Division 8000 has several groups operating at Sandia National Laboratories, New Mexico (SNL/NM). Although these groups, from an organizational perspective, are part of Division 8000, they are managed locally and fall under the environmental requirements specific to their New Mexico location. The New Mexico groups in Division 8000 follow the corporate EMS Program for New Mexico operations.

1.1 Integration with Corporate EMS Standards

On June 4, 2008, the Department of Energy (DOE) issued a revised DOE Order 450.1A, Environmental Protection Program. Order 450.1A outlines the basic strategy for environmental compliance at DOE facilities. It became effective for all Sandia National Laboratories (SNL) facilities on September 3, 2008 through incorporation into the Sandia management and operating contract. The objectives of Order 450.1A are to implement sound environmental stewardship practices, and to meet or exceed compliance with environmental, public health, and resource protection laws, regulations, and DOE requirements (DOE 2008). The order requires DOE sites to meet these objectives through an environmental management system (EMS) that follows the ISO 14001 framework (DOE 2008). To meet this new requirement, Sandias corporate EMS program has been modified to the ISO standard and is scheduled for a certification audit in June 2009.

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Under the corporate EMS umbrella, each SNL Division implements an EMS program tailored to the characteristics and operations of that division. Because the SNL/CA EMS Program conforms to the ISO 14001 Standard, it already meets the requirements of DOE Order 450.1A as well as the updated corporate program.

1.2 SNL/CA EMS Program Mechanics

SNL/CA prepared the Sandia National Laboratories, California Environmental Management System Program Manual (EMS Manual) to document and provide a roadmap to its EMS Program. Annually, the SNL/CA EMS Core Team updates the EMS Manual to document the aspects/impacts of current operations, the goals and objectives that respond to these impacts and the EMS changes and improvements that occurred during the year. The EMS Manual represents a point in time. Updated information about the EMS program is added to the Environmental Management Department website. Consequently, the most up-to-date information is typically found on Sandias website. The SNL/CA EMS Program encompasses an annual cycle of planning, implementing, assessing, and improving operations in support of site-specific environmental goals. The EMS Program cycle is presented in Figure 1. As shown, the EMS cycle aligns with the budget cycle so that investment and resource requirements can be requested for the next budget year. To provide further detail of the timing of EMS actions throughout the year, an annual EMS calendar is maintained and included as Figure 2.

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Assess / audit EMS Program Identify improvements Semi-annual management review Semi-annual ISO surveillance audit Establish new FY action items Review / update objectives / targets Advisory committee review Ongoing EMS implementation
Oct Nov

Complete annual environmental aspect risk assessment Review and update Program risk assessments
Dec Jan Feb

Update Program reports Advisory committee review Semi-annual management review Identify improvements Update EMS Program Manual Semi-annual ISO surveillance audit Prepare investment requests Budget submittal

Mar

Annual Calendar
Sep Apr

Aug Jul Jun

May

Receive budget approvals

Budget Cycle

Figure 1 EMS Program Cycle

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Figure 2 Annual EMS Calendar, 2009

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2 SNL/CA Environmental Policies

SNL/CA follows corporate and site-specific environmental policies that are combined with broader environment, safety, and health (ES&H) requirements. The Sandia corporate policy (CPSR400.1) (SNL 2007a) is to protect and preserve the environment, and to ensure the safety and health of its Members of the Workforce by providing a place of employment that is free from recognized hazards that have the potential to cause physical harm to workers. Principles outlined in the corporate policy related SNL/CA ES&H Standard of Performance to environmental management include employee accountability for minimizing SNL/CA is firmly committed to meeting all corporate and regulatory ES&H policies and requirements that apply to its impact on the environment and the operations. The application of compliant ES&H principles and belief that environmental incidents are practices is considered a fundamental element of everyones work preventable and unacceptable. Sandias assignment. ES&H performance objectives also In this regard, SNL/CA commits to: include creating a work environment that strives for zero environmental Nurture a safety and health conscious work ethic and culture. We will all assume responsibility for creating and incidents and zero operations fines, maintaining a worksite, as well as performing our work, in a violations, or penalties. manner that respects and supports the safety and health of In addition, the SNL/CA Vice President re-issued a Division 8000 ES&H standard of performance statement in January 2007. The statement reinforces individual accountability, environmental stewardship, and regulatory compliance - the basic elements of the corporate ES&H policy (SNL 2007a). The statement stresses the need to move beyond compliance requirements to nurture a positive ES&H culture at all levels of the workforce.
every individual. SNL/CA believes that all accidents are preventable. We will all strive to create a workplace that is free of accidents and injuries. Be a responsible steward of the environmental resources in our care. We will integrate environmental risk assessment, planning and impact mitigation into every aspect of our work. SNL/CA programs, operations, processes, and facilities will be planned and managed such that they support environmental objectives and targets to minimize the creation of waste, pollution, and adverse impact on the public and the environment. SNL/CA will remain committed to an efficient and effective Environmental Management System as part of the laboratorys Integrated Safety Management System. Comply with all applicable laws, regulations and permits. Compliance with the letter and the spirit of ES&H laws and regulations is viewed as the minimum acceptable standard. When necessary and appropriate we will go beyond legal mandates in order to implement more effective approaches and to nurture a positive and learning ES&H culture. SNL/CA is committed to continual improvement in all aspects of our environment, safety, and health performance and commits to establish performance indicators to guide these efforts and measure our progress.

Annually, the SNL/CA EMS Core Team reviews the ES&H standard of performance statement to ensure that it remains aligned with the site vision and the corporate ES&H policy. This review is executed as part of the internal EMS program audit. If needed, the EMS team presents recommendations for revisions to site management during the management review process described in Chapter 17.

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The Standard of Performance Statement resides on the SNL/CA ES&H website at http://surf.ran.sandia.gov/centers/8500/esh/CA-EnvMgmt/policy and the Sandia external website at http://public.ca.sandia.gov/casite/about/community/environmental_mgt.php. It was also made into posters and distributed to the site management team for display in their respective organizations (at their discretion).

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3 Structure, Responsibilities, and Authorities

3.1 Management Structure
The management structure for SNL/CAs EMS Program is depicted in Figure 3. As shown, the EMS Program is implemented through the Environmental Management Department under the Site Operations Center. Site Operations is one of six centers at SNL/CA reporting to the SNL/CA (Division 8000) Vice President. The site Vice President oversees the Safety, Health, & Environment Action Committee (SHEAC) comprised of the site vice president and center directors. SHEAC provides leadership and strategic management oversight of ES&H for Division 8000, and validates and approves the site EMS Program. The SNL/CA EMS Core Team manages day-to-day implementation and maintenance of the EMS Program. An advisory committee consisting of representatives from various functional areas also supports the EMS Program.

3.2 Key Responsibilities

SNL/CA personnel with key responsibility for the EMS Program include the site Vice President, the Director of Site Operations, the Level II Manager for ES&H, Facilities, and Security, the Manager for the Environmental Management Department, and the environmental functional program leads. The site Vice President holds overall responsibility for the success of the SNL/CA EMS Program and establishes the ES&H standard of performance for all site operations. The Director, Level II Manager, and Department Manager are responsible for providing the appropriate resources to implement and maintain the EMS, functional programs, and site infrastructure to support EMS objectives and targets. The Department Manager also serves as the designated management representative for the EMS. The functional program leads are responsible for day-to-day management of EMS elements and for assisting the site workforce in meeting established objectives and targets. The Environmental Programs Representative serves as an environmental liaison to the workforce. SNL/CA personnel assigned to each job function are listed in Table 2.

3.3 Authorities
EMS authorities at SNL/CA are defined in an internal memorandum issued by the Division 8000 Vice President on November 13, 2008. Authorities are defined for all levels of the workforce from the site VP, directors, and managers, to the basic worker. A copy of the authorities memorandum is provided in Figure 4.

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Figure 3 SNL/CA EMS Management Structure Table 2 SNL/CA EMS Key Personnel, 2009 Job Function or Title

Vice President, SNL/CA (Division 8000) Director, Site Operations Level II Manager, ES&H, Facilities, and Security Department Manager, Environmental Management Designated Management Representative Environmental Programs Representative Functional Program Leads: Air Quality Environmental Monitoring and Restoration Environmental Planning and Ecology Hazardous Materials Management Pollution Prevention and Waste Minimization Waste Management

Name Paul Hommert (through June 09) Rick Stulen (after June 09) Pat Smith Ed Cull Gary Shamber Gary Shamber Deanna Dicker Leslee Gardizi Robert Holland Barbara Larsen Mark Brynildson Janet Harris / Laurie Farren Mark Brynildson

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Figure 4 SNL/CA EMS Authorities and Responsibilities

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4 Environmental Aspects
An environmental aspect is an element of an organizations activities, products, or services that can interact with the environment. Simply put, an environmental aspect is a pathway for an environmental impact, either beneficial or adverse. For 2009, the EMS Core Team reviewed the previous environmental aspects identified for SNL/CA to reaffirm their applicability to current operations. One aspect, universal waste, a subset of hazardous waste, was combined with the hazardous waste aspect. All others were reaffirmed as applicable to current operations. SNL/CAs environmental aspects are presented in Table 3 along with the specific site activities that correspond to each aspect.
Table 3 SNL/CA Environmental Aspects Environmental Aspect Site activity office operations, medical operations, laboratory and test activities, facilities construction and deconstruction, exterior maintenance and operations, building maintenance and operations, general environmental Water discharges operations laboratory and test activities, facilities construction and deconstruction, exterior maintenance and operations, building maintenance and operations, Air emissions onsite receiving and transportation, offsite transportation general environmental operations, facilities construction and Land use deconstruction, exterior maintenance and operations office operations, medical operations, laboratory and test activities, facilities construction and deconstruction, exterior maintenance and operations, building maintenance and operations, general environmental Material procurement and use operations medical operations, laboratory and test activities, facilities construction and deconstruction, exterior maintenance and operations, building maintenance Hazardous materials and operations, security operations onsite receiving and transportation, offsite transportation, security General transportation operations Radioactive and mixed waste laboratory and test activities medical operations, laboratory and test activities, facilities construction and deconstruction, exterior maintenance and operations, building maintenance Hazardous waste and operations, security operations, office operations Biological agents laboratory and test activities Radiological materials laboratory and test activities Contaminated sites general environmental operations office operations, medical operations, laboratory and test activities, facilities construction and deconstruction, building maintenance and Solid waste (non-hazardous) operations, security operations, onsite receiving and transportation facilities construction and deconstruction, exterior maintenance and Legacy asbestos operations, building maintenance and operations Natural gas use office operations, medical operations, laboratory and test activities office operations, medical operations, laboratory and test activities, exterior maintenance and operations, facilities construction and deconstruction, Water use building maintenance and operations

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Hazardous material transportation Electricity use Fire Earthquake

onsite receiving and transportation, offsite transportation office operations, medical operations, laboratory and test activities emergency event emergency event

4.1 Significant Environmental Aspects

Significant environmental aspects for SNL/CA were identified through the risk ranking process described in Section 5.3. The sites significant aspects are those with the highest risk score under normal operations: water discharges, air emissions, land use, general transportation, and hazardous waste. Table 4 provides the complete list of SNL/CA aspects for 2009 along with the ranking score from the risk assessment process for both normal operations and off-normal events. Significant environmental aspects are highlighted in bold. The risk ranking for offnormal events is also shown in Table 4. Although only one of the highest ranked aspects in offnormal situations (highlighted in italics) is categorized as a significant aspect, all of these offnormal high risks are addressed during the establishment of action items. Table 5 shows the changes in SNL/CAs significant environmental aspects between 2008 and 2009.
Table 4 SNL/CA Environmental Aspects Aspect Ranking Scorea
Normal OffNormal

Aspect

Ranking Scorea
Normal OffNormal

Water discharges Air emissions Land use General transportation Hazardous waste Hazardous materials Material procurement and use Radioactive materials Solid waste (non-hazardous) Contaminated sites
a

12.6 12 11 11 9.6 7 6.3 6 5.5 5.5

20 8 15 1 45 13 1 24 10 0

Water use Radioactive and mixed waste Biological agents Natural gas use Electricity use Legacy asbestos Hazardous material transportation EMERGENCY ASPECTS Fire Earthquake

5.4 5 5 5 5 4 3.6 0 0

18 42 52 21 11 34 44 22 26

See Section 5.3 for description of methodology used to rank environmental aspects.

