U.S. Department of Energy 06-ED-016 Mr. M . S. Spears, President and General Manager CH2M HILL Hanford Group, Inc. Richland, Washington 99352 Dear Mr. Spears: P.O. Box 450 Richland, Washington 99352 MAR 10 2 006 0 89 32 llE~~~!~ID EDMC CONTRACT NO. DE-AC27-99RL14047 - ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) ASSESSMENT REPORT This letter transmits for your action the results (Attachment) of the U.S. Department of Energy (DOE), Office of River Protection (ORP) assessment performed from November 14 through 18, 2005, of the CH2M HILL Hanford Group, Inc. (CH2M HILL) EMS Implementation. The assessor found CH2M HILL had successfully implemented the EMS requirements of DOE 0 450.1, EMS, including the integration of the EMS into the CH2M HILL Integrated Safety Management System (ISMS). The assessor identified four Findings during this assessment. Finding 1 identifies the need to update many implementing engineer, business management, and operations procedures to reflect the new EMS/ISMS requirements established by RPP-MP-003 (Revision 5), "Integrated Environmental, Safety, and Health Management System Description," and TFC-PLN-73 (Revision A), "Environmental Program Description." Finding 2 identifies that RPP-16922, "Environmental Specifications Requirements," is not comprehensive or complete, and is not appropriately identified in other field implementing procedures as a mandatory source of environmental requirements. RPP 16922 is identified in RPP-MP-03 as a primary implementing procedure for environmental requirements. Finding 3 identifies that significant environmental interfaces between CH2M HILL and other site contractors and site environmental programs identified in TFC-PLN-73 are not appropriately documented or controlled under CH2M HILL's own interface management procedure. Finding 4 identifies deficiencies in RPP-MP-612, "Pollution Prevention/Waste Minimization Program," and TFC-PLN-58, "Chemical Waste Management Plan," which are cited by RPP-MP- 003 as principal EMS implementing procedures (e.g., both documents generally fail to provide citation to_ specific implementing procedures, interface controls, and EMS specific requirements). CH2M HILL staff was provided the opportunity to review and comment on ORP's draft assessment report prior to finalization. Additionally, ORP conducted an out briefing with CH2M HILL to provide an additional opportunity for CH2M HILL to discuss and comment on the draft report.
Dear Mr. Spears:
MAR 10 2006
CONTRACT NO. DE-AC27-99RL14047 - ENVIRONMENTAL MANAGEMENT SYSTEM
(EMS) ASSESSMENT REPORT
This letter transmits for your action the results (Attachment) of
the U.S. Department of Energy (DOE), Office of River Protection
(ORP) assessment performed from November 14 through 18, 2005, of
the CH2M HILL Hanford Group, Inc. (CH2M HILL) EMS
Implementation.
The assessor found CH2M HILL had successfully implemented the EMS
requirements of DOE 0 450.1, EMS, including the integration of the
EMS into the CH2M HILL Integrated Safety Management System (ISMS).
The assessor identified four Findings during this assessment.
Finding 1 identifies the need to update many implementing engineer,
business management, and operations procedures to reflect the new
EMS/ISMS requirements established by RPP-MP-003 (Revision 5),
"Integrated Environmental, Safety, and Health Management System
Description," and TFC-PLN-73 (Revision A), "Environmental Program
Description."
Finding 2 identifies that RPP-16922, "Environmental Specifications
Requirements," is not comprehensive or complete, and is not
appropriately identified in other field implementing procedures as
a mandatory source of environmental requirements. RPP 16922 is
identified in RPP-MP-03 as a primary implementing procedure for
environmental requirements.
Finding 3 identifies that significant environmental interfaces
between CH2M HILL and other site contractors and site environmental
programs identified in TFC-PLN-73 are not appropriately documented
or controlled under CH2M HILL's own interface management
procedure.
Finding 4 identifies deficiencies in RPP-MP-612, "Pollution
Prevention/Waste Minimization Program," and TFC-PLN-58, "Chemical
Waste Management Plan," which are cited by RPP-MP- 003 as principal
EMS implementing procedures ( e.g. , both documents generally fail
to provide citation to_ specific implementing procedures, interface
controls, and EMS specific requirements).
CH2M HILL staff was provided the opportunity to review and comment
on ORP's draft assessment report prior to finalization.
Additionally, ORP conducted an out briefing with CH2M HILL to
provide an additional opportunity for CH2M HILL to discuss and
comment on the draft report.
Mr. M . S. Spears 06-ED-016
-2- MAR 1 O 2006
If CH2M HILL incorporates the Findings of the ORP assessment into
its Corrective Actions Program, no response to the Findings is
necessary. Please provide a copy of the Problem Evaluation
Request(s) (PER) documenting incorporation to ORP no later than 30
days from
. receipt of this letter. ORP shall assess corrective actions
during the next annual ISMS assessment.
If CH2M HILL elects not to document the Findings of this assessment
in the Corrective Actions Program via PER, please provide the
following information to ORP no later than March 31, 2006:
• Provide a statement of admission or denial of the
Finding(s);
• Identify the causes(s) of the Finding(s);
• Identify corrective actions already taken to correct the
Findings;
• Identify corrective actions that will be taken to prevent
recurrence of the Finding(s); and
• State the date the contractor will be in full compliance with
their contractual and regulatory commitments.
The direction herein is considered to be within the limitations of
the Technical Direction (TD) clause in the Contract and does not
meet any of the conditions described in paragraph (b) (1) through
(4) of the TD clause. If, in the opinion of the Contractor, any
instruction or direction by the COR in this letter falls within one
of the categories defined in TD clause (b)(l) through (b )( 4 ),
the Contractor shall not proceed but shall notify the Contracting
Officer immediately orally, and in writing within five (5) working
days, after receipt of any such instruction or direction and shall
request the Contracting Officer to modify the contract accordingly.
The Contracting Officer will respond as required by the TD
clause.
If you have any questions, please contact me, or you may contact
Richard R. McNulty, Environmental Division, (509) 373,.9304.
ED:RRM
Mr. M. S. Spears 06-ED-016
cc w / attachs: M. N. Jaraysi, CH2M HILL P. C. Miller, CH2M HILL K.
Parnell, PAC C. R. Ungerecht, PAC Administrative Record
-3- MAR 10 2006
Environmental Safety and Quality
REPORT:
LOCATION: Hanford Site
ASSESSOR: Richard (Rick) McNulty, Lead Assessor Lori Huffman,
Assessor Gae Neath, Assessor
APPROVED BY: Jim Rasmussen, Division Director Environmental
Division
Executive Summary
The U.S. Department of Energy (DOE), Office of River Protection
(ORP) conducted an assessment of the CH2M HILL Hanford Group, Inc.
(CH2M HILL) implementation of DOE O 450.1, Environmental Management
Systems (EMS). Specific EMS requirements were incorporated into the
CH2M HILL contract through the Standard/Requirements and
Identification Documents (S/RID) process. Effectively, the EMS
documents show CH2M HILL complies with the Requirements Basis
(e.g., DOE Orders, S/RID) and the Environmental Basis (e.g.,
permits, Hanford Federal Facilities Agreement and Consent Order
[HFFACO], regulations) identified in the CH2M HILL-ORP
Authorization Basis Agreement.
This assessment was limited to validating CH2M HILL's certification
to ORP that its EMS has been implemented and incorporated into its
Integrated Safety Management System (ISMS). An annual evaluation of
the CH2M HILL EMS required by DOE 0 450.1 as a component of the
ISMS will be conducted by ORP during the next scheduled ISMS annual
review in July 2006.
CH2M HILL supported its EMS certification with a management
assessment which included one Finding and 13 Observations. As a
required component of its EMS system, CH2M HILL entered finding and
observations into its corrective actions system (Problem Evaluation
Request). ORP adopts CH2M HILL's management assessment finding and
observations. Additionally, ORP has adopted two Observations and
two Concerns from a 2005 Phase VPhase II Environmental Protection
Functional Areas S/RID Independent Assessment Report.
Prior to this assessment, ORP reviewed and commented on the draft
RPP-MP-003, ISMS Description, Revision 5 which integrated the CH2M
HILL EMS into its ISMS. ORP's comments are now closed and formal
approval of this ISMS revision incorporating DOE · comments is
expected shortly.
Prior to this assessment, ORP also reviewed and commented on
TFC-PLN-73 , Environmental Program Description, which describes the
CH2M HILL EMS identified in RPP-MP-003 . This Plan did not require
DOE approval and has been approved by CH2M HILL. The Plan addresses
all of the specified DOE O 450.1 requirements. Additionally, CH2M
HILL has an EMS management policy statement.
Based on prior extensive ORP staff reviews ofRPP-MP-003 and
TFC-PLN-73 and closure of DOE comments, ORP concludes that CH2M
HILL has successfully incorporated its EMS into the ISMS as
required by DOE O 450.1.
ORP assessed implementation of EMS requirements through a
substantial review of implementing policies, plans, procedures
identified in RPP-MP-003 , TFC-PLN-73, and independently identified
by the assessment team. This assessment concludes that
11
CH2M HILL has implemented its EMS with additional findings, and
observations which should be promptly addressed by CH2M HILL in its
corrective action process (the effectiveness of the EMS corrective
action system will be evaluated during the next annual ISMS
assessment).
Four Findings resulted from this assessment: 1) absence of formal
interface agreements with other Hanford contractors at EMS site
interfaces and/or failure to place such agreements under
configuration management; 2) inadequate identification of
implementing procedures with requirements in the Pollution
Prevention and chemical management program plans; 3) incomplete
update of field implementing procedures to reflect the new EMS and
EMS-IMS integration requirements; and 4) incomplete and ineffective
incorporation of the environmental and requirements basis of the
EMS (e.g., permit conditions, HFFACO requirements, environmental
regulation compliance) into implementing procedures. Two
Observations were made relating to training and environmental
oversight of subcontractors. One concern was made regarding
environmental staffing.
lll
Table of Contents
.............................................................................................................
iv
List of Acronyms
...............................................................................................................
v
DOE Assessment Results Derived from Prior Reviews
................................................. 9
Results of the ORP Assessment
.......................................................................................
9
Signature
....................................................................................................
: ..................... 13
l V
CH2M HILL CRD DOE EM EMS EP ESQ HFFACO HGET ISMS NEPA ORP P2 S/RID
TFC
List of Acronyms
'
V
CH2M HILL Hanford Group, Inc. (CH2M HILL) Environmental Management
System (EMS) Program Assessment
Background:
U.S. Department of Energy (DOE) 0 450.1, "Environmental Management
Systems," contains a contract requirements document (CRD) which,
when incorporated into the contract, requires a management
contractor to implement a documented and structured EMS and
incorporate their EMS into their Integrated Safety Management
System (ISMS). Additionally, the CRD mandates that the EMS
addresses specific environmental programmatic
requirements/components as appropriate ( e.g., wild fire
protection, watershed management).
The compete DOE O 450.1 CRD requirement was implemented into the
CH2M HILL contract without limitation or revision through the
"S/RIDS" process in March 2004. CH2M HILL was given one year to
fully develop and implement their EMS and incorporated the EMS into
the ISMS. CH2M HILL committed to the DOE Office of · River
Protection (ORP) to have a functioning EMS in place and integrated
into their ISMS by October 31, 2005 . Following a CH2M HILL
management assessment, CH2M HILL gave notice to ORP in November
2005 that their EMS had been successfully implemented, Enclosure
1.
The intent of DOE O 450.1 was to capitalize on existing EMS when
they existed, rather than invent new systems. Additionally,
Environmental Management (EM) facilities were authorized to utilize
a graded approach, when appropriate, in analyzing the environment
aspects of their operations and activities, and then identifying
the significant environmental impacts to be managed through the
EMS.
In consideration of the extraordinary external regulation of the
Tank Farms operations and facility management through the Hanford
Federal Facilities Agreement and Consent Order (HFF ACO), highly
conditionized environmental operating permits, concurrent
Comprehensive Environmental Response Compensation and Liability Act
management of the Hanford Site and the existence of extensive
National Environmental Policy Act (NEPA) site analysis, ORP
determined that a graded approach was appropriate to CH2M HILL. ORP
directed CH2M HILL to take credit for these environmental analyses,
studies, and controls in lieu of conducting new environmental
aspects and impacts analysis. A graded approach was not authorized
for pollution prevention (P2) requirements since these requirements
are minimally impacted through external regulation. ORP did not
require CH2M HILL to develop new EM systems. However, it was ORP's
expectation that CH2M HILL would coordinate and document their
existing EM systems into an integrated EMS, develop and document
interface controls for Hanford Site environmental interfaces, and
integrate their EMS into their ISMS.
RPP-MP-003, "Integrated Safety Management System," identifies three
components of the authorization basis agreement between CH2M HILL
and ORP: 1) Safety Basis;
6
2) Requirements Basis; and 3) Environmental Basis.
The Requirements Basis which CH2M HILL implements through
Standard/Requirements and Identification Documents (S/RID) includes
the specific EMS requirements derived from DOE O 450.1. The
Environmental Basis includes laws and regulations, NEPA
documentation, legal agreements (e.g., the HFFACO), and permits.
Thus, the CH2M HILL EMS must appropriate address both the
Requirements Basis and the Environmental Basis as defined by their
ISMS.
As stated in CH2M HILL Policy, TFC-POL-04, "Procedure Compliance
Expectations," procedures form the basis for the correct and safe
operation of Tank Farm Contractor (TFC) processes and facilities.
Procedures authorize activities within an authorization basis. CH2M
HILL requires mandatory procedural compliance. CH2M HILL maintains
configuration management over their procedures and electronically
publishes them on their intranet site. CH2M-HILL "procedures"
includes a variety of document classifications including policies,
plans, procedures, interface control documents, and miscellaneous
publications (e.g., documents adopted from other site
contractors).
Scope of Assessment:
DOE O 450.1 requires that the contractor's EMS be evaluated
annually as part ofDOE's line management annual review and
certification of the ISMS. This is not an annual ISMS certification
assessment (the next annual ISMS evaluation of CH2M HILL by ORP is
currently scheduled for July 2006). This assessment has the limited
purpose of validating, from a DOE prospective, CH2M HILL' s
certification that it has successfully implemented the CRD
requirements of DOE O 450.1. This assessment will be used as the
supporting documentation for a December 2005 declaration by the ORP
Manager that the CH2M HILL has implemented the applicable EMS
requirements ofDOE O 450.1.
DOE O 450.1 did not impose new substantive environmental standards
that were not already enforceable in CH2M HILL's contract. However,
DOE O 450.1 required a new level of formality, primarily by
requiring a system approach to EM and integration of the EMS into
the ISMS. This assessment looked for objective evidence that the
EMS described in RPP-MP-003 and TFC-PLN-73 has been implemented.
Since CH2M HILL Policy TFC-POL-04 requires procedural
implementation of the authorization basis, this assessment targeted
appro1imately 50 relevant implementing procedures (i.e., plans,
policies, procedures, and other controlled documents). These
procedures were picked for review based on self-identification in
RPP-MP-003 and TFC-PLN-73, because of internal references within
cited procedures, or because the·audit team determined that the
procedure has a rationale with the EMS.
Prior Reviews Considered by this Assessment:
In July 2005, ORP reviewed and commented on TFC-PLN-73,
"Environmental Program Description," which describes the CH2M HILL
EMS identified in RPP-MP-003. TFC PLN-73 did not require DOE
approval and CH2M HILL approved the document in
7
September 2005. CH2M HILL did revise the document based on ORP
comments prior to approval. The TFC-PLN-73 addresses all of the CRD
requirements of DOE O 450.1.
In September 2005, ORP reviewed and commented on the draft
RPP-MP-003, "Integrated Environmental, Safety, and Health
Management System Description," Revision 5 which integrated the
CH2M HILL EMS into their ISMS. ORP's comments are now closed and
formal approval of this ISMS revision incorporating DOE comments is
expected shortly. CH2M HILL also published an EM Policy Statement
which was reviewed by ORP and found adequate.
During 2005, CH2M HILL initiated as independent Phase I and Phase
II environmental S/RIDs Assessment. However, the work on the
independent assessment was terminated early due to funding issues
and the assessment was completed internal to CH2M HILL. This
assessment included observations and concerns.