Table 5 Change in Significant Environmental Aspects Between 2008 and 2009 2008 Significant Aspects 2009 Significant Aspects Water discharges Water discharges Air emissions Air emissions Land use Land use Material procurement and use General transportation Universal waste Hazardous waste Hazardous materials

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5 Quality Assurance and Risk Management

The Sandia Corporate Quality Assurance (QA) Program, defined in CG 100.5 (SNL 2009b) is implemented in California through the Sandia National Laboratories Division 8000 QA Program. The Division 8000 QA Program establishes the quality management system for planning work, evaluating work, implementing controls, performing work, and improving processes. The Division QA Program directs all SNL/CA departments to evaluate the hazards associated with their activities using the ISMS primary hazard screening (PHS) software tool. It also requires each department to perform activity or program risk assessments in order to determine the formality that must be used in managing these department activities or programs. Additionally, SNL/CAs Environmental Management Department completed a third quality-related evaluation, a risk ranking of EMS aspects to assist the department in focusing EMS Program efforts and resources on those aspects that represent the greatest risks to the site. Figure 5 shows the quality assurance process for the Environmental Management Department.

Figure 5 Environmental Management Department QA Process

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5.1 Identifying and Managing Risk to Environmental Management Personnel

The execution of each of the six EMS environmental programs introduces personal risks to the staff performing the various actions of these programs. SNL/CA uses the corporate PHS software tool as the first step in managing risk to environmental management personnel. The PHS assists action owners in identifying hazards using a detailed set of questions about all aspects of environment, safety, and health. The PHS software generates a hazard evaluation based on the answers provided, and identifies training requirements and safety controls needed to protect the workforce. Each functional environmental program maintains a program-specific PHS to manage the safety risks associated with program activities.

5.2 Identifying and Managing Environmental Program Risk

The Environmental Management Department completed a formality determination to identify and manage risk associated with each SNL/CA environmental program. The formality determination is required and outlined in the Division QA Program. In general, a formality determination is made by conducting a risk assessment to identify the risk category of a particular activity, or in this case, program. Under the Division QA Program, programs that fall within the high-risk category require work-specific quality assurance plans. Programs that fall within the medium risk category require supplemental controls as outlined in one of four quality management guides. The formality determination for the Environmental Management Department was completed by assessing the unique program risks associated with each of the six environmental programs. These assessments followed the Division 8000 process, which is a modified version of the corporate process. The results of the assessments show that risks associated with environmental programs fall within the low and medium risk categories. Department activities fall within the Exemplary Operations guide and the use of quality best practices as supplemental controls. Although not required, the Environmental Management Department prepared a departmentspecific quality assurance plan as its quality best practice supplemental control.

5.3 Identifying and Managing Risk Associated with Environmental Aspects

Annually, the EMS Core Team ranks the environmental aspects identified through the EMS Program to evaluate the risks of SNL/CA operations. Environmental aspects are ranked first under normal operating conditions using a modified risk assessment process that accounts for existing controls, compliance programs, and EMS improvements made during the previous year. Each aspect is evaluated against nine exposure pathways and rated on an impact scale from zero to 3 (negligible to high consequence). The resulting risk score is then adjusted (either up or down) to account for changes that occurred in the previous year in funding, resources, knowledge, or activity level gained or lost. Figure 6 shows the assessment matrix for one

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environmental aspect under normal operating conditions. A second assessment of each aspect is performed for a plausible off-normal event (determined by the core team and listed for each aspect) using a similar risk assessment process with the addition of a probability index of zero to 4 (zero to very high probability of an occurrence). Figure 7 shows the assessment matrix for an environmental aspect for an off-normal event. Ranking results are compiled and presented in Figure 8. Figure 9 graphically shows a summary of the ranking assessment for both normal operations and off-normal events. As shown, the highest risk aspects associated with normal operations are different from those identified for off-normal events. The results of the aspects risk analysis are used to validate the resources applied to the environmental program that manages those risks. The results are also used to help establish the set of actions for the year that are designed to:
Reduce the impacts of high-risk normal operations; Reduce the probability of high-risk off-normal events; Reduce the consequences of high-risk off-normal events should they occur.

5.4 Quality Assurance Program Plan

The Environmental Management Department QA Program Plan (QAPP), dated March 23, 2006 documents the activities that are vital to assuring the quality of work performed by the department. It applies to all environmental programs within the department. Although not required by the formality determination, the QAPP was selected as the quality best practice to manage medium risk category activities and to ensure consistent application of quality practices for functional environmental programs as well as for the EMS Program. The QAPP addresses the ten QA criteria of an effective quality program identified by DOE.

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Figure 6 Aspect Ranking Example - Normal Operations

Figure 7 Aspect Ranking Example - Off-Normal Event

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Figure 8 Environmental Aspect Ranking Results, 2008

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High Risk

Low Risk

Ranking Order of Aspects

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Figure 9 SNL/CA Aspect Ranking Summary

Wat arge s A ir E miss ions er D ishc

Risk Ranking of Environmental Aspects

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Aspect

La n d Us Ge n e eral Tran spor ta tio n Ha z ardo us W aste Ha z ardo u Ma t s Ma eria teria l Pro ls c ure men t an d Us R ad e ioa c tive Soli Ma t dW eri a aste ls (non -h az ard o us) C on tam i na t ed S i te s R ad W ate r ioa c Use tive an d Mi xe dW a ste B io l o gic al A ge n ts Na tu ral G as U se Elec trici ty U se Le g a c y Ha z A s ardo b es to s us M ater ial T ran s p ort Eart Fi re hq u ak e

Normal

Off-Normal

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6 Objectives and Targets

Setting objectives and targets, and establishing actions to help achieve these is a continuous cycle as shown in Figure 10. Objectives and targets provide a measure of environmental performance and the effectiveness of an EMS. SNL/CAs objectives support efforts to reduce potential environmental risk from site operations and enhance environmental stewardship. Our targets are detailed measurable performance requirements directly linked to site objectives. Each year, the EMS Core Team reviews EMS objectives and targets and evaluates the sites progress in meeting them. Targets are modified and new action items are established for the upcoming calendar year. As part of this review process, the Core Team identifies additional resources needed to implement current or future action items and submits an investment request through the budget cycle. The sites senior management team (VP and directors) are responsible for approving new EMS objectives and targets, and validating existing objectives and targets annually. The management team approved and validated the 2009 EMS objectives and targets on October 30, 2008.

Measure progress in meeting targets / objectives, New aspects needed?

Review corporate aspects

Re-validate aspects that apply to SNL/CA

Corporate Aspects
Establish

calendar year
action items

10 SNL/CA activity categories

Review SNL/CA operations and identify sitespecific aspects

Identify targets specific to activity categories

Complete risk assessment to identify high priority aspects

Identify goals and objectives for all aspects

Figure 10 Cycle of Setting and Evaluating EMS Objectives and Targets

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6.1 Defining Objectives

In 2006, the EMS Core Team established broad, multi-year objectives for environmental aspects applicable to SNL/CA activities. The inclusion of objectives for each aspect rather than only significant aspects serves as a best business practice by providing an expectation of overall environmental stewardship across the spectrum of activities conducted on site. An additional objective for general environmental operations was also established in 2006. Each EMS objective was formed around the concept that the sites negative environmental impacts cannot be eliminated, in most cases, but should be minimized to the extent practical. For example, site operations will continue to generate waste, use hazardous materials, etc, but these can be managed to reach a minimum level appropriate to the level of operations and mission of the site. SNL/CA EMS objectives are shown in Table 6. Objectives associated with significant environmental aspects are highlighted in green.
Table 6 SNL/CA EMS Objectives Environmental Aspect/Area Objective General Environmental Operations Provide exceptional environmental management for the SNL/CA site. Water Discharges Air Emissions Land Use General Transportation Hazardous Waste Hazardous Materials Material Procurement and Use Radiological Material Radioactive and Mixed Waste Biological Agents Contaminated Sites Legacy Asbestos Solid Waste (non-hazardous) Hazardous Material Transportation Natural Gas Use Water Use Electrical Use Fire Earthquake Minimize the volume and contamination of sewer water. Minimize the volume and pollution of storm water runoff. Minimize air emissions related to operations and transportation with particular emphasis on Spare-the-Air days. Enhance the natural habitat. Design and manage all buildings and facilities using green principles. Minimize the use of vehicles by members of the workforce. Minimize the generation of hazardous waste. Minimize the use of hazardous materials. Procure and use environmentally friendly products and materials. Minimize the use of radiological materials. Minimize the generation of radioactive and mixed waste. Minimize the use of biological materials. Minimize the environmental impacts of site contaminated areas. Reduce site legacy asbestos material. Minimize the quantity of landfill waste through reduced consumption and/or reuse/recycling. Minimize the potential environmental effects of hazardous material due to transportation. Minimize site natural gas consumption. Minimize site water consumption. Minimize site electrical consumption. Minimize the environmental effects of a site fire emergency. Minimize the environmental effects of a site seismic event.

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6.2 Defining Targets and Assigning Actions

Annually, the EMS Core Team establishes new targets and updates existing targets to support site environmental objectives. At a minimum, targets (or actions) are established for significant environmental aspects. The Core Team identifies specific actions, timeframes, and personnel assignments needed to meet these targets. Completion of actions and progress towards meeting established targets is tracked using standard project management software (i.e., FastTrack Schedule). Project management schedules for significant environmental aspects are presented in figures 11 through 15. The EMS Core Team may also establish targets for environmental aspects that are not categorized as significant to support specific environmental program activities (e.g., activities that receive special funding, support corrective actions, or implement site initiatives). For example, in 2009, the Core Team established a target to increase the use of bio-based products by 25% by 2010, using 2008 as the baseline (aspect = material procurement and use; objective = procure and use environmentally friendly products and materials). Actions to support targets not associated with significant environmental aspects are incorporated into routine environmental program activities and tracked to completion by functional program leads. The complete list of targets for 2009 is provided in Appendix A.

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Figure 11 Water Discharges Objectives, Targets, and Actions

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Figure 11 Water Discharges Objectives, Targets, and Actions (continued)

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Figure 12 Air Emissions Objectives, Targets, and Actions

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Figure 13 Land Use Objectives, Targets, and Actions

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Figure 13 Land Use Objectives, Targets, and Actions (continued)

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Figure 14 General Transportation Objectives, Targets, and Actions

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Figure 15 Hazardous Waste Objectives and Actions

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7 Emergency Preparedness and Response

SNL/CA has an established Emergency Plan (SNL/CA 2008d) and procedures to provide an effective and timely response to emergency conditions. The sites Emergency Management Program was established in accordance with a separate DOE order, Order 151.1C, Comprehensive Emergency Management System (DOE 2005). SNL/CAs Emergency Plan establishes guidelines and procedures to mitigate the potential consequences of an operational emergency. The Emergency Management Program maintains implementing procedures for all assigned roles that support emergency events on site. SNL/CA conducts annual training exercises to validate elements of the Emergency Management Program. Routine training drills and communication tests are also completed. The Emergency Plan and Emergency Plan Implementing Procedures are available to the site workforce on SNL/CAs web site at http://surf.ran.sandia.gov/centers/8500/security/em. Emergency response actions support our EMS Program by managing and mitigating the potential environmental risk from site operations. During site emergencies, members of the Environmental Management Department provide support with hazardous materials spill response and clean-up. Through these efforts, potential long-term environmental effects are avoided or minimized. The Chemical Inventory System, managed by the Hazardous Material Management Program, one of the six environmental programs, provides invaluable information in support of the Emergency Management Program.

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8 Environmental Programs
SNL/CA maintains an Environmental Management Department that manages six functional program areas supporting the site EMS Program. The program leads from each of these six programs are part of the EMS Core Team responsible for developing, implementing, and modifying the site EMS. Functional program areas are:
Air Quality Environmental Monitoring Environmental Planning and Ecology Hazardous Materials Management Pollution Prevention and Waste Minimization Waste Management

The program lead for each functional area prepares an annual report that provides detailed information about all aspects of program operations. The program reports are provided in Appendix B and include the following:
A detailed summary of program activities Program drivers Operational controls Documents produced Job descriptions, qualifications, and training Performance measures Quality assurance / program risk assessment Program assessments Accomplishments in the last 12 months Trends Goals and objectives (short-term)

8.1 Air Quality

The Air Quality Program provides compliance assistance for all nonradiological air emission sources at SNL/CA. Program staff review all directives, laws, and regulations relevant to air emissions for applicability to the site. This program manages the air permit process, from the initial steps of preparing permit applications through implementation of permit conditions and annual renewals. The Air Quality Program is responsible for evaluating proposed projects, assessing chemical use, and assessing emissions of all criteria pollutants and toxic air contaminants. The Air Quality Program assists the site in complying with the Clean Air Act, California Air Resources Board (CARB) regulations, and local Bay Area Air Quality Management District (BAAQMD) regulations.

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8.2 Environmental Monitoring

The Environmental Monitoring Program routinely monitors wastewater, storm water, and groundwater systems at SNL/CA to assess the effect of site operations on the public and local environment. Storm water is evaluated for general water quality, and for non-radiological and radiological constituents. Wastewater effluent resulting from site operations is monitored for non-radiological constituents. Liquid effluent control systems are operated and maintained by the program to capture wastewater from laboratory activities for analysis prior to release to the sanitary sewer. Groundwater is sampled and analyzed for non-radiological and radiological constituents to assess the extent of groundwater contamination from past operations. In addition, monitoring of external radiation at the site perimeter is conducted using thermo luminescent dosimeters. Comparisons are made of site data to offsite dose rates. The program also conducts project specific soil sampling to assess potential soil contamination from past or current operations and implements restoration activities, as needed. The Environmental Monitoring Program assists the site in complying with federal requirements (Clean Water Act, National Emission Standards for Hazardous Air Pollutants Rule for Radionuclides); state of California requirements (Porter-Cologne Water Quality Act); and state and local permits for storm water and wastewater discharges.

8.3 Environmental Planning and Ecology

The Environmental Planning and Ecology Program provides oversight for ecological resource management, site-wide National Environmental Policy Act (NEPA) review, and cultural and historic resource reviews. The program coordinates and oversees wildlife, vegetation, and historic building surveys; prepares routine environmental reports that cross over multiple program areas; and implements the NEPA process. The Environmental Planning and Ecology Program assists the site in complying with the Endangered Species Act; Migratory Bird Treaty Act; California Endangered Species Act; Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), as it applies to wildlife and habitat; National Historic Preservation Act; NEPA; DOE NEPA Implementing Procedures; DOE Order 231.1 Environment, Safety, and Health Reporting; and Executive Order 11990 Protection of Wetlands.

8.4 Hazardous Materials Management

The Hazardous Materials Management Program is responsible for tracking hazardous materials (chemical and biological), managing the Material Safety Data Sheets (MSDS) library, providing MSDS information to site personnel, and for regulatory compliance reporting required under various hazardous materials regulations. The program is also responsible for supporting hazardous material safety and information requirements site-wide. The Hazardous Materials Management Program assists the site in complying with the Emergency Planning and Community Right-to-Know Act and California Right-to-Know

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(EPCRA) regulations. The Hazard Communication/Lab Standard of the Occupational Safety and Health Administration is also key to program operations.

8.5 Pollution Prevention and Waste Minimization

The Pollution Prevention and Waste Minimization Program promotes the elimination or reduction of all types of wastes generated at SNL/CA. Program staff work closely with Facilities organizations to establish routine and project specific recycling programs. The program provides guidance for resource and energy conservation and assists in identifying recycled-content products for use throughout the site. Pollution Prevention and Waste Minimization also implements the universal waste program to ensure proper handling and disposal of low-hazard waste such as consumer electronics, mercury wastes, cathode ray tubes, and fluorescent tubes. The Pollution Prevention and Waste Minimization Program assists the site in complying with the Pollution Prevention Act; Resource Conservation and Recovery Act (RCRA), California Hazardous Waste Source Reduction and Management Review Act; and numerous executive and DOE orders. A complete list of orders is provided in the Pollution Prevention and Waste Minimization Program Annual Report (Appendix B).

8.6 Waste Management

The Waste Management Program manages hazardous, radioactive, and mixed wastes generated by SNL/CA operations. Program personnel collect waste from the point of generation and transfer it to either the Hazardous Waste Storage Facility or the Radioactive Waste Storage Facility for storage, consolidation, and packaging. The program establishes and maintains contracts for offsite treatment and disposal of wastes, manages the RCRA permit process and implements conditions of the permit, conducts process knowledge evaluations to characterize waste types generated from specific operations, and provides training to all SNL/CA waste generators. The Waste Management Program assists the site in complying with Federal requirements (RCRA, Toxic Substances Control Act, Federal Facilities Compliance Act, FIFRA); State of California requirements (Hazardous Waste Control Law, Medical Waste Management Act); DOE orders for radioactive waste management and packaging and transportation of waste; and the RCRA Part B Permit for SNL/CA.

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9 Legal and Other Requirements

SNL/CA is subject to many federal, state, and local environmental laws, regulations, and requirements. Sandia operations are also subject to DOE directives identified in Sandia Corporations contract with DOE for management and operation of Sandia National Laboratories. Sandia is committed to managing all activities in accordance with these policies, directives, and processes within the boundaries of the prime contract, applicable laws, DOE and corporate directives, and best management practices. As part of our mission, we strive to serve our customers by anticipating their needs, meeting their requirements, and exceeding their expectations (SNL 2008a). DOE and Sandia establish an annual performance evaluation plan that outlines the expectations for performance.

9.1 Current Requirements

Environmental requirements applicable to SNL/CA operations are detailed in annual program reports prepared for each environmental program area (Appendix B). Table 7 provides a list of primary environmental requirements that are applicable to each environmental aspect. In addition to the requirements listed in Table 8, DOE and Sandia establish a set of operational expectations each year. DOEs expectations of Sandia for 2009 can be found in the Fiscal Year 2009 Performance Evaluation Plan for Sandia Corporation in the Operation and Management of Sandia National Laboratories at https://rproxy.sandia.gov/my/authsec/portal/ilms/default/ customer/requirements/satisfaction/laboratoryPerformanceEvaluation. The 2009 Performance Evaluation Plan includes performance measures for environmental compliance.
Table 7 Primary Environmental Requirements Associated with Environmental Aspects
Environmental Aspect Environmental Requirement CPR 400.1.1 ES&H Manual and Supplements DOE Order 450.1, Environmental Protection Program 33 United States Code (USC) 1251, Clean Water Act 40 Code of Federal Regulations (CFR) 112, Oil Pollution Prevention 40 CFR 122 - 125, National Pollutant Discharge Elimination System 40 CFR 129 Toxic Pollutant Effluent Standards and Prohibitions 40 CFR 403 General Pretreatment Regulations for Existing and New Sources of Pollution 40 CFR 433 Metal Finishing Point Source Category Title 23 California Code of Regulations (CCR), Division 3 Title 17 CCR Public Health California Health and Safety Code (H&S Code), Division 20, Chapter 6.6, California Safe Drinking Water and Toxic Enforcement Act of 1986, Proposition 65

Water discharges (significant aspect)

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Environmental Aspect

Air emissions (significant aspect)

Land use (significant aspect)

General transportation (significant aspect)

Hazardous waste (significant aspect)

Environmental Requirement CPR 400.1.1 ES&H Manual and Supplements DOE Order 450.1, Environmental Protection Program Clean Air Act, 42 USC 7401 40 CFR 61, National Emissions Standards for Hazardous Air Pollutants, Subpart H California H&S Code, Division 26 California Clean Air Act California Air Resources Board Regulations Bay Area Air Quality Management District Regulations Executive Order (EO) 12843, Procurement Requirements and Policies for Federal Agencies for Ozone-Depleting Substances California H&S Code, Division 25.5 38500 et. seq. California Global Warming Solutions Act of 2006 CPR 400.1.1 ES&H Manual and Supplements DOE Order 450.1, Environmental Protection Program 42 USC 4321 et. seq., National Environmental Policy Act 16 USC 1531 et. seq., Endangered Species Act 16 USC 703 et. seq., Migratory Bird Treaty Act 33 USC 1251, Clean Water Act 7 USC 136, Federal Insecticide, Fungicide, and Rodenticide Act 10 CFR 1022 Compliance with Floodplain and Wetlands Environmental Review Requirements EO 11988 Floodplain Management EO 11990 Protection of Wetlands California Fish and Game Code 2050 2068, California Endangered Species Act California Fish and Game Code Biological and Conference Opinion for SNL/CA Operations DOE Order 4700.1 Project Management System DOE Order 413.3 Program and Project Management for the Acquisition of Capital Assets DOE Order 430.2B Departmental Energy, Renewable Energy, and Transportation Management EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management DOE Order 450.1, Environmental Protection Program Energy Policy Act of 2005 EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management CPR 400.1.1 ES&H Manual and Supplements GN470075 Guidelines for Waste Generators at SNL/CA DOE Order 450.1, Environmental Protection Program 42 USC 6901 et. seq., RCRA 42 USC 6961, Federal Facility Compliance Act 40 CFR 239 299, RCRA Implementing Regulations 29 CFR 1910.120, Hazard Communication Standard California H&S Code, Division 20, Chapter 6.5, California Hazardous Waste Control Law California H&S Code, Division 104, Part 14, 117600 -118360, California Medical Waste Management Act Title 22 CCR California Implementing Regulations for RCRA 42 USC 13101 et. seq., Pollution Prevention Act of 1990 EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management California Hazardous Waste Source Reduction and Management Review Act of 1989 California H&S Code, Division 20, Chapter 6.5, Hazardous Waste Control California H&S Code, Division 20, Chapter 6.5, Waste Minimization Certification 15 USC 2601 et. seq., Toxic Substances Control Act SNL/CA Hazardous Waste Facility Permit SNL/CA Part B Hazardous Waste Operation Plan