CH2M HILL conducted a management assessment of their implementation
of the EMS in September 2005 and documented the results in CH2M
HILL Management Assessment Report No. FY 2005 ,-M-0147,
"Environmental Management System Implementation." On November 9,
2005 , CH2M HILL provided ORP the results of the EMS management
assessment and self-declared implementation of DOE O 450.1 ,
Enclosure 1. Enclosure 1 · concludes that the CH2M HILL EMS has
successfully integrated with TFC-PLN-73 and RPP-MP-003 and
appropriately integrated into applicable implementing documents/
procedures. Enclosure 1 notes one Finding and 13 opportunities for
improvement. These deficiencies were entered into the CH2¥ HILL
Corrective Action Program as PER-2005- 03661 and are pending
resolution and verified by ORP during its assessment.
Assessment Findings Adopted From Prior Reviews:
The following concerns and observations are adopted from the S/RIDS
assessment (See Enclosure 2):
Observation 2: Environmental Program (EP) requirements are not
flowed down in a consistent manner. Numerous requirements
throughout the S/RID are not specifically addressed in upper level
(administrative procedures), such as the TFC-ESHQ series. .
Although the majority of the requirements have some tie to this
procedural series, there are clear gaps between the administrative
procedures (TFC-ESHQ SERIES) and some key requirements.
Concern 2: Without the linkage between the base requirement and
implementing procedure or plan, there is no clear means to ensure
the requirement is being properly flowed down t9 appropriate
organizations that implement the specific requirement.
Observation 3: Many of the requirements that are addressed in the
administrative level (TFC-ESQH series procedures) do not appear to
flow down to the field procedures where a specific requirement gets
implemented. In the case of RPP-16922, Environmental Specifications
Requirements, specific requirements are
8
flowed down into field procedures; however, this covers only a
relatively small set of the requirements in the EP S/RID.
Concern 3: Without traceability of the base requirement from the
source to the field, it is difficult to verify the requirement is
actually being implemented. This requires management to rely on the
experience of key personnel as opposed to a clearly documented
program that is capable of ensuring compliant conditions during
times of personnel transition.
This assessment adopts the finding and 13 opportunities for
improvement identified in the CH2M HILL EMS Management Assessment,
Enclosure 2.
DOE Assessment Results Derived from Prior Reviews:
Based on prior comprehensive ORP staff reviews ofRPP-MP-003 and
TFC-PLN-73 and the closure of DOE comments thereto, ORP concludes
that CH2M HILL has successfully incorporated their EMS into their
_ISMS as required by DOE O 450.1. Implementation deficiencies
currently in the CH2M HILL Corrective Action Program are further
augmented by the ORP assessment results below.
Results of the ORP Assessment:
The ORP assessment plan is provided as Enclosure 3. The ORP
assessment results matrix is provided as Enclosure 4.
ORP has determined that CH2M HILL has substantively implemented
their EMS with additional finds, observations, and concerns which
are derived from Enclosure 4.
A required component of the EMS required by DOE O 450.1 is a
corrective action program providing for feedback and continuous
improvement. CH2M HILL has implemented a corrective actions process
described in TFC-ESHQ-Q-C-C-01, Problem Evaluation Request. As with
any new program with extensive requirements but few objective
performance standards, implementing shortfalls will be identified.
Provided that CH2M HILL appropriately utilizes their Corrective
Action Program to resolve such shortfalls, the existence of
findings, observations, and concerns in this assessment does not
constitute a programmatic failure to implement the EMS . ORP
expects CH2M HILL to make substantive progress in resolving the
deficiencies identified in this assessment in their Corrective
Action Program in advance of the 2006 annual ISMS assessment.
Failure of the corrective actions system to substantively and
timely address these deficiencies would be viewed as a failure of
the EMS system itself.
Finding 1: RPP-MP-003 and TFC-PLN-73 clearly demonstrate that CH2M
HILL understands and has adequately defined the scope of their
required EMS and has appropriately integrated the EMS into the
ISMS. TFC-PLN-73 provided a nominal roadmap of how the EMS and ISMS
are procedurally mapped together and implemented through
procedures. This assessment found that many implementing
engineering,
9
operations, and business management procedures have not been
upgraded to include the requirements basis and environmental basis
of the ISMS, or procedures were so poorly documented regarding EMS
requirements that effective field implementation of environmental
standards and requirements is not apparent. See Enclosure 4. For
example, the Maintenance Plan, the Conduct of Operations Plan,
Engineering Change Control Procedure, Equipment Temporary
Modifications and Bypass Procedure, Startup and Testing Program
Plan, the Configuration Management Plan, and the Operational
Readiness Review Program have not been upgraded to include the
requirements basis and the environmental basis of the ISMS
including identification of interfacing EMS implementing and
control procedures.
CH2M HILL adopted for use three comprehensive site EMS documents
which are nominally required to implement EMS requirements between
site contractors at site interfaces, HNF-PRO-15333, "Environmental
Protection Processes," HNF-PRO-15335, "Environmental Permitting and
Documentation Preparation," and HNF-PRO-15334, "Effluent and
Environmental Monitoring." However, CH2M HILL failed to implement
any of these requirements by incorporation into CH2M HLL procedures
as required by TFC-BSM-AD-C-04, "FH Documents Used by CH2M HILL
Hanford Group, Inc."
Finding 2: Paragraph 2.3.3 ofTFC-PLN-73 identifies RPP-16922,
"Environmental Specification Requirements," as the supporting
procedure for incorporating environmental requirements into
technical procedures. The assessment found RPP-16922 was not
comprehensive or complete, and almost no other field procedure
acknowledges RPP 16922 as a control standard or source for
environmental requirements as a component of the authorization
basis. Weaknesses were found in documenting procedures for
obtaining environmental permits (except air permits), HFFACO
administration and compliance, and environmental regulatory
compliance ( e.g. , most regulatory requirements are not actually
identified). While some non-Office of Environmental Safety and
Quality (ESQ) procedures identify a nominal ESQ interface, the
assessment team could find no ESQ procedure which effectively
mapped required ESQ interfaces into non-ESQ procedures although
some interfaces are identified in TFC-PLN-73. TFC-ESHQ-ENV-RM-D-02,
Resource Conservation and Recovery Act Operating Records, documents
environmental regulatory requirements which need to be mapped into
RP-16922, but the requirements list is incomplete (e.g., did not
include the 242 Evaporator, Bulk Vitrification Research and
Development, or the Integrated Disposal Facility) and had erroneous
compliance entries reflecting non applicability ( e.g., siting
requirements) . This finding is consistent with Observation 2 and 3
of the CH2M HILL S/RID Assessment adopted above.
Finding 3: CH2M HILL has a formal procedure for managing site
interfaces under configuration management, TFC-BSM-CP-CPR-C-17,
"Interface Management." Although significant environmental
interfaces exist between CH2M HILL and other site contractors and
environmental programs as described in the CH2M HILL EMS ( e.g.,
P2, environmental permitting and reporting, chemical management,
HFF ACO administration, and environmental monitoring), no
environmental interface agreements were found as either controlled
documents or otherwise published with CH2M HILL procedures
and
10
directives. TFC-PLN-73 identifies the existence of at least one
interface agreement which is not under configuration management as
such: Memorandum of Agreement, CNN-112822, "Re-Issuance of
Clarification of Contractor Responsibilities for Hanford Site
Groundwater Management." Procedures generally failed to acknowledge
the existence site interface agreements, the requirements of
interface agreements, or identify how CH2M HILL integrates with
site programs it has identified in the EMS (e.g., see Finding 4
below). If essential EMS interface agreements remain unpublished
and without configuration management, procedure managers will have
no technical basis to upgrade their implementing procedures to
reflect site EMS integration requirements. ORP recognizes that
informal site EMS interfaces do exist and site requirements are
currently managed through informal staff contacts and formal
information calls from the DOE Richland Operations Office. This
finding is consistent with Concerns 2 and 3 of the CH2M HILL S/RID
Assessment adopted above.
Finding 4: TFC-PLN-73 states that the CH2M HILL P2 Plan is
implemented through RPP-MP-612, "Pollution Prevention, /Waste
Minimization Program." Three pages of this six page procedure
describes elements of the Hanford Pollution Abatement Program
administered by another site contractor. There is no implementing
instruction on how or when CH2M HILL interfaces or integrates with
this site P2 Program. The remaining three pages of TFC-PLN-73
contain unsupported statements that CH2M HILL conducts a variety of
P2 activities without citation to any specific implementing
procedures or requirements (i.e. , the plan is not self
implementing). TFC-PLN-73 has not been upgraded to reflect DOE O
450.1 or new P2 S/RID requirements. When other implementing
procedures make reference to compliance with P2 requirements (e.g.,
engineering procedures), they typically reference only TFC-PLN-73
as the basis for the requirement.
Similar discrepancies were identified in TFC-PLN-58, "Chemical
Waste Management Plan." This plan asserts the existence of various
internal CH2M HILL controlled processes, but provides no cross
reference to specific procedures or implementing instructions
(i.e., it is also not self implementing). For example, Section 4.4
states CH2M HILL will track chemicals from acquisition, through
storage and use, to their final disposition but provides no
explanation of how this will be accomplished, how it will be
documented, or what staff element(s) exercises operation
responsibility for these activities. Furthermore, Section 6.0
states no records are generated in the performance of this plan
(e.g., if no records are generated, how are chemicals
"tracked"?).
TFC-PLN-58, Section 4.0 describes the existence of an unidentified
sitewide chemical management plan which has been "signed" jointly
by the Hanford site prime contractors. This interface agreement, if
it exists, is not published with the CH2M HILL procedures and is
not listed as a CH2M HILL interface control document. HNF-PR-10468,
"Chemical Management Process," is the current Hanford site EMS
chemical management plan. Howeyer, HNF-PR-10468 is not cited or
identified in TFC-PLN-58 and HNF-PR- 10468 has not been adopted for
use as required by CH2M HILL procedure HFC-BSM AD-C-04, "FR
Documents Used by CH2M HILL Hanford Group, Inc." If chemical
11
management integration with the Hanford site exists, it was not
apparent in review of the CH2M HILL procedures or this plan.
Despite the substantial inadequacies of both plans in failing to
associate implementing procedures with requirements, the assessment
found many topic specific implementing procedures documenting P2
and chemical management activities. See Enclosure 4. Unfortunately,
most procedures which logically should interface with P2 and
chemical management requirements (e.g., engineer procedures) do not
recognize the topical procedures ( e.g., asbestos management) as
requirements at all and only reference the plans. CH2M HILL can
substantially correct this finding by modifying the plans to
appropriately associate implementing procedures with
requirements.
TFC-OPSWM-D-16, "Management of Recycled Materials," requires
procedural compliance with HNF-EP-0863, another contractor's
document which was not available in the CH2M HILL procedures
database and has not been officially adopted as required by CH2M
HILL procedure, TFC-BSM-AD-C-04. TFC-BSM-CP-CPR-D-02.2, "Energy
Conservation and Efficiency," and TFC-PLN-73 erroneously claim
exemption from energy efficiency goals and standards alleging CH2M
HILL does not manage "facilities." CH2M HILL adopted HNF-PRO-15333,
"Environmental Protection Processes" which describes the site P2
Program and provides detailed P2 procedures. Although HNF-PRO-
15333 could potentially correct many deficiencies in the CH2M HILL
P2 Program, CH2M HILL failed to implement this Fluor Hanford, Inc.
document by incorporation into implementing CH2M HILL procedures as
required by HFC-BSM-AD-C-04.
Observation 1: DOE O 450.1 requires that the contractor provide EMS
training for the staff responsible for implementing the EMS. CH2M
HILL did not prepare a staff training matrix to document how it
accomplished EMS implementation training. Section 5.4 of TFC-PLN-73
cites the Hanford General Employee Training (HGET) Environmental
Module for general EMS training. However, a review ofHGET did not
reveal any meaningful training associated with EMS, even at the
familiarization level. There is a Waste Minimization Module which
does briefly address pollution abatement but that module is
optional. A review of various qualification standards identified in
TFC-PLN-07, "Dangerous Waste Training Program," identified a heavy
bias towards waste management activities but little discussion of
the other aspects of the EMS program.
Section 2.4 ofTFC-PLN-73 identified the basic and advanced
environmental qualification card for TFC environmental management.
Although the qualification card addresses many requirements and
authorization basis components and requires reading of the
Environmental Program Description, the qualification guide itself
does not require a demonstrated knowledge of the P2 program, the
EMS system, or ISMS-EMS integration.
Observation 2: TFC-ESHQ-ENV-AP-D-01 , Environmental Oversight of
Subcontractors, expressly excludes subcontractor work performed in
the tank farms. No corresponding procedure was found addressing
environmental oversight of onsite work performed by
subcontractors.
12
Concern: TFC-ESHQ-ENV -AP-01 , "Environmental
Surveillance/Compliance Inspection," assigns management of this
program is assigned to the Environmental Program Coordinator. That
position was recently terminated. The Environmental Program
Coordinator was also the designated EMS coordinator and the only
trained EMS auditor on staff. It is unclear how CH2M HILL will
provide meaningful oversight of the EMS program without adequate
trained staff.
Enclosure 1: CH2M HILL transmittal of EMS management
assessment.
Enclosure 2: S/RID assessment observations and concerns.
Enclosure 3: ORP Assessment Plan.
Enclosure 4: ORP Assessment Results Matrix.
Signature
13
Date
• CH2MHILL Hanford Group, Inc.
November 9, 2005
Mr. R. J. Schepens,Manager Office of River Protection U.S.
Department of Energy Post Office Box 450 Richland, Washington
99352-0450
Dear Mr. Schepens:
CONTRACT NUMBER DE-AC27-99RL14047 - IMPLEMENTATION OF THE U.S.
DEPARTMENT OF ENERGY ORDER 450.1, "ENVIRONMENTAL PROTECTION
PROGRAM," AT CH2M HILL HANFORD GROUP, INC. FACILITIES
Pursuant to the U.S. Department of Energy (DOE) Order 450.1,
"Environmental Protection Program," the U.S. Department of Energy,
Office of River Protection (ORP) and the U.S. Department of Energy,
Richland Operations Office are required to self-declare to the U.S.
Department of Energy-Headquarters that the Hanford Site has a
functional Environmental Management System (EMS) in place by
December 31, 2005. In support of the ORP's self-declaration, CH2M
HILL Hanford Group, Inc. (CH2M HILL) has implemented the
requirements of DOE Order 450.1.
CH2M HILL staff conducted a management assessment ( enclosed) to
assess CH2M HILL' s implementation of DOE Order 450.1 requirements.
The assessment was conducted between September 7, 2005, and October
3, 2005. Although the management assessment determined that a
functional EMS has been implemented, it identified 1 finding_ and
13 observations. The finding documents a concern with the flow-down
of requirements to control and phase-out ozone depleting substances
pursuant to Title 40, Code of Federal Regulations, Part 82. Even
though the control and phase-out requirements have been implemented
at Hanford and are reflected in Fluor Hanford, Inc. procedures,
they have not been included in CH2M HILL procurement or
environmental management procedures. The observations indicate
opportunities to improve implementation ofrequirements in areas
that are currently deemed satisfactory.
RECEIVED
CH2M-0503261
Should you have any questions regarding this matter, please contact
Mr. P. C. Miller at 373-1920.
Very truly yours,
kjs
Enclosure
cc: ORP Correspondence Control R. C. Barr, ORP J.E. Rasmussen, ORP
C. B. Reid, ORP T. Z. Smith, ORP
CH2M-0503261
Enclosure
Consisting of 28 pages, including coversheet
MANAGEMENT ASSESSMENT REPORT
Assessment No. FY2005-POPD-M-0147 Environmental Management System
Implementation
A management assessment on CH2M HILL's implementation of DOE O
450.1., "Environmental Protection Program" and Attachment 2 of the
order, titled "Contractor Requirements Document" (CRD), was
conducted between September 7 and October 3, 2005. This report
discusses the purpose, scope, and results of the assessment.
1.0 Executive Summary
DOE Order 450.1, Environmental Protection Program, hereafter
referred to as the Environmental Management System, has been
implemented at CH2M HILL Hanford Group, Inc. (CH2M HILL)
facilities. The requirements of DOE O 450.1 are implemented at CH2M
HILL through the Standards/Requirements Identification Document,
Management Plans, Policies, Charters, Environmental Requirements
Document, Emergency Plans, CH2M HILL procedures, and Hanford
site-wide plans and procedures.
This assessment resulted in one finding and 13 observations. A
finding has been developed concerning the £lowdown of requirements
to control and phase-out Ozone Depleting Substances pursuant to 40
CFR 82. Although the requirement has been implemented at Hanford
and is reflected in Fluor Hanford procedures, the requirement has
not been included in the CH2M HILL procurement or environmental
management procedures.