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Environmental Aspect

Hazardous materials

Material procurement and use

Radiological materials

Radioactive and mixed waste

Biological agents

Contaminated sites

Legacy asbestos

Environmental Requirement CPR 400.1.1 ES&H Manual and Supplements GN470094 Handling Chemicals at SNL/CA DOE Order 450.1, Environmental Protection Program 42 USC 11001 et. seq., Emergency Planning and Community Right-to-Know Act 29 CFR 1910.1200 Hazard Communication Standard 29 CFR 1910.1450 Lab Standard 40 CFR 68 Risk Management Plan EO 12856 Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements DOE Order 151.1C Emergency Management California H&S Code, Chapter 6.95, California Hazardous Materials Release Response Plans and Inventory Law EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management California H&S Code Division 20, Chapter 6.7, Underground Storage Tanks 42 USC 6901 et. seq. Resource Conservation and Recovery Act (RCRA) (related to underground storage tanks) 40 CFR 280 RCRA Implementing Regulations for Underground Storage Tanks 15 USC 2601 et. seq., Toxic Substances Control Act 7 USC 136, Federal Insecticide, Fungicide, and Rodenticide Act CPR 400.1.1 ES&H Manual and Supplements DOE Order 450.1, Environmental Protection Program DOE Order 413.3 Program and Project Management for the Acquisition of Capital Assets EO 12843, Procurement Requirements and Policies for Federal Agencies for Ozone-Depleting Substances EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management 42 USC 6901 et. seq., Resource Conservation and Recovery Act (RCRA) 42 USC 2011 et. seq., Atomic Energy Act CPR 400.1.1 ES&H Manual and Supplements MN471016 Radiological Protection Procedures Manual DOE Order 450.1, Environmental Protection Program DOE Order 5400.5, Radiation Protection of the Public and Environment DOE/EH-0173T, Environmental Regulatory Guide for Radiological Effluent Monitoring and Environmental Surveillance 10 CFR 835, Radiological Protection CPR 400.1.1 ES&H Manual and Supplements GN470075 Guidelines for Waste Generators at SNL/CA DOE Order 450.1, Environmental Protection Program 42 USC 2011 et. seq., Atomic Energy Act DOE Order 435.1 Radioactive Waste Management DOE Order 5400.5 Radiation Protection of the Public and the Environment 42 USC 6961, Federal Facility Compliance Act SNL/CA Hazardous Waste Facility Permit SNL/CA Part B Hazardous Waste Operation Plan California H&S Code, Division 20, Chapter 6.5, Hazardous Waste Control Law Nevada Test Site Waste Acceptance Criteria CPR 400.1.1 ES&H Manual and Supplements SNL/CA Biohazardous Waste Management Plan SNL/CA Medical Waste Management Plan CPR 400.1.1 ES&H Manual and Supplements DOE Order 450.1, Environmental Protection Program California Regional Water Quality Control Board, San Francisco Bay Region Waste Discharge Requirements CPR 400.1.1 ES&H Manual and Supplements DOE Order 450.1, Environmental Protection Program 40 CFR 61, National Emissions Standards for Hazardous Air Pollutants 15 USC 2601 et. seq., Toxic Substances Control Act

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Environmental Aspect

Solid waste (non-hazardous)

Hazardous material transportation

Natural gas use

Water use

Electricity use

Fire (emergency aspect) Earthquake (emergency aspect)

Environmental Requirement DOE Order 450.1, Environmental Protection Program 42 USC 13101 et. seq., Pollution Prevention Act of 1990 EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management California Public Resources Code 42961.5, Waste Tire Manifest Program California H&S Code Division 20, Chapter 6.5, 25211, Appliance Recycling Title 22 CCR Division 4.5, Chapter 16, Recyclable Materials Title 22 CCR, Division 4.5, Chapter 23, Universal Waste Management Title 22 CCR, 66273, California Electronic Waste Recycling Act California Public Resources Code 42490 42499, Cell Phone Recycling Act CPR 400.1.1 ES&H Manual and Supplements DOE Order 450.1, Environmental Protection Program DOE Order 460.1B Packaging and Transportation Safety 49 CFR - Transportation SNL/CA Transportation Safety Document SNL/CA Transportation Security Plan DOE Order 450.1, Environmental Protection Program Energy Policy Act of 2005 DOE Order 430.2B Departmental Energy, Renewable Energy, and Transportation Management EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management DOE Order 450.1, Environmental Protection Program DOE Order 430.2B Departmental Energy, Renewable Energy, and Transportation Management EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management DOE Order 450.1, Environmental Protection Program Energy Policy Act of 2005 DOE Order 430.2B Departmental Energy, Renewable Energy, and Transportation Management EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management CPR 400.1.1 ES&H Manual and Supplements DOE Order 151.1C Emergency Management CPR 400.1.1 ES&H Manual and Supplements DOE Order 151.1C Emergency Management

9.2 Monitoring Requirements

The process for monitoring ES&H requirements is identified in Administrative Procedure (AOP 04-02 (SNL 2007b). At the corporate level, Sandia monitors DOE directives, DOE Acquisition Regulation activity, Federal Register, and federal, state, and local government publications for regulatory changes and issues applicable to SNL operations. New requirements are communicated to the workforce through established internal mechanisms and incorporated into the Sandia ES&H Manual, a comprehensive document that guides the workforce through the compliance process (SNL 2009a). New requirements are then incorporated into facility- and operation-specific work planning and control documents. Environmental subject matter experts (SMEs) at SNL/CA monitor state and local issues to augment corporate monitoring. Subscriptions to electronic and paper publications and interactions with regulators are two primary ways that SNL/CAs SMEs stay current on environmental requirements. SNL/CA SMEs work directly with regulating agencies to obtain information on new and changing requirements well in advance of requirements becoming effective. Such advance notice allows the SNL/CA EMS Core Team to identify resources and implement effective and cost efficient processes for compliance. Environmental staff members

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attend conferences routinely and participate as members of environmental organizations that publish newsletters and discipline-specific informational materials. Environmental consultants that support Sandias staff also keep abreast of regulatory changes that may affect their clients. SMEs at both SNL/CA and SNL/NM interact regularly with their DOE counterparts and regulators. Through these customer and stakeholder interactions, some changes (i.e., executive orders and policies, applicable litigation results, best management practices, etc.) may be identified that are not incorporated into Sandias Management and Operating Contract (M&O Contract) as formal requirements. Although such changes are not necessarily contract requirements, where appropriate, they are incorporated into the EMS and implemented through functional environmental programs. However, because this process is informal, some changes that may be appropriate may not be captured.

9.3 Recent Modifications to Requirements

Table 8 summarizes information from the annual program reports pertaining to new and modified environmental requirements that were implemented in 2008/2009 or are pending.
Table 8 New and Modified Environmental Requirements, 2008/2009
Requirement Summary Update - DOE Order 450.1A, Environmental Protection Program Outlines the basic strategy for environmental compliance at DOE facilities DOE Order 430.2B Departmental Energy, renewable Energy and Transportation Management Requirements for efficient and effective management or energy, water, and vehicle fleets at DOE facilities Authorization from US Army Corp of Engineers for remaining tasks under the Arroyo Seco Improvement Program Tentative Order for updated Construction Activities General Permit for hydromodification project requirements, sampling requirements, effluent triggers / limits, notice of intent / storm water pollution prevention plan public review process Update Electronic Waste Recycling Act of 2003 to include electronic devices with screens less than 4 inches Effective Date Driver Program Modification Environmental Aspect

June 4, 2008

DOE Order 450.1A

Incorporated into EMS Program Objectives and targets for energy use, water use, and general transportation incorporated into EMS Program SNL/CA must initiate these tasks over next ten years

All Water use, general transportation, electricity use, natural gas use, land use,

February 27, 2008

DOE Order 430.2B

September 2008

Clean Water Act

Land use

Expected in 2009

Clean Water Act

SNL/CA will implement as outlined in the Tentative Order Incorporated into universal waste recycling program

Water discharges

June 2008

CCR Title 22, Div. 4.5, Chapter 11

Hazardous waste

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Requirement Summary

Effective Date

Driver

CARB regulation limits emissions from off-road diesel vehicles with engines equal to or greater than 25 hp

March 1, 2009

CCR Title 13, Section 2449

CARB regulation limits emissions from portable diesel equipment with engines equal to or greater than 50 hp.

January 1, 2010

CCR Title 17, Section 9316

CARB regulation limits emissions from on-road diesel trucks with GVWR greater than 14,000 pounds. CARB Large Spark Ignition Engine regulation limits emissions from gasoline forklifts. BAAQMD requires results of annual Leak Test on gasoline dispensing facility to be submitted to agency

January 31, 2010

CCR Title 13, Section 2025 CCR Title 13, Sections 2430, 2431, 2438, 2775 BAAQMD Regulation 8, Rule 7 and BAAQMD Permit condition

January 1, 2009

January 2008

BAAQMD regulation requires increase measures to control emissions from boilers rated between 2 MMBtu/hr and 10 MMBtu/hr/

January 1, 2009

BAAQMD Regulation 9, Rule 7

Program Modification SNL/CA must adopt idling policy by March 1, 2009, report inventory by April 1, 2009, and reduce emissions from offroad diesel vehicles starting March 1, 2010 SNL/CA must not purchase Tier 0 engines starting January 1, 2010 and must reduce emissions from existing engines starting January 1, 2013 SNL/CA must report inventory by January 31, 2010 and reduce emissions from onroad trucks starting January 1, 2011 SNL/CA must reduce emissions from forklifts starting January 1, 2011 SNL/CA must submit results of Leak Test within 20 days of test date SNL/CA must perform annual inspections/tune-ups starting 2009; install insulation by January 1, 2010; and meet stack temperature and emission requirements starting January 1, 2011

Environmental Aspect

Air emissions

Air emissions

Air emissions

Air emissions

Air emissions

Air emissions

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10 Operational Control
Sandia maintains a Corporate Policy System that reflects the requirements of its contract with DOE and is consistent with the intent of Lockheed Martin Corporate Policy (Sandias parent company). The Corporate Policy System governs all Sandia operations (SNL 2009f). It is part of Sandias Integrated Laboratory Management System, and managed by the Corporate Policy & Lab Performance Evaluation Department. Operational controls for the site are further enhanced with division and project-specific technical work documents.

10.1 Corporate Controls

The Corporate Policy System contains nine policy areas and three levels within each area. The nine policy areas include corporate governance, ES&H, facilities, finance, human resources management, information management, integrated safeguards and security, mission execution, and supply chain management. The policy system levels are: Level 1 Corporate Policies; Level 2 Corporate Processes; and Level 3 Corporate Procedures. All policies, processes, and procedures require review at least every three years. The Corporate Policy System was rolled-out in April 2009 and replaces the Corporate Business Rules System. The ES&H Policy Area is available through the corporate system but the structure of its policy, processes, and procedures will not change to the new format until September 2009. Many of the Corporate Policy System requirements support the SNL/CA EMS Program. References to specific corporate policy system requirements are made throughout this manual when appropriate.

10.1.1 ES&H Manual and Supplements (CPR400.1.1)

The primary corporate control document for environmental requirements is the ES&H Manual. It provides basic operational controls for the Sandia workforce (SNL 2009a) at all Sandia locations. It describes the basics of Sandias ES&H Program. It identifies the boundaries of the program, describes how requirements flow down to Sandia organizations, and defines ES&H roles and responsibilities. The ES&H Manual is a compilation of process requirements and general procedures for complying with ES&H laws, regulations, DOE Orders, and Sandia requirements. The ES&H Manual is supplemented by site-specific process requirements when needed to address state and local requirements that are applicable at SNL/CA.

10.2 Local Controls

SNL/CA maintains a variety of operational controls that are site specific. These include technical work documents, an ES&H, Facilities, and Security Interdisciplinary Team, environmental permits and compliance documents, and contract specifications.

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The process used at SNL/CA for work planning and control is depicted in Figure 161. The process follows standard Sandia ISMS/EMS steps to plan work, analyze hazards, control hazards, perform work, and improve. Relevant significant environmental aspects for specific activities are determined during analyses of hazards.

10.2.1 Technical Work Documents

Technical work documents are required for all operations. The procedure for preparing and maintaining technical work documents is identified in Chapter 21 of the ES&H Manual. The initial step in identifying operational controls is accomplished through Sandias PHS process. The PHS is an online tool used to identify potential hazards associated with new and continuing activities. Through execution of the PHS tool, technical work documents, training, and personal protective equipment are identified to control safety conditions and environmental releases. All active PHSs are reviewed and updated annually. At SNL/CA, the center ES&H coordinators assist the site workforce with preparation and update of PHSs. The PHS database is available online to all Sandia workers at http://info.sandia.gov/esh/phs/. Technical work documents are used to define administrative and engineered controls required to address the hazards identified through the PHS. Technical work documents include operating procedures, standard operating procedures, safe work permits, and radiological work permits. These documents are updated every one to five years, or more frequently as needed. Technical work documents are maintained in an online database that can be found at https://sierrarf.ran.sandia.gov/eshdoc.nsf.

10.2.2 Interdisciplinary Team Process

The Interdisciplinary Team (IDT) process is a review process for new and changing projects at SNL/CA. IDT reviews occur during project planning so that environmental requirements and controls can be identified early and incorporated into project schedules. The IDT process has been used for more than ten years and is recognized by internal and DOE stakeholders as a successful best management practice and operational control mechanism. Additional information about IDT is provided in Chapter 14.

The work planning and control process is being updated. Implementation of the updated process must be initiated by June 30, 2009. Updates are expected to enhance the existing process to create efficiencies and effectiveness in planning and controlling work. The methodology outlined in Figure 16 will not change substantially.

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Line Manager authorizes work process initialization and assigns work planner

Ver 4d

2a

Plan Work

Perform preplanning with other organizations.

2
YES Does work involve multiple organizations? NO

Please consult a coordinator for help on any step

3
NO A NEW activity, project, operation or lab? YES

12
Review existing PHS Review any associated TWDs

13

10

Purchases involving onsite services

YES

14 4
IDT Review YES Will any NEW hazards or conditions be introduced?

Analyze Hazards
5
Complete / Update ISMS software

NO

10a

Contact Coordinator for guidance

6a 6c
Complete / Review Training Requirements Complete and resolve all action items from ISMS software determination and IDT review

6b
Create / Update & Submit TWDs

Control Hazards

Update PHS & TWDs to reflect any administrative changes if needed

15

8
Work control binder. (optional) Workers read & sign official work authorizing documents

Perform Work

10

Purchases involving onsite services

Ensure all controls are in place, training requirements have been met, hazards are documented and communicated to MOW, and the readiness review process has been completed (if required, as per Chapter 13, ES&H Manual).

Shape color designates primary responsibility. Border color designates authorization required. Text color designates additional input expected. Manager Responsibility

MOW Perform Work

Work Planner Responsibility

Feedback & Improve

Feedback and Lessons Learned (Post Job Review)

Member Of Workforce Responsibility

11

Involve ES&H Coordinators

Figure 16 SNC/CA ES&H Review Process

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10.2.3 Environmental Permits and Compliance Documents

Environmental permits and compliance documents function as activity-specific operational controls. They provide conditions under which the SNL/CA site may operate to meet federal, state, and local environmental regulatory requirements. Table 10 provides a list of the permits and documents valid in 2009. The individual environmental program annual reports provide additional information about each type of permit or compliance document (Appendix B).
Table 9 Environmental Permits and Compliance Documents, 2009 Type
Air

Description
Permit to Operate emission sources (15 sources for 2008/2009) Site Clean-up Order No. 89184 Business Plan Permit to Operate RCRA Hazardous Waste Facility Permit Permit by Rule

Statute / Regulation
Clean Air Act

Agency /Authority
BAAQMD

Environmental restoration Hazardous materials Hazardous waste Hazardous waste

California Water Code

Regional Water Quality Control Board, San Francisco Bay Alameda County Environmental Health Department California Department of Toxic Substances Control Alameda County Environmental Health Department Alameda County Environmental Health Department Alameda County Environmental Health Department Alameda County Environmental Health Department City of Livermore Water Reclamation Plant State of California Water Resources Control Board Army Corp of Engineers

California Health and Safety Code RCRA RCRA

Hazardous waste

Conditionally Authorized Permit to Operate Small Quantity Generator with Onsite Treatment Small Quantity Generator without Onsite Treatment Wastewater Discharge Permit State of California General Industrial Permit Channel improvements under the Arroyo Seco Improvement Program Permit to Operate

California Health and Safety Code California Health and Safety Code California Health and Safety Code Clean Water Act Clean Water Act Clean Water Act

Medical waste

Medical waste

Wastewater Storm water Jurisdictional waters of the U.S. Underground storage tank Aboveground storage tanks Environmental assessment Biological resources Universal waste

Resource Conservation and Recovery Act and California Health and Safety Code Aboveground Petroleum Storage Act NEPA Endangered Species Act California Electronic Waste Recycling Act, 22 CCR 66273

Alameda County Environmental Health Department State of California Water Resources Control Board DOE U.S. Fish and Wildlife Service California Department of Toxic Substances Control

Storage statement Final Site-wide Environmental Assessment of the SNL/CA Biological and Conference Opinion for SNL/CA Generator statement

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10.2.4 Contract Specifications

SNL/CAs contract specifications function as operational controls for contractor-directed work activities. The specifications include requirements for contractors to apply environmental controls in all appropriate work activities to maintain regulatory compliance and support environmental stewardship efforts at SNL/CA. Contractors are also required to report to SNL/CA on their efforts in waste reduction, recycling, and reuse of materials. SNL/CA implemented an environmental specification that will consolidate all environmental requirements applicable for construction activities into one document. An environmental permit is also pending implementation that will be included as part of the bid package to identify check points and contacts for various activities. The permit is expected to be implemented by June 2009. Efforts are also underway to identify environmental concerns for small value service / repair contracts. In October 2008, SNL/CA developed an environmental checklist to collect information during the procurement process from service / repair contractors. Identification of environmental concerns will be part of a new SNL/CA Work Planning and Control Procedure expected to be implemented by June 30, 2009.

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11 Document Control
11.1 Corporate Documents
The Information Management Policy Area (IM 100) identifies the process and procedures for managing and protecting Sandia information (SNL 2009c). The official version of all corporate policies, processes, and procedures is the electronic version maintained on the Sandia Restricted Network. These documents are disseminated to the workforce exclusively through the Corporate Policy System. They are reviewed and updated at least every three years. Each document is assigned an Executive Policy Sponsor. Only the sponsor or their delegate can approve changes to these documents.

11.2 Technical Work Documents

ES&H requirements and concerns related to activities and operations at SNL/CA are addressed through technical work documents such as operating procedures, hazard assessments, safety plans, and other similar documents. The procedure for updating and controlling technical work documents is identified in Chapter 21 of the ES&H Manual (SNL 2009a). Technical work documents are marked with an issue identifier for version control, date of publication, review period, and due date of next issue. The most current version of technical work documents is maintained in an online database. Outdated versions are removed from the online system when new versions are issued to prevent unintended use of obsolete documents. Safety procedures and plans contain authorized users lists. Personnel must read updated versions of technical work documents when issued and sign the authorized users list indicating their understanding and agreement to operate in accordance with new and modified procedures. Reference copies of technical work documents may be kept at the point of use at the discretion of the appropriate line manager. Line managers are responsible for establishing a process to keep printed reference documents up to date and for ensuring that personnel have reviewed appropriate procedures and signed the authorized users list before conducting operations. To control obsolete documents at point of use, Sandia identifies five methods of document control in the ES&H Manual, Chapter 21 (SNL 2009a). Methods range in formality from use of a formal document control center or numbered controlled copies to posting electronic copies on an internal Sandia network. SNL/CA increased efforts to control obsolete documents at point of use in 2006 in response to an ISO audit finding. Line manager responsibilities for document control were specifically identified in the Division 8000 Work Planning and Control Procedure (AP800015). In November 2008, validation of the corrective action was conducted and found that 38 percent of documents maintained in point of use binders were obsolete. SHEAC reiterated that it is the line managers responsibility to review document binders during routine surveillances for obsolete documents. A follow-up validation is planned for October / November 2009.

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In August 2008, SNL/CA implemented a new process to stamp obsolete documents maintained in the ES&H Records Center as superseded. As updated documents are filed in the Records Center, outdated versions are stamped.

11.3 Environmental Program Documents

EMS program and other environmental program documents are controlled by the Environmental Management Department (Organization 8516). These documents are reviewed annually as part of the program assessment process outlined in Quality Assurance of Data, Documents and Select Activities of the Environmental, Safety, and Health Departments, 8516 and 8517 (Appendix C). Each program lead controls and approves changes to their documents. The department manager controls and approves changes to EMS-specific documents. Current versions are maintained in active records storage in the ES&H Records Center, and displayed on the SNL/CA ES&H web site. Paper copies are not distributed to the workforce. Environmental documents of external origin (e.g. permits, regulatory authorizations, etc.) are maintained by the Environmental Management Department. Many of these documents are marked as valid for a specified period of time. Environmental program leads coordinate updates to external documents to ensure that documentation remains current. Permits and other regulatory authorizations that require posting at point of use are controlled and distributed by environmental program leads to ensure that obsolete documents are not used unintentionally.

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12 Competence, Training, and Awareness

Operations at SNL/CA fall within two categories, Sandia-directed and contractor-directed. The mechanisms used to ensure that the workforce is competent, trained, and aware differ depending on the category of operation. To foster general site awareness of EMS and ES&H issues, SNL/CA routinely disseminates information through brochures, fact sheets, newsletter articles, the ES&H website, electronic announcements, project reviews, and line assessments. Chapter 20 provides additional information on EMS communications.

12.1 Sandia-directed Operations

Members of the workforce involved in Sandia-directed operations are subject to the requirements of Sandias ES&H Manual. These requirements apply to Sandia employees (full and part-time staff, student interns, post-doctoral appointees), contractors performing under Sandia-directed contracts, and visitors (conference and meeting attendees, visiting researchers, industry partners). Chapter 11 of the ES&H Manual summarizes training for Sandia-directed operations. All Sandia workers and visitors are accountable and responsible for meeting applicable ES&H requirements, including those related to training. SNL/CA provides general EMS awareness training to the site work force through the following mechanisms.
New-hire orientation is a one time basic orientation to ES&H for employees and contractors performing under Sandia-directed contracts. ESH100 is an annual training requirement for the entire site workforce. ENV112CA is an annual training requirement for generators of hazardous waste at SNL/CA. Presentations tailored to site organizations.

12.1.1 Employee Competence, Training, and Awareness

It is Sandias practice to select the best qualified individuals on the basis of demonstrated competence (HR 100.1 Acquire Talent) (SNL 2009d) and to provide opportunities for, and encourage, professional development (HR100.2 Develop the Workforce) (SNL 2009e). To support this policy, Sandia maintains a set of general corporate training courses that cover a wide range of areas such as information and physical security, business ethics and diversity, ES&H, and general business processes. General corporate training requirements are identified at the time of hire by Sandia managers and training coordinators. Job-specific training and competencies are identified through the PHS process, by ES&H coordinators, and by project and department managers. Training requirements are listed on a Work Authorization Form maintained for each member of the workforce. Employees review and sign the Work Authorization Form indicating their understanding of training requirements.

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Sandia maintains an online Corporate Education, Development, and Training System (CEDT System) at https://hrprod.sandia.gov/cfdocs/prod/hris/ctd/apps/cedtweb/cedtmain/index.cfm to track completion status for all corporate training requirements and to provide electronic reminders to an employee and their manager when a course is due. ES&H Coordinators also communicate past due training statistics with Center Directors on a routine basis. 12.1.1.1 Environmental Program Workforce

Each of the six SNL/CA functional environmental program areas (Chapter 8) supporting the sites EMS Program maintain job descriptions, qualifications, and training requirements for each environmental program job position. Program leads review job descriptions, qualifications, and training requirements annually, update them as needed, and document the results of the review in annual program reports (Appendix B). The annual review and update provides an opportunity to modify training and competencies for existing environmental positions, or to identify new environmental positions, that are needed to support new or changing requirements. EMS Program awareness and training for members of the Environmental Management Department is accomplished through monthly department meetings. Updates on current EMS Program efforts and improvements made to the program are provided to the environmental program workforce during these meetings. Additionally, EMS information specific to functional environmental programs is relayed routinely to the appropriate personnel through established and informal meetings promoted by functional program leads.

12.1.2 Contractor Training, Awareness, and Competence

Contractors involved in Sandia-directed operations must meet basic competencies required to perform the assigned functions. Contracting companies also provide any general certifications needed for the assignment. Sandia communicates competency requirements and required qualifications with a job statement. Contracting companies provide resumes of potentially qualified workers to Sandia for review. Sandia managers or program leads review contractor resumes and screen against the job statement, conduct interviews, and select the preferred candidate. Sandia augments contractor training for Sandia-specific requirements identified through the PHS system or by the manager directing the contractors work. Sandia-required courses are tracked in the CEDT System. Similar to Sandia employees, contracted workers and the appropriate manager are notified when courses become due.