2.0 Purpose
This assessment evaluated CH2M HILL's implementation of DOE O
450.1, "Environmental Protection Program" and Attachment 2 of the
order, titled "Contractor Requirements Document" (CRD), which
imposes specific requirements on CH2M HILL. These requirements are
intended to ensure integration of a structured Environmental
Management System (EMS) within the Integrated Safety Management
System (ISMS). CH2M HILL has committed to DOE Office of River
Protection to have a functioning EMS in place by October 31, 2005.
This assessment supports senior management' s verification to DOE
ORP that an EMS is in place.
DOE is required to "self-declare" to DOE Headquarters that the
Hanford site has a functional EMS in place by December 31, 2005.
ORP has indicated that it will perform an assessment of CH2M HILL's
EMS in November 2005. CH2M HILL's assessment supports preparation
for the ORP assessment.
3.0 Scope
The assessment looked for evidence that the applicable elements of
the CRD have been incorporated into the Standards and Requirements
Document, flowed down into policies, procedures and plans (as
appropriate), and implemented in the field. The assessment also
evaluated how well the EMS itself is described in program
documentation, and how well it is understood by tank farm
contractor (TFC) staff and management.
4.0 Assessment Approach and Methodology
The assessment (Attachment 1, Management Assessment Plan
FY2005-POPD-M-0147) consisted of document reviews, interviews, and
record reviews. Documents were reviewed for mention of the
applicable EMS elements, and evidence of a structured,
well-integrated EMS. Interviews were conducted to assess awareness
of EMS, the related Environmental Management Policy (TFC-POL-30),
and implementing plans and procedures that comprise the EMS.
Records were reviewed for confirmation that proceduralized
requirements are being implemented.
5.0 Assessment Results
The Environmental Management System has been integrated within
TFC-PLN-73, Environmental Program Description, and RPP-MP-003,
Integrated Environment, Safety, and Health Management System
Description for the Tank Farm Contractor. TFC-PLN-73 contains a
roadmap which cross-references DOE O 450.1 EMS elements with
elements contained within RPP-MP-003 . TFC-PLN-73 also contains a
listing, by element, of the applicable implementing documents.
Additionally, aspects of the Environmental Management System have
been included in the Tanlc Farm Documented Safety Analysis (DSA) as
Defense-In-Depth attributes .
The requirements of State of Washington issued Resource
Conservation and Recovery Act (RCRA) permits, State Waste Discharge
Permits, Hanford Air Operating Permit, and various toxic and
radiological contaminant air operating permits have been
implemented and incorporated in procedures and plans. -
A recently completed Phase I and Phase II assessment of the CH2M
HILL Tanlc Farm S/RIDs indicated that the requirements of the
S/RIDS have been implemented at Tank Farms. The assessment did
reflect that additional evidence was required to prove compliance
with some requirements. The assessment also indicated that there
are several requirements contained within the Tank Farm S/RID that
are not applicable and recommended the deletion of the subject
requirements. The recommended corrective actions are pending.
A finding has been developed concerning the flowdown of
requirements to control and phase-out Ozone Depleting Substances
pursuant to 40 CFR 82. Although the requirement has been
implemented at Hanford and is reflected in Fluor Hanford
procedures, the requirement has not been included in the CH2M IDLL
procurement or environmental management procedures.
6.0
The review of applicable documentation indicates that DOE O 450.1
has been satisfactorily implemented at CH2M HILL facilities.
Although satisfactorily implemented, there are 13 opportunities for
improvement. There is one finding. Attachment 2 provides the
assessment criteria, documentation, and the observations.
Attachments 1. Management Assessment Plan No. FY2005-POPD-M-0147 2.
EMS Assessment Documentation
Management Assessment by:
Assessment Lead: Phil Miller Manager, Environmental Support and
Assessment CH2M HILL Environmental Compliance Officer
Assessment Team: Lucinda Borneman
John Doughty Environmental Support and Assessment
John Guberski Environmental Compliance and Support
Cynthia Stratman Waste Services
Consisting of 3 pages, including coversheet
MANAGEMENT ASSESSMENT PLAN
Purpose
Scope
This assessment evaluates CH2M HILL's implementation of DOE O
450.l, "Environmental Protection Program." Attachment 2 of the
order, titled "Contractor Requirements Document" (CRD), imposes
specific requirements on CH2M IDLL. These requirements are intended
to ensure integration of a structured environmental management
system (EMS) within the Integrated Safety Management System. CH2M
illLL has committed to DOE Office of River Protection to have a
functioning EMS in place by October 31, 2005. This assessment
supports senior management's verification to DOE ORP that an EMS is
in place.
DOE is required to "self-declare" to DOE Headquarters that the
Hanford site has a functional EMS in place by December 31, 2005.
ORP has indicated that it will perform an assessment of CH2M HTLL's
EMS in November 2005 . CH2M HILL's assessment supports preparation
for the ORP assessment.
The assessment will look for evidence that the applicable elements
of the CRD have been incorporated into the Standards and
Requirements Document, flowed down into policies, procedures and
plans (as appropriate), and implemented in the field. The
assessment will also evaluate how well the EMS itself is described
in program documentation, and how well it is understood by TFC
staff and management.
Assessment Team
Assessment Lead:
Assessment Team:
Support Team:
Lucinda Borneman Environmental Lead, Analytical Technical Services
Environmental Compliance Officer for A TS Has completed training
and qualification as Assessment Team Lead
John Doughty Environmental Support and Assessment Has completed
training and qualification as Assessment Team Lead
John Guberski Environmental Compliance and Support No TFC
assessment training
Cynthia Stratman Waste Services Completed Course No. 350318 "TFC
Assessment Training"
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Assessment Schedule
The assessment is to be conducted between September 7 and September
30, 2005. Completion includes issuance of final management
assessment report.
Performance objectives and criteria, including source information
used to perform the assessment, and implementing documents and
checklists developed
The source document is DOE O 450.1, Attachment 2
Primary review documents are:
• TFC S/RID, chapters 16 and 20 • RPP-MP-003 • TFC-PLN-73 (draft) •
TFC-PLN-58 • RPP-MP-612 • TFC-POL-16 • TFC-POL-30 •
TFC-POL-10
This assessment evaluates the integration of EMS elements into the
ISMS, and will touch on all Core Functions and Guiding
Principles.
Assessment Approach and Methodology
The assessment will consist of document review, interviews, and
records review. Documents will be reviewed for mention of the
applicable EMS elements, and evidence of a structured, well
integrated EMS. Interviews will be conducted to assess awareness of
EMS, the related Environmental Management Policy (TFC-POL-30), and
implementing plans and procedures that comprise the EMS. Records
will be reviewed for confirmation that proceduralized requirements
are being implemented.
Assessment Plan by:
Signature of Team Leader's Manager Date
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MANAGEMENT ASSESSMENT REPORT
Environmental Management Assessment Documentation and
Observations
Consisting of 21 pages, including coversheet
Criteria DOE O 450.1, Environmental Protection Program Regardless
of the performer of the work, contractors with this Contractor
Requirements Document (CRD) incorporated into their contracts are
responsible for (1) compliance with the requirements of the CRD and
(2) flowing down the requirements of the CRD to subcontracts at any
tier to the extent necessary to ensure the contractors' compliance
with the requirements.
Contractors must: 1. General Requirements. Ensure their
integrated safety management systems (lSMSs) include environmental
management systems (EMSs) that do the following.
(a) Provide for the systematic planning, integrated execution, and
evaluation of programs for-
EMS Assessment
Documentation and Observations MP-003, Section 4.4.4,
"Subcontractor ISMS Flowdown" specifically addresses Flowdown of
requirements. While it does not specifically identify the CRD, it
does describe the mechanism for ensuring all applicable
requirements are flowed down. It cites
- RPP-8411 , "CH2M HILL Hanford Group, Inc. - Procurement Process
Description," generically states that prime contract requirements
will be flowed down, ·
- TFC-BSM-CP _ CPR-C-05, Procurement of Services - section 4.2,
requires BTR to evaluate work scope and ensure review by
appropriate SMEs; expectation is that environmental SME will ensure
CRD requirements are flowed down in the SOW as appropriate, and
that appropriate oversight is identified to ensure
compliance.