12.1.3 Visitor Competence, Training, and Awareness

The level of training required for visitors is dependent on the length of stay and activity that they will perform. ES&H training for visitors at SNL/CA is addressed in Chapter 11 of the ES&H Manual. Sandia hosts and their managers determine the level of training required for visitors. At a minimum, visitors performing hands-on work in SNL/CA facilities receive ES&H awareness training. Laboratory- and equipment-specific training is also provided for visiting researchers performing hands-on work at SNL/CA user facilities. For general EMS awareness, SNL/CA requires all visitors to review an ES&H briefing card when they receive a badge and prior to entering the site.

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12.2 Contractor-directed Operations

Contractors performing under contractor-directed contracts are subject to standard specifications established by SNL/CA and included in the contract. Sandia identifies specialized training, credentials, or certifications required for contractors in the contract specifications. For contractor-directed operations, contractor companies must submit an Injury Illness Prevention Program and a Job Hazard Analysis for review by SNL/CAs Construction Safety Engineer. Work does not begin until these documents are approved by Sandia. A Preliminary Hazard Assessment prepared by Sandia is also included in contract documents. The hazard assessment identifies specific environmental issues, such as air quality, waste management, and storm water pollution prevention that are applicable to a specific project. SNL/CA requires contractors to provide a project safety officer when conducting work at Sandia, and to provide written documentation that the safety officer meets the qualifications defined in the contract specifications. Additionally, specifications require contractors to maintain appropriate contractor training records on site and make available to Sandia oversight personnel upon request. All construction projects or construction-like activities at SNL/CA are presented to the ES&H IDT for review. The IDT process functions both as an awareness and compliance mechanism. SNL/CA executes the IDT process to identify ES&H requirements and to disseminate EMS information to the respective SNL Project Manager. Requirements and other applicable information identified during the IDT review are provided to contractors through contract specifications and during the safety plan review process. A pre-construction conference is held to determine if the pre-work contract requirements have been met (e.g. approved safety plan, activity hazard assessment, construction site requirements, etc.). Environmental staff routinely attend pre-construction conferences to provide awareness training on topics of concern such as storm water pollution prevention, wildlife, and recycling/reuse of materials. Sandia provides oversight throughout the length of projects. Oversight personnel identify nonconformances through deficiency notices, non-compliance notices, and safety violation notices. All non-conformance notices are tracked by Sandia and used during evaluations for contract renewals.

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13 Environmental Monitoring and Measurement

Each SNL/CA functional environmental program routinely monitors and measures the key characteristics of site operations that can affect the environment. Monitoring and measurement information supports our compliance requirements as well as assessment of overall progress in meeting site environmental objectives. For instance, the Environmental Monitoring and Restoration Program routinely samples and analyzes wastewater and storm water for contaminants of concern and other parameters. Data collected provide a measure of the quality of water discharges that can be used to determine if site operations meet permit conditions (compliance), or show improvement in sewer water quality (wastewater discharge objective). Program leads report the monitoring results as site metrics and publish these on the SNL/CA ES&H webpage. Table 11 identifies the monitoring activities conducted at SNL/CA and the EMS objective that the activities support.
Table 10 EMS Monitoring Activities Key Characteristics of Site Operations Monitoring Activity
Laboratory wastewater discharges Industrial and construction activities Emissions generated from site operations and onsite transportation Material procurement and use Use of land where sensitive wildlife and habitat are present Commuter site Use of fuel in onsite vehicles / equipment Hazardous and biological material use Hazardous waste generation Radioactive and mixed waste generation Routine sampling/analyses of sewer water; weekly monitoring of continuous flow meter at sewer outfall Routine sampling/analyses of storm water (2 storm events per year) Estimate mobile source emissions and compare against baseline estimate; collect and compile data on fill-ups on Spare-the-Air days Monitor annual affirmative procurement purchases, EPEAT designated computer purchases, and purchases of paper products Annually monitor wildlife species richness; annually monitor habitat improvements from Arroyo Seco project and compare against success criteria Periodic survey of site population on use of commute alternatives Annually monitor use of liquid transportation fuels Annually conduct chemical inventory reconciliation Continuous monitoring of quantities and types of hazardous waste generated Continuous monitoring of quantities and types of radioactive and mixed waste generated Continuous monitoring of quantities of solid waste generated and quantities and types of materials recycled

Supports EMS Objective

Minimize the volume and contamination of sewer water Minimize the volume and pollution of storm water runoff Minimize air emissions related to operations and transportation with particular emphasis on Spare-the-Air days Procure and use environmentally friendly products and materials

Enhance the natural habitat Maximize the use of commute alternatives by members of the workforce. Minimize the environmental impacts of transportation. Minimize the use of hazardous material; minimize the use of biological material Minimize the generation of hazardous waste Minimize the generation of radioactive and mixed waste Minimize the quantity of landfill waste through reduced consumption and/or reuse/recycling Minimize site water consumption; minimize site natural gas consumption; minimize site electrical consumption Minimize the environmental impacts of site contaminated areas

Solid waste generation Use of energy and water resources Previously contaminated areas

Quarterly monitoring of resources used Quarterly monitoring of groundwater at previously contaminated areas

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13.1 EMS Metrics

SNL/CA uses various metrics to measure environmental affects or impacts from site operations. Additionally, SNL/CA established metrics to measure general environmental management and awareness. Table 12 provides a list of site EMS metrics. Graphical representation of each metric is displayed on the SNL/CA ES&H website at http://surf.ran.sandia.gov/centers/8500/esh/CAEnvMgmt/metrics.
Table 11 List of EMS Metrics Impact Metrics Mobile source emissions Fueling operations on Spare-the-Air days Wildlife species diversity Energy use Sewer flow Sewer water contamination Storm water system controls Water use Site chemical inventory Chemical inventory reconcilliation Gas cylinder inventory Hazardous waste Hazardous waste chemical spills Environmentally preferred procurement Landfill waste Recycling Arroyo Seco Improvement Program plant survival EMS Management Metrics Published communications Outreach activities Environmental awareness Environmental violations, findings, DOE occurrences IDT reviews of site projects and activities NEPA reviews

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14 Evaluating Compliance with Environmental Requirements

SNL/CA evaluates compliance with all environmental requirements through the IDT process, self-assessments, and audits.

14.1 IDT Process

The IDT process is used to review SNL/CA projects early in the planning stages and to provide guidance to project proponents on ES&H, security, facilities issues (engineering, maintenance, and operations) and general operational/logistical issues. The IDT meets weekly to review new activities and significant changes to existing activities. This process also serves as an avenue for project proponents to provide feedback that can be used for both project and ES&H process improvement. Each functional environment, safety, security, and facility operations program has a representative on the IDT. The environmental program representatives provide project proponents with information and guidance on environmental objectives, compliance, requirements, and other EMS-related topics. In 2007, SNL/CA began using an electronic data management system to record IDT reviews and compile the results of the review into an electronic report. The electronic report is accessible to the presenter, IDT members, and other designated participants in the process. A paper copy of the report is printed and maintained in the ES&H Records Center. The IDT record includes an IDT evaluation request, a list of IDT members in attendance, comments and requirements provided by IDT members; and presentation materials. A digital recording of each presentation that serves as meeting minutes is also maintained as a record in the Web File Share database, a corporate database for electronic files.

14.2 Self-assessments and Audits

Compliance evaluations are supported by a wide variety of assessments and audits. Implementation of requirements across all SNL/CA operations, as well as management processes, are evaluated through self-assessments and audits. Self-assessment and audit results are maintained as Sandia records either in the ES&H Records Center or in an online database. Table 13 identifies the types of self-assessments and audits routinely conducted for SNL/CA operations, and the records that result from each. In 2006, SNL/CAs EMS Program received certification under the international standard for environmental management systems, ISO 14001:2004. The ISO 14001:2004 standard requires annual or semi-annual surveillance audits of certified EMS programs. In 2008, SNL/CAs surveillance audits were conducted in April and September, resulting in continued certification under the ISO standard.

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Table 12 SNL/CA Environmental Assessment and Audit Types

Type Line Implementation Corporate Line ES&H Manual Self-assessment Section 22A Division 8000 Line SelfES&H Manual assessment Section 22A Environmental program line assessment EP Representative assessment Guidance Document / Driver Conducted By All members of the workforce Schedule Scope Record Type Corporate self-assessment database Division 8000 ES&H selfassessment database Record Maintenance

Monthly

Select ES&H areas

Online

Line manager

Annual

Administrative procedure AP800005 Administrative procedure AP800009

Functional program lead EP Representative

Annual Routine / ongoing

Select ES&H areas Adequacy and effectiveness of processes, adequacy of resources, communication of requirements, line ownership of requirements Informal, focus on critical environmental requirements and trouble spots All aspects of facility operations, record keeping, program processes, and adherence to permit conditions / requirements, audits are generally unplanned and unannounced Subset of ES&H programs audited each year

Online

Assessment report

SNL/CA ES&H Records Center SNL/CA ES&H Records Center

Informal report

Audits
External regulating agency audits and inspections Federal, state, and local regulations and permits M&O Contract, DOE policies and requirements M&O Contract, Corporate Policy Statement CPS001.3, Corporate Policy Requirement CPR001.3.5

Regulatory Inspectors

Annual

Official correspondence

SNL/CA ES&H Records Center SNL/CA ES&H Records Center

DOE audits

Management System audits

DOE auditors Sandia ES&H, Quality, and Safeguards & Security Assessments Department

Annual

Audit report

Third party certification

ISO 14001

External third party auditor

Annual Recertify every three years; surveillance semiannually

Internal, independent audit of laboratory systems associated with ES&H, Quality, and Safeguards & Security

Audit report

SNL/CA ES&H Records Center

Requirements of the ISO 14001 Standard

Audit report

SNL/CA ES&H Records Center

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15 EMS Internal Audit and Self-Assessment

Annually, SNL/CA completes an internal audit of the EMS Program to determine if it conforms to the ISO 14001 Environmental Management System standard, and to ensure that it is properly implemented and maintained. Additionally, the various assessments and audits described in Chapter 14 support management and maintenance of the EMS. SNL/CA maintains an administrative procedure for conducting assessments used in support of the EMS Program (SNL/CA 2008c). Figure 17 summarizes the assessment sources that assist in keeping SNL/CAs EMS on track.

SNL/CA EMS Assessments

Independent Assessments
External Internal Internal SNL Audit Dept. Corporate Line Self Assessment Division 8000 Line Self Assessment

Government Audits & Assessments

Non-Govt Assessments

DOE, EPA, County, City L/M, Consultant, Reciprocal Covers specific Covers all or specific
program elements EMS elements.

Dept 12870 Covers all or specific

EMS elements.

Unscheduled Formal Driver: Fed/State laws,

SNL/DOE contract

Scheduled Formal or Informal Formatted or Unformatted Driver: CPR 001.3.10

- FY06: ISO14001

Scheduled Formal Driver: CPR 001.3.10

ES&H Manual Chapter 22

Corp. Process Targeted Content Scheduled Formal Web Based Driver: CPR 001.3.10
ES&H Manual Chapter 22

Facilitated by Div.
ES&H coordinator

Scheduled Driver: CPR 001.3.10

ES&H Manual Chapter 22

Self Assessments
EMS Managers Annual Assessment
Review of all EMS elements. Scheduled Formatted Driver: AOP
EP Reps Line Assessments

Individual Environmental Program Assessments (6)

Assesses targeted env.

program requirements

Formatted Tracks line trouble

spots and trends

Program Leads Program Self Assessment

Program Leads Line Performance Self Assessment

Driver: OP

Looks internally at program

mechanics

Targeted but covers entire

breadth of program over a 3 Yr period.

Formatted Driver: AOP

Formal planned/designed Driver: AOP

Figure 17 Assessments Supporting SNL/CAs EMS Program

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15.1 Internal EMS Audits

Sandias corporate assessment team in the ES&H, Quality, and Safeguards & Security Assessments Department (Organization 12870) conducts periodic internal audits of SNL/CAs EMS Program. Internal audits will be completed every three years and will evaluate the EMS Program against the requirements of the ISO 14001 standard. The first internal audit against ISO 14001:2004 requirements was conducted in June 2008. During interim years, the EMS Core Team completes a gap analysis of select ISO elements. The gap analysis provides a broad look at requirements rather than an in-depth comparison against the details of the ISO standard. Internal audit reports and gap analyses are EMS records and maintained in the ES&H Records Center.

15.1.1 2008 Audit

In June 2008, Organization 12870 conducted an audit of the SNL/CA EMS Program against the requirements of the ISO standard. The audit resulted in two issues2 requiring corrective action. The first issue relates to discrepancies between information presented in the EMS Manual and similar information maintained on the EMS website. Corrective actions were implemented to update all information presented on the website and to state in Section 1.2 of this manual that information presented on the web is the most up-to-date and that the manual reflects a point-intime. The second issue relates to consideration of small-dollar subcontracts in identifying environmental aspects and undefined operational controls for such activities. Corrective actions were implemented to insert an environmental questionnaire into the contracting process to capture environmental data and identify action-specific controls, when applicable.

15.1.2 2009 Audit

The 2009 internal audit of the SNL/CA EMS Program consists of an interim gap analysis against the ISO 14001:2004 standard. The gap analysis was completed in April 2009. No gaps were identified, but several areas of improvement were noted in the areas of communications and awareness and document control.

15.2 EMS Program Self-Assessments

The primary self-assessment used for the EMS Program is the annual EMS Management Representative assessment. Other self-assessments may also be used to evaluate the EMS Program, including corporate and DOE assessments. EMS Program self-assessment results are EMS records and maintained in the ES&H Records Center.

15.2.1 2008 Assessment

The EMS Management Representative completed an EMS Program self-assessment in December 2008 with a focus on identifying improvements. The results of the assessment are documented in the Laboratory Enterprise Self Assessment (LESA) database. A self-assessment report is

An issue represents a noncompliance with requirements and/or presence of a potentially unacceptable risk.

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generated from LESA and submitted to the ES&H Records Center. The results of the 2008 assessment are summarized below.

Include the Arroyo Improvement Plan on the Environmental Planning and Ecology Program website. Include a date on the current wildlife issues website. Environmental Planning and Ecology Program should assume a greater role in site development planning to capture and communicate environmental requirements. Consider a separate specification for environmental requirements. Implement a procedure to routinely remove sediment from LEC pits. In the Waste Management Program, review past year assessment results for trends and develop actions to correct negative trends. Complete procedures for universal waste items. Implement cardboard recycling process. Submit Federal Electronics Challenge submission for a site award. Develop an energy conservation section on the EMS website that includes corporate targets, conservation tips, and external links. Update preferred list of recycled paper products for ease in readability. Establish clear baselines for pollution prevention and waste minimization targets. Complete the diesel transition plan and communicate to SHEAC. Work with corporate Fleet Management Program to adequately reflect SNL/CA in the corporate plan. Develop a site vehicle plan. Update Fact and Help sheets with current information, place updated sheets on website. Work with Badge Office to implement a visitor briefing card. Update website with current significant aspects. Verify that assessment documents from the CUPA inspection are copied into the 2008 assessment files. Complete the installation of sewer flow meters including one at the pump discharge station. Devote one core team meeting to review of assessment and corrective action process. Review self-assessment reports and assure actionable items are entered into LESA and/or Actions Spreadsheet. Convert Quality Assurance Program Plan to a companion to the EMS Manual. Develop a list of outreach presentations to line organizations. Create metrics for new 2009 targets. Input above action items on the Actions Spreadsheet.

15.2.2 2009 Assessments

During the fourth quarter of 2009, the EMS Management Representative will complete a selfassessment of the EMS Program. This self-assessment will evaluate each element of the program for improvements in implementation and management. Other than the scheduled gap analysis (see Section 15.1.2), there are no other corporate, division, or DOE assessments planned for the EMS Program in 2009.

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16 Nonconformity, Corrective, and Preventive Action

SNL/CA maintains a procedure for identifying nonconformities through a system of audits and assessments. Administrative Procedure AP800005, Environmental Management System Assessment Process (SNL/CA 2008c) describes the various audit/assessment types that are conducted to assess site compliance with environmental regulations and requirements, and continually improve the site EMS. The procedure also describes scheduling, tracking, and management of results. Audits and assessments conducted at SNL/CA are described in Chapters 14 and 15 of this manual.

16.1 Audit and Assessment Tracking

SNL/CA environmental and EMS-related audits and assessments are tracked and documented in one of three databases: the LESA database, the Corrective Action Tracking System (CATS), or the EMS Actions Spreadsheet. LESA and CATS are online corporate systems. The EMS Actions Spreadsheet is an Environmental Management Department tool used to capture actions that do not warrant entering into LESA or CATS.

16.2 Corrective and Preventive Action

The EMS Core Team and SNL/CA Assurance Department evaluate the results of environmental and EMS-related audits/assessments to identify findings, observations, opportunities for improvement, and noteworthy practices3. Corrective actions are established for all findings. SNL/CA uses the corporate Corrective Action Tracking System (CATS) to record and track implementation of environmental and EMS-related corrective actions associated with audit issues / findings from Organization 12870, DOE, or external agencies. Corrective actions from self-assessments (including ISO surveillance audits) are recorded and tracked in LESA or the EMS Actions Spreadsheet. Verification of corrective actions entered into CATS is conducted by an independent verifier, generally a member of SNL/CAs Quality Assurance organization. Verification of corrective actions entered into LESA and the EMS Actions Spreadsheet are verified by the EMS Core Team. A root cause determination is required for all findings entered into CATS. Preventive actions are established for observations and opportunities for improvement. Preventive actions are recorded in LESA and tracked using an EMS action spreadsheet. Core Team members notify the responsible member of the workforce of the need for preventive actions using the site email system. Verification of preventive actions is conducted by the Core Team.

Definitions of terminology are provided in AP800005.

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16.3 Validating Effectiveness of Actions

SNL/CAs process for validating the effectiveness of corrective and preventive actions for environmental and EMS-related issues is documented in Administrative Procedure AP800010, Validation of Environmental or EMS-Related Corrective / Preventive Actions (SNL/CA 2008b). The EMS Core Team and SNL/CA Assurance Department determine which actions require validation. Actions are selected for validation based on the significance or risk of nonconformity. For example, actions that address serious nonconformities with potential for a fine, significant negative environmental impact, or actions attempting to correct recurring issues, may be selected for effectiveness validation. The validation of an action is documented on an SNL/CA EMS Corrective / Preventive Action Validation Form. Completed forms serve as the ES&H record of validation.

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17 Management Review
Annually, the EMS Management Representative reviews SNL/CAs EMS Program with SHEAC (Section 3.1). Management reviews are intended to ensure continued suitability, adequacy, and effectiveness of the EMS Program. Reviews include the following topics.
Results of internal audits and evaluations of compliance with legal and other requirements Communications from external parties Site environmental performance Progress in meeting EMS objectives and targets Status of corrective and preventive actions Follow-up actions from previous management reviews Changing circumstances including developments in legal and other requirements related to environmental aspects Recommendations for improvements Modifications and additions to environmental objectives and targets

In the past year, management reviews were completed in April and October 2008.

During the April management review (conducted April 24, 2008), the EMS presentation included a follow-up on issues from the previous review, results of audits and assessments, compliance and changes to requirements, communications with external parties, the status of corrective and preventive actions, and recommendations for improvements. Actions resulting from this management review are: Provide information to center directors and the management team about the hierarchy of environmental risks that can then be communicated to the workforce. Evaluate and understand Office of Science expectations related to environmental programs to clearly position SNL/CA for a multi-landlord site. During the October management review (conducted October 30, 2008), the EMS presentation included a follow-up from the prior review, recent major events, environmental performance for past year, extent to which objectives and targets were met, and new and modified objectives and targets. Actions resulting from this management review are: Review status of copper exceedance with site VP. Communicate to the workforce about landscape changes underway to conserve water and other resources.

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18 EMS Documentation
Documentation to support SNL/CAS EMS Program is comprised of both EMS-specific and general corporate and site documents and information sources. The SNL/CA EMS Program Manual is the primary EMS document for the site. It describes all elements of the EMS Program, how these elements connect, and it provides reference to other general documents that support the program. The EMS Program Manual documents the process used to identify significant environmental aspects applicable to site operations, and to establish objectives and targets that are measurable and relevant. It serves as a roadmap for continual EMS implementation, assessment, and improvement. The SNL/CA EMS Program Manual is reviewed and updated annually. Other documentation established for the SNL/CA EMS Program includes a communication plan (Appendix D), ES&H policy/standard of performance (Chapter 2), annual environmental program reports (Appendix B), annual EMS communications calendar (Figure 19), and project management schedules for significant environmental aspects (Chapter 6). EMS documents also include procedures developed specifically for the EMS Program, EMS decision documents, EMS internal audit and self-assessment results, communications with external parties, and results of management reviews. All documents created under the EMS Program are records in accordance with the definition of a record used at Sandia. Other SNL/CA site-specific and corporate policies, document systems, and databases also support the EMS Program. Figure 18 identifies the documents and document systems that support the SNL/CA EMS Program.

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Corporate - Corporate policy system - ES&H policy - ES&H Manual - ILMS - Training database - Assess/audit reports - Corp. EMS Program - Occurrence mgmt. sys.

Site/Division - Site requirements - Emergency Mgmt Prog. - Fire Mgmt Prog. - Div 8000 ES&H Plan - Technical work docs - Occurrence reports - Assess/audit reports - IDT reviews

Documents Supporting SNL/CA EMS Program

EMS Documents - EMS Program Manual - Communication Plan - ES&H Standard of Perf. - Env. program reports - Sig. aspect schedules - Comm. calendar - EMS decision docs - EMS procedures - Audit/assessment results - Mgmt review results

Environmental Programs - Permits - Regulatory reports - DOE reports - Training records - Department reports - Site reports - Dept. QA Plan

Figure 18 EMS Documentation

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19 Records
Sandia manages all information created by Sandia work in accordance with the Corporate Policy System requirements identified in IM 100, Information Management (SNL 2009c). As defined in the information management procedures, information encompasses data, records, published material, and knowledge in written, pictorial, electronic, audio, oral, or other form. To assist the workforce with the requirements for managing information, Sandia developed a Records Management Manual. The Records Management Manual provides guidance on identifying records and non-records, provides a list of federal and DOE requirements governing records management, and summarizes the records retention and disposition schedule. The complete manual is available on the Sandia intranet at http://wwwirn.sandia.gov/recordsmgmt/rmm/Requirements.htm. SNL/CA maintains an additional procedure for managing ES&H records, OP471347 Administrative Procedures for Managing Sandia/CA ES&H Recorded Information (SNL/CA 2008a). This procedure incorporates corporate policies, requirements of the Records Management Manual, best business practices, program-specific regulatory requirements, and the requirements of the ISO 14001 standard. Under this procedure, ES&H programs are responsible for transmitting recorded information to the SNL/CA ES&H Record Center for storage and protection. The Record Center establishes file guides for categories of records and assigns a file code number. The file guide describes the record, identifies the retention period, describes the disposition instructions (where applicable), and provides filing instructions. Record Center personnel log all transmitted records into an electronic database. Document titles, dates, authors, and key words are included in the database to assist with tracking and retrieval of records. SNL/CA established a file guide and code for EMS records in March 2005. The file code is ADMAN-07.05. EMS program documents and supporting information are filed under this code with a permanent retention. SNL/CA maintains separate file guides and codes for other functional environmental program records that also support the EMS Program. SNL/CA also uses a corporate database, Web File Share, to maintain digital recordings of IDT meetings and other electronic environmental program records. Environmental Program Leads have the option of submitting electronic records to the Web File Share system instead of creating paper copies. Electronic records support reductions in paper use and resources needed to manage and maintain paper records. The Web File Share system has been established and is managed as a permanent record.