- TFC-BSM-CP _ CPR-C-06, Procurement ofltems (Materials) - - BTR
Process - TFC-ESHQ-ENV _AP-D-01, "Environmental Oversight of
Subcontractors" -
subcontracted work not controlled by the TFC work control process
is monitored using this oversight process, as well as S&H
oversight process.
Section 4.5.2, last paragraph cites BTR process· as administrative
control to ensure Flowdown
Section 4.6.2, states that the environmental and waste services
programs are responsible for flowing down applicable requirements
to subcontractors.
Result: Satisfactory
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Criteria public health and environmental protection,
Documentation and Observations MP-003 - References to systematic
planning and integrated execution and evaluation begin in Section
1.1 with restating of the contractual requirement - "requires CH2M
HILL to accomplish work " ... in a manner that achieves high levels
of quality, protects the environment and the safety and health of
workers and the public, and complies with requirements. "
Systematic planning is discussed in detail in Chapters 4.4, 4.5,
and 4.6.
Observation 1: The ISMS matrix for chapter 4.5 could be improved by
adding the "Field Implementation of Env permits" procedure and the
procedure covering project mgt of expense funded projects.
Integrated execution is discussed in Chapter 4.7. Evaluation is in
Chapter 4.8
Observation 2: ISMS matrix - move SCI procedure from ·core Function
3 to core function 5
TFC-POL-30 and HNF-1773 (precursor to TFC-PLN-73) are called
out.
Observation 3: Need to update -003 to callout TFC-PLN-73
TFC-POL-30 identifies responsibility to consider protection of
public health and environment
TFC-PLN-73 Identifies mechanisms that the environmental
organization uses to ensure public health and any protection is
considered in planning, execution and evaluation.
No deficiencies noted.
Observation 4: May be more effective if TFC-PLN-73 identified and
discussed specific implementing procedures in the body of the
report.
Consider moving EMS discussion to MP-003; it may be appropriate to
have the entire EMS described in one place, and MP-003 is where
that would belong.
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compliance with applicable environmental protection
requirements.
(b) Include policies, procedures, and training to identify
activities with significant environmental impacts, to manage,
control, and mitigate the impacts of these activities, and to
assess performance and implement corrective actions where
needed.
Documentation and Observations
Based on this review, it appears that the ISMS/EMS adequately
provides for systematic planning, integrated execution, and
evaluation of programs for public health and environmental
protection.
MP-003 This is a subset of "public health and any protection" as
addressed above. The S/RID process is specifically cited in section
2.1.2, and discussed in detail in section 4.6.1. The role of the
S/RID in the evaluation process is mentioned in section
4.8.3.
Result: Satisfactory
Specific policies and procedures are cited in MP-003 and the
associated EMS documents. Between MP-003 and TFC-PLN-73, all
environmental protection policies, plans and procedures (and
standards) are listed.
TFC-POL-30 and TFC-POL-1 Oare the policies.
The procedures driving implementation are the two project
management procedures TFC-PRJ-PM-C-02, "Project Management for DOE
O 413.3 Projects" TFC-PRJ-PM-C-11, "Project Management for Hanford
Tank Waste Cleanup Expense Funded Projects"
These require consideration of environmental requirements, the need
for permits, and NEP A/SEPA and natural/cultural resources. This
will drive identification of activities with impacts, and
development of appropriate controls.
The two PM procedures in conjunction with the TFC Work Control
procedure drive implementation of the environmental procedures and
standards, ensuring that the TFC will identify activities with
significant environmental impacts, to manage, control, and mitigate
the impacts of these activities, and to assess performance and
implement corrective actions where needed.
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(c) Include measurable environmental goals, objectives, and targets
that are reviewed annually and updated when appropriate.
Documentation and Observations For subcontracts, the Procurement of
Services and Procurement of Items (Materials) procedures drive
involvement of environmental subject matter experts, which we rely
on to ensure that the TFC will identify activities with significant
environmental impacts, manage, control, and mitigate the impacts of
these activities, and assess performance and implement corrective
actions where needed.
MP-003 discusses policies and procedures to assess performance and
implement corrective actions in section 4.8. rt cites the CH2M HILL
assessment program implementing documents as well as the
Environmental SCI procedure.
Result: Satisfactory
TFC-PLN-73 includes specific discussion of environmental goals.
Because CH2M HILL has used a graded approach, the goals are, for
the most part, addressed outside the scope of the ISMS/EMS, coming
instead from the TPA process. A snap-shot of relevant TP A goals
was prepared during implementation of the EMS.
Observation 5: There is no TFC controlled process in place to
ensure periodic review and update of the TFC-related TP A
goals.
Other goals cited in TFC-PLN-73 include the P2 goals and the
monthly performance indicators.
P2 goals are identified by DOE and communicated by FH. Goals are
established annually in accordance with MP-612.
Observation 6: MP-612 appears to warrant review and update.
The environmental performance indicators track environmental
releases, regulator citations (NOCs and NOVs), and TPA milestone
compliance status. These are established at the company level (VPs)
and tracked on a monthly basis. This process is governed by
TFC-PRJ-PC-C-11, "Performance Indicator Program."
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Criteria Documentation and Observations
2. Integration of an EMS into ISMS. As part of integrating EMSs
into their ISMSs, do the following.
(a) Consider the following for inclusion as applicable:
Conformity of DOE proposed actions with State Implementation Plans
to attain and maintain national ambient air quality
standards,
implementation of a watershed approach for surface water
protection,
implementation of a site-wide approach for groundwater
protection,
MP-003 , Section 4.8.2 states "The TFC publishes a monthly report
of performance indicators (f'FC-PRJ-PC-C-11, "Performance Indicator
Program "), which meets the objectives of DOE O 210.1. Annually,
senior management establishes goals to achieve the mission in a
safe manner (discussed in Section 4. 4. 1). "
CCN-112822, "Re-Issuance of Clarification of Contractor
Responsibilities for Hanford Site Groundwater Management"
The Central Environmental CoW1cil, a consortium of Hanford site
prime contractors, has issued a document describing its
understanding of roles and responsibilities relating to groW1dwater
protection at the Hanford site. The docwnent has been signed by
representatives of the participating prime contractors and
submitted to the DOE.
Observation 7: Assessors could find no TFC implementing documents
for TFC roles and responsibilities identified in CCN-112822.
Though not directly referenced in the ISMS, it is referenced in
TFC-PLN-73, and is considered part of the EMS.
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protection of site resources from wildland and operational fires,
and
protection of cultural resources.
(b) promote the long-term stewardship of a site ' s natural and
cultural resources throughout its operational, closure, and post
closure life cycle;
Documentation and Observations This is implemented through the NEPA
procedure, and driven by the two project management procedures and
the TFC work control procedure.
Confirmatory records are EISs and related documents, categorical
exclusions, completed work packages that indicate consideration of
natural resources, and PNNL letters addressing TFC requests review
of natural and cultural resources.
Result: Satisfactory
The TFC supports the Hanford Fire Department (FH) in the
implementation of this activity. Specific activities addressing
prevention of wildland and operational fires are found in
TFC-ESHQ-FP-STD-01.
Result: Satisfactory
This is implemented through the NEPA procedure, driven by the two
project management procedures and the TFC work control
procedure.
Records generated include cultural resource reviews.
This is implemented through the NEPA procedure, driven by the two
project management procedures and the TFC work control
procedure.
PNNL implements the program on a site wide basis. The TFC supports
this effort by ensuring related issues are addressed when
appropriate.
No deficiencies noted.
Criteria (c) reduce or eliminate
a. the generation of waste, b. the release of pollutants to
the environment, and c. the use of Class I ozone
depleting substances (ODS)
through source reduction, re-use, segregation, and recycling, and
by procuring recycled content materiaJs and environmentally
preferable proaucts and services;
Documentation and Observations Source reduction, re-use,
segregation, and recycling : TFC-PLN-33 documents and implements a
Facility Waste Management Strategy that specifically includes
source reduction and waste segregation as means of reducing or
eliminating waste. It also addresses management of recycled
materials. The primary record generated is the waste planning
checklist (TFC-OPS-WM-C-01, "Waste Planning Checklist").
Source reduction and segregation are applied to in-tank waste
through engineering procedures that address stability of tank
wastes, waste transfer, and evaporator campaigns. TFC relies on
environ.mental review (TFC-ESHQ-Q_INSP-C-05) of related engineering
documents and wo.rk packages to ensure that source reduction and
segregation are considered.
"Procurement of Services" and "Procurement of items (Materials)"
both drive review and approval of pertinent requisitions by S&H
and Environmental. S&H has responsibility for the chemical
management program which is implemented through TFC-PLN-58 .
"Procurement of Services" ensures that this EMS element is applied
to subcontractors that use chemical products on the Hanford
site.
TFC-BSM-CP _ CPR-D-01.2, "Recovered/Recycled Materials," implements
federal guidance regarding purchase of recycled/recovered content
materials and environmentally preferable products. The record
generated by this desk instruction is the "Justification of
Procurements not meeting recovered/recycled content
requirements."
3. Update approved ISMS descriptions as TFC-PLN-73, Environmental
Program Description, and RPP-MP-003, Integrated necessary to
include EMS Environment, Safety, and Health Management Systems
Description for the Tank Farm requirements of this CRD.
Contractor.
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l o
0 H
C I-
requirements under Executive Order 13148 by ensuring, where
appropriate, implementation of centralized procurement and
distribution programs (e.g., pharmacy) for purchasing, tracking,
distributing, and managing materials with toxic or hazardous
content at facilities under their purview.
5. Monitor progress toward meeting the P2 requirements of paragraph
2c above, and make such information available annually to the DOE
operations/field/site office.
Documentation and Observations The procurement process within CH2M
HILL addresses the control of purchasing the purchasing chemicals
with toxic or hazardous content. Chemicals are prohibited from
purchasing with a P-Card in the attachment A to the procedure,
Purchasing Card (P Card), TFC-BSM_ CPR-C-01, rev. D. Chemicals are
purchased in accordance with procedure Procurement of Items
(Materials), TFC-BSM-CP-CPR-C-06, REV F-2. Formal Environmental
approvals are required for radioactive material and items that
involve the potential to release emission to the environmental
(e.g., chemical or chemical waste storage tanks, chemical detectors
or monitoring equipment, sampling pumps, etc.). IH and Chemical
Management approval is required for the purchasing of potentially
harmful chemicals/substances or hazardous materials, acids, or
items that will result in the release of any regulated
constituent.
Other procurement procedures that specify environmental or chemical
management approvals of chemicals can be found in the following
procedures: TFC-BSM-CP-CPR-C-01, Purchasing Card (P-Card)
TFC-BSM-CP-CPR-C-03, BTR Process TFC-BSM-CP-CPR-C-05, Procurement
of Services TFC-BSM-CP~CPR-C-06, Procurement of Items (Materials)
TFC-BSM-FPM-C-01 , Material Receipt, Issuance, Return and Excess
Control
Observation 8: The Environmental Program Description, TFC-PLN-73,
REV.A, did not appear to address purchasing or procurement of
materials with toxic or hazardous content. Responsibility for this
process is does not fall to one organization, so this element needs
to be more clearly addressed in RPP-MP-003.
CH2M HILL is currently conducting two pollution prevention
operational assessments. The operational assessments will be
submitted to ORP in January 2006. An additional assessment is
scheduled as part of the annual Waste Services Fiscal Year 2006
assessment.
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acquisition of supplies to cost effectively maximize procurement of
environmentally preferable products. As appropriate, all
acquisitions must be coordinated with the DOE operations/field/site
office "Green Acquisition Advocate." (See Acquisition Letter
AL-2000-03, dated 05/16/00)
Documentation and Observations The integration of a Pollution
Prevention program into the policies, procedures, and plans to be
implemented in the field is comprehensive. The flow of pollution
prevention activities is evident in the documents reviewed.
Good Practices:
• The Procurement process identifies the need to incorporate
pollution prevention into procurement activities of goods or
services.
• The internet page (
http://www.hanford.gov/chgcp/ProcurementProcedures.cfm) providing
assistance to procurement provides a list of procedures applicable
to solicitation. The procedures listed include pollution
prevention.
• CH2M HILL facilitates the WTP recycle program. • Recycling is
referenced in the waste management and planning documents used
by
CH2M HILL.
Observation 9: Although procurement procedures require
implementation of pollution prevention and waste minimization there
is not a requirement to provide a product evaluation before
procurement.
Procedures Reviewed
TFCBSM-CP _ CPR-P-01 - Procurement Planning - Includes planning for
energy conservation and pollution prevention.
TFC-PRJ-CM-C-01 Construction Management - references
RPP-MP-612
TFC-OPS-WM-D-16 MANAGEMENT OF RECYCLABLE MATERIALS GENERA TED AT
TANK FARM FACILITIES - This guidance document describes handling
and management of.recyclable materials generated at tank farms
facilities to
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Criteria Documentation and Observations ensure compliance with the
Hanford Site recyclable material management plan. Several
recyclable materials streams, such as aerosol products, batteries,
and light ballasts with dioctyl phthalate (DOP) capacitors, are
generated at the tank farins facilities. Several
collection/drop-off points are set up at the 200 East and 200 West
Areas for operations and maintenance personnel and electricians for
the material they generate. These materials will be collected on a
regular basis and transferred to the 616 storage pad. The materials
are segregated, packaged, and shipped to the Centralized
Consolidation/Recycling Center (CCRC) at the 400 Area. At the CCRC,
the materials are evaluated, consolidated, and shipped to off-site
recycling contractors.
The Washington State Department of Ecology has concurred with the
management plan for recyclable materials administered by the CCRC.
In the plan, the recyclable material would not be considered to be
solid waste until it was received at the CCRC where the
determination is made concerning the material's disposition. Tank
farms, as a generating facility, ensures compliance with the CCRC
plan. Acceptance criteria for receipt of recyclable material at the
CCRC is identified in Attachment A.
The process includes generation, collection and accumulation,
segregation, packaging, and shipping of recyclable material
generated at the tank farms facilities to the CCRC at the 400 Area.
The plan also ensures compliance with the Hanford Site recyclable
material management plan, CCRC acceptance criteria, and
transportation to the CCRC.
TFC-OPS-WM-C-01- WASTE PLANNING CHECKLIST-This procedure describes
the process for completing and approving a Waste Planning
Checklist. This procedure applies only to tank farms waste
generating activities associated with containerized solid waste. It
does not apply to the management of tank waste.
This procedure applies to -activities that generate low-level
radioactive waste, mixed waste, non-radioactive dangerous waste,
non-regulated waste, and recyclable materials.
The Waste Planning Checklist is required per TFC-PLN-33 to ensure
waste is designated, segregated, and packaged in compliance with
state and federal regulations, and to ensure it meets the
treatment, storage, or disposal (TSO) receiving facility's
acceptance criteria for packaged waste. (7_1.2)
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Criteria Documentation and Observations This procedure is
implemented in accordance with the core functions and guiding
principles of RPP-MP-003. The plan describes the ISMS structure,
policies, programs, processes, and implementing mechanisms to
ensure that protection of the environment and safety and health of
the workers and the public, and quality are integrated into
management and work practices.
TFC-OPS-MAINT-C-01-TANK FARM CONTRACTOR WORK CONTROL This
procedure defines work management from initiation of a work request
through work order closeout. It specifies when formally written
work instructions are required; and it specifies the degree of
planning required. This procedure uses a graded approach to
implement requirements and to provide the level of discipline
required to perform work in a manner thus protecting the workers,
the environment, and the public.
This procedure applies to all Tank Farm Contractor (TFC) personnel
who schedule, plan, approve, release, perform operations acceptance
or post review using work orders. This procedure applies to
corrective maintenance, preventive maintenance, troubleshooting,
modification, fabrication, select operational activities, and
certain construction on structures, systems, and components at tank
farms. This procedure does not cover operator rounds, radiological
surveillances, or other operational activities specified in
technical procedures.
Contractors for projects will perform work using their planning
processes with release through the TFC Work Release for
Construction/Service Organizations form (A-6003- 532), or using
this process, dependent on the Notice of Intent (see
TFC-PRJ-CM-C-07).
Subcontractors performing work in non-operational facilities, such
as office buildings, or in non-TFC controlled facilities, must have
the facilities manager or representative authorize the start of the
work, but are otherwise exempt from this procedure.