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20 Communications
SNL maintains an active communication system with established tools and processes to share information both internally and externally. As a result, SNL/CA has many options available to communicate EMS information to the site workforce and to external stakeholders. SNL/CAs Communication Plan Supplement (Appendix D) builds on the corporate EMS communication plan. The supplement identifies the communicators and their roles, outlines the site-specific communication tools used at SNL/CA, and provides a typical list of communication activities.

20.1 Internal Communications

The SNL/CA EMS Core Team communicates EMS information to the site workforce through the IDT process, publications, the internal web site, briefings, assessments, and promotional materials. The EMS Core Team receives input on environmental issues, including aspects and impacts, through the IDT process, the NEPA process, an ES&H telephone hotline, the selfassessment process, and the ES&H internal web site contacts list. SNL/CA also established an EMS Advisory Committee to facilitate communication between the EMS Core Team and the various organizations on site. The Advisory Committee consists of representatives from various functional areas including administrative support, facilities organizations, research and testing organizations, emergency planning, and procurement. Advisory Committee meetings are held semi-annually to seek input on current issues and concerns related to EMS implementation. Figure 19 provides a list of actions scheduled and completed in 2009 to promote internal communications.

20.2 External Communications

SNL/CAs decision to communicate externally about the EMS program, including significant environmental aspects, is documented in a Memo-To-File (Figure 20). SNL/CA accomplishes external EMS communications through the annual site environmental report and Sandias external web site at http://public.ca.sandia.gov/casite/about/community/environmental_mgt.php. Figure 20 provides a list of EMS topics included in the annual report. A comment response card is distributed with the annual report and a link is provided on the web site to gather input from external stakeholders. All published information distributed externally must be reviewed and approved for public release in accordance with Sandia requirements. The EMS Core Team routinely communicates with external parties about elements of the SNL/CA EMS. External communications follow the Administrative Procedure (AP800007), Receiving, Documenting, and Responding to EMS Communications from External Parties (SNL/CA 2008e). Environmental staff members also conduct community outreach efforts by participating in site events, such as family days and site celebrations, and through presentations at local schools and community events. In 2008, Environmental Department staff participated in

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Bring your sons and daughters to work day and conducted a presentation on local wildlife at a Livermore elementary school. Regulating authorities also conduct scheduled and unannounced site audits. These audits provide an additional avenue for communicating with our stakeholders and keeping them abreast of our EMS Program. Finally, SNL corporate is working to include a statement on the external procurement web page to communicate corporate EMS information to current and prospective contractors and suppliers.

Figure 19 EMS Communications Calendar, 2009

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Figure 20 External Communication Decision Memo

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Appendix A - EMS Targets for 2009

The following targets were approved by SHEAC on October 30, 2008. Targets are grouped under each aspect (green) and objective (blue). All Performance Track targets were removed in March 2009 (plum) because EPA canceled the program. (Reviewed by EMS Core Team on 8/19/08) (Reviewed by EMS Advisory Committee on 9/17/08) (Approved by SHEAC on 10/30/08)

General Environmental Operations..

Objective: Provide exceptional environmental management for the SNL/CA site. Targets: Receive zero findings per audit per environmental program as the result of annual DOE audits. Receive no more than 2 minor non conformances as a result of ISO14001 certification audits. Receive no Notices of Violation (NOVs) as a result of any external regulatory agency audit. Maintain a level of published environmentally-related communications at 6 per month (total of 72/FY). Maintain a level of environmentally-related outreach activities at 4 per month (total of 48/FY). By the end of FY2010 achieve a 20% increase in the EMS awareness survey average score from an FY2008 baseline.

Water Discharges (Significant Aspect)

Objective 1: Minimize the volume and contamination of sewer water. Target: Maintain the average weekly composite Zinc and Copper concentrations in sewer below the 50% regulatory trigger level. (0.5 mg/L for Cu and 1.5 mg/L for Zn) Conduct sewer line cleaning and CCTV inspection for all sewer lines 6 inches and greater at least every three years. (Next due in fall 2011)

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Conduct annual physical survey/visual inspection of all sewer system components (exposed piping, manholes, pump stations, cooling tower basins, sink traps, LEC systems and sumps). (Next due in fall 2009)

Objective 2: Minimize the volume and pollution of storm water runoff. Targets: 100% of new construction will have post-construction runoff equal to or less than preconstruction runoff. 100% inspection / cleaning of on site storm drain system including drop structures by October 1 of each year. By Sept 1 of each year implement runoff controls for 100% of bulk erodable landscape and construction material.

Air Emissions (Significant Aspect)

Objective: Minimize air emissions related to operations and transportation with particular emphasis on Spare-the-Air days. Targets: Maintain on site fueling operations on Spare-the-Air-Days at (an average of) less than or equal to 3 fill ups/STAD.

General Transportation (Significant Aspect)

Objective: Maximize the use of commute alternatives by members of the workforce. Target: In FY15 increase the use of single driver commute alternatives by 25% from the FY06 commuter survey established baseline. Alternatives include: carpooling, mass transportation, purchase/use of hybrids, biking/walking, telecommuting.

Objective: Minimize the environmental impacts of transportation. SLN/CA commits to reduce the use of transportation fuels (diesel, gasoline, and E85) by 10% by 2010 from a baseline year of 2006 (from 32,548 to 29,293 gallons). PERFORMANCE TRACK TARGET . Target removed because EPA canceled the Performance Track Program in March 2009.

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Land Use (Significant Aspect)

Objective 1: Enhance the natural habitat. Targets: Complete the most critical actions identified in the Arroyo Seco Management Plan within 10 years of receipt of the 10 year permit (Permit received Sept 25, 2008). SNL/CA commits to complete four of the Arroyo Seco Improvement projects by 2010. PERFORMANCE TRACK TARGET Target removed because EPA canceled the Performance Track Program in March 2009.

Objective 2: Design and manage all buildings and facilities using green principles.

Material Procurement and Use .

Objective: Procure and use environmentally friendly products and materials. Targets: In FY10 purchases made by Affirmative Procurement Program will equal or exceed 96% of available procurements. In FY09 100% of purchased general use computers will meet or exceed EPEAT silver requirements. SNL/CA commits to increase the recycled content of paper products purchased by 10% by 2010 from a baseline year of 2006 (from 38,884 to 42,772 lbs). PERFORMANCE TRACK TARGET Target removed because EPA canceled the Performance Track Program in March 2009. In FY10 increase the use of bio based products by 25% from the FY08 amounts.

Hazardous Material.
Objective: Minimize the use of hazardous material. Targets: Maintain an annual overall Chemical Information System reconciliation of >94%. Maintain an annual Chemical Information System reconciliation of 100% for the NFPA 704 health hazard rated 4 materials greater than 10% of laboratory scale quantities (4 lbs solid, 0.5 gal liquid, 1 lb gas).

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Solid Waste.
Objective: Minimize the quantity of landfill waste through reduced consumption and/or reuse/recycling. Targets: In FY10 decrease the amount of copy paper purchased by 5% from the FY05/06 average. Maintain 100% recycling of recyclable quality wood, concrete/asphalt and green landscape waste.

Water Use
Objective: Minimize site water consumption. Target: In FY15 achieve a reduction in site water consumption by 16% from a FY07 baseline. (from 69,901 kgal to 58,717 kgal) (EO 13423) SNL/CA commits to reduce the quantity of water used on site by 6% by 2010 from a 2006 baseline (from 69,908,244 gallons to 65,713,749 gallons). PERFORMANCE TRACK TARGET. Target removed because EPA canceled the Performance Track Program in March 2009. No landscape watering between 7am and 7pm except for testing and maintenance.

Objectives with no Current Established Targets

Hazardous Waste (Significant Aspect)
Objective: Minimize the generation of hazardous waste.

Universal Waste ...

Objective: Maintain effective and efficient processes for the management of Universal Waste.

Use of Biological Agents

Objective: Minimize the use of biological materials.

Radiological Material
Objective: Minimize the use of radiological materials.

Radiological & Mixed Waste

Objective: Minimize the generation of radiological and mixed waste.

Contaminated Areas
Objective: Minimize the environmental impacts of site contaminated areas.

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Legacy Asbestos
Objective: Reduce site legacy asbestos material.

Hazardous Material Transportation

Objective: Minimize the potential environmental effects of hazardous material due to transportation.

Earthquake
Objective: Minimize the environmental effects of a site seismic event.

Fire
Objective: Minimize the environmental effects of a site fire emergency.

Natural Gas Use

Objective: Minimize site natural gas consumption. Defer to corporate program.

Electrical Use
Objective: Minimize site electrical consumption. Defer to corporate program.

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Appendix B - Environmental Program Reports

Annual environmental program reports are available on the SNL/CA ES&H website. Listed are the links to each report. The official record of this manual stored in the ES&H Records Center contains a hard copy of each report. Air Quality Program http://surf.ran.sandia.gov/centers/8500/snl_ca_air_quaility_program_annual_report Environmental Monitoring Program http://surf.ran.sandia.gov/centers/8500/snl_ca_environmental_monitoring_program_annual_repo rt Environmental Planning and Ecology Program http://surf.ran.sandia.gov/centers/8500/esh/CA-EnvMgmt/programs/PE Hazardous Materials Management Program http://surf.ran.sandia.gov/centers/8500/snl_ca_hazardous_material_management_program_annua l_report Pollution Prevention and Waste Minimization Program http://surf.ran.sandia.gov/centers/8500/esh/CA-EnvMgmt/programs/PP/reports Waste Management Program http://surf.ran.sandia.gov/centers/8500/snl_ca_waste_management_program_annual_report

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Appendix C - ES&H Quality Assurance

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Note: In August 2006, this form was modified. The new form was distributed for use to the EMS Core Team on August 16, 2006.

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Appendix D - SNL/CA Communication Plan Supplement

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References
DOE 2005, DOE Order 151.1C, Comprehensive Emergency Management System, November 2, 2005 DOE 2008, DOE Order 450.1A, Environmental Protection Program, June 4, 2008. ISO 2004, ISO 14001, second edition, Environmental management systems Requirements with guidance for use, November 15, 2004. SNL 2007a, CPSR 400.1, Environment, Safety & Health, January 23, 2007. SNL 2007b, ES&H and Emergency Management Administrative Procedure AOP 04-02, revision 3, Requirements Management Process, October 2, 2007. SNL 2009a, CPR 400.1.1, ES&H Manual & Supplements (MN471001), January 9, 2009. SNL 2009b, CG 100.5, Ensure Quality, April 20, 2009. SNL 2009c, IM 100, Information Management, April 20, 2009. SNL 2009d, HR 100.1, Acquire Talent, April 20, 2009. SNL 2009e, HR 100.2 Develop the Workforce, April 20, 2009. SNL 2009f, CG 100, Corporate Governance, April 20, 2009. SNL/CA 2008a, OP471347, Administrative Procedure for Managing Sandia/CA ES&H Recorded Information, March 19, 2008. SNL/CA 2008b, Administrative Procedure AP800010, Issue B, Validation of Environmental or EMS-Related Corrective / Preventive Actions, June 4, 2008. SNL/CA 2008c, Administrative Procedure AP800005, Issue E, Environmental Management System Assessment Process, August 4, 2008. SNL/CA 2008d, Emergency Management Plan, http://surf.ran.sandia.gov/centers/8500/security/em/pp, September 2008. SNL/CA 2008e, Administrative Procedure AP800007, Issue C, Receiving, Documenting, and Responding to EMS Communications from External Parties, November 11, 2008.

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