References the Waste Planning Checklist
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'1: .. <C (I
Criteria Documentation and Observations TFC-POL-10 - POLLUTION
PREVENTION AND WASTE MINIMIZATION POLICY - Operations and
activities shall be conducted in a way that minimizes the quantity
and toxicity of wastes generated, eliminates or minimizes pollutant
releases to the environment, and minimizes the use of toxic
substances. This shall be done by designing waste
minimization/pollution prevention into new products and processes,
through affirmative procurement, and by integrating waste
minimization/pollution prevention into changes in technologies and
existing policies and procedures.
RPP-MP-612 -POLLUTION PREVENTION/WASTE MINIMIZATION -This
management plan establishes requirements and guidelines for CH2M
HILL Hanford Group (CHG) to comply with federal, state, and
Department of Energy (DOE) pollution prevention and waste
minimization requirements.
This management plan also describes the CHG pollution prevention
program to be implemented in compliance with pollution prevention
and waste minimization requirements contained in WAC 173-303; 40
CFR 262, 264, and 265; 10 CFR 435; DOE 0 5400. I; and DOE O
5820.2A. The requirements of this plan apply to projects with
responsibility for implementing the CH2M HILL pollution prevention
program, includirig all dangerous, radioactive, mixed, and sanitary
waste generators.
TFC-PLN-33- WASTE GENERATING PLAN -This plan describes the
management activities of waste and recyclable material that is
generated at the tank farms and associated facilities . This plan
applies only to waste generating activities associated with
containerized solid waste. This plan does not apply to the
management of tank waste.
1. TFC-PLN-58 - CHEMICAL MANAGEMENT PLAN - Integrates the chemical
management program with the infrastructural functions that are
necessary to support and control chemical management at CH2M HILL,
including:
• Procurement • Environmental
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7. Conduct operational assessments, such as Pollution Prevention
Opportunity Assessments, of site operations to identify
opportunities for source reduction, material segregation,
recycle/reuse, or other P2 projects. Based on the results of these
assessments, implement cost-effective P2 projects, using life-cycle
assessment concepts and practices in determining
return-on-investment.
Documentation and Observations TFC-PLN-37 - CH2M HILL RADIOACTIVE
WASTE MANAGEMENT BASIS Waste Minimization and Pollution
Prevention
(4.1.1 , 4.1.2, 4.1.7, 4.1.8,.4.1.1 0)
RPP-MP-612, "Pollution Prevention/Waste Minimization," describes
waste minimization and pollution prevention at tank farms.
CH2M HILL is currently conducting two pollution prevention
operational assessments. The operational assessments will be
submitted to ORP in January 2006. An additional assessment is
scheduled as part of the annual Waste Services Fiscal Year 2006
assessment.
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appropriate, to • support the site's ISMSs, • to detect and
characterize
releases from DOE activities; • assess impacts; • estimate the
dispersal patterns in
the environment; • characterize the pathways of
exposure to members of the public;and
• characterize the exposures and doses to individuals, and to the
population; and
• to evaluate the potential impacts to the biota in the vicinity of
the DOE activity.
Documentation and Observations Conduct environmental monitoring, as
appropriate. Monitoring of effluents from Tanlc Farm Contractor
facilities is effectively implemented by various processes. These
processes collectively detect and characterize releases; assess
their impacts on workers, public and biota; identify the dispersal
patters and associated exposure pathways; and relate this to
exposures and doses to individuals and the population. Documents
reviews and personal knowledge were the assessment methods. Further
detail is discussed below using TFC-PLN-73, Environmental Program
Description, Section 2.9, bullets.
2.9 a not assessed at thls level
2.9 b not assessed at this level
2.9 c Pre-operational m01tltoring is conducted to characterize
baseline values against which impacts of Tank Farm Contactor
activities are measured. This is accomplished by the ongoing
program of effluent monitoring supplemented as necessary with site
specific monitoring. Site specific monitoring is normally limited
to a biological review for threatened or endangered species. The
far and near field monitoring programs conducted by the PHMC per
reference 5 provide the ongoing characterization data. The
Automated Bar Coding of All Samples at Hanford [ ABCASH] data base
is the information repository for these programs as well as data
collected from Tank Farm Contractor facilities per reference 8.
ABCASH provides periodic reports [Quarterly Anomaly Report] that
identify adverse trends in environmental impacts to biota and the
public. This is done by identifying concentrations of radionuclides
that have changed beyond a trigger level. The PHMC provides the
report to the Tank Farm Contractor for investigation of facility
related items. The PHMC investigates non-facility related items.
The Problem Evaluation Request process would be the means to
initiate response to an anomaly that impacts the environment.
The following documents also are involved:
TFC-ESHQ-ENV-STD-05, Radioactive Airborne Effluent Sampling
RPP-QAPP-004, NESHAP Quality Assurance Program Plan/or Tank Farm
Contractor Radioactive Air Emissions
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Criteria Documentation and Observations Observation 10: The QAPP
was last revised four years ago; recommend it be reyiewed and, if
needed. updated.
2.9 d This element is similar to 2.9 c and that discussion applies
here also. In addition, TFC-ESHQ-S_IH-P-09, Industrial Hygiene
Personal/Area Exposure Monitoring, provides data on
non-radiological releases. Also, various radiological program
procedures, used to meet DOE Order 435.1, provide methods that
assist in detecting, characterizing, and responding to releases
from DOE activities. No formal process for providing this
information to the environmental organization was identified. In
practice, the radiological control organization has provided
radiological monitoring data to the environmental organization to
assist in the characterization of detected releases and
identification of appropriate environmental response. The airborne
releases for the C-200 series hose-in-hose radiological
contan1ination and the C-201 Articul~ted Mast System airline
radiological contamination are two recent instances where
information was provided to environmental to assess impacts to the
environment where a release to the environment [air] occurred.
RPP-13033 , Tank Farms Documented Safety Analysis, HNF-14755, 242-A
Evaporator Documented Safety Analysis, HNF-12125, 222-S Laboratory
Documented Safety Analysis, all provide information on the type and
quantities of materials that could be released in an accident and
estimated impacts on individuals and the population. New projects,
such as Demonstration Bulk Vitrification, are similarly evaluated
and the information included in one of these documents or· a new
document.
2.9 e The near and far field monitoring programs discussed in 2.9.c
apply. The core of the program is the additional documents
identified in 2.9.c.
Observation 11: A review of the last few ABCASH anomaly reports
identjfied repeated errors in some of the data. Some of these are
human errors, others are due to differences in how the radiological
and environmental organizations view a particular data item. This
is an area for follow-up.
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9. Ensure the analytical work supporting environmental monitoring
is implemented using-
( a) a consistent system for collecting, assessing, and documenting
environmental data of known and documented quality;
Documentation and Observations 2.9 f DOE has a contract with PNNL
to conduct meteorological data gathering for Hanford. PNNL and the
PHMC then assemble this data, along with historical near and far
field monitoring data to prepare various documents that estimate
dispersal patterns in the environment. These include:
DOE-RL-2005-06, Radionuclide Air Emission Report for the Hanford
Site, Calendar Year 2004 HNF-EP-0527-14, Environmental Releases for
Calendar Year 2004 HNF-3602, Calculating Potential to Emit Release
and Doses for Facility Effluent Monitoring Plan and Notice of
Construction
2.9 g See reports discussed in 2.9 f
2.9 h See 2.9 f, HNF-EP-0527.
2. 9 i through knot assessed
Two environmental monitoring processes were investigated for this
assessment, Air monitoring and Groundwater monitoring.
Both monitoring programs are managed by a centralized program; FH
managed the air monitoring program, and PNNL manages the
groundwater monitoring program. CH2M HILL provides air samples to
the laboratory to be analyzed in accordance with the established
protocols of the air monitoring program as established in the QA
Project Plan for the NESHAPS Air Monitoring. PNNL collects
groundwater samples and submits those samples to laboratories to be
analyzed in accordance with the established protocols as found in
the QA Plan for the Groundwater Monitoring Program.
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Criteria (b) a validated and consistent approach
for sampling and analysis of radionuclide samples to ensure
laboratory data meets program specific needs and requirements
within the framework of a performance-based approach for analytical
laboratory work; and
( c) an integrated sampling approach to avoid duplicative data
collection.
10. Develop and implement a program and procedures to maximize the
use of safe alternatives to ODS whereby-
Documentation and Observations The air program assures consistency
in the effluent monitoring program through the Environmental
Monitoring Plan (DOE/RL-91-50, rev. 3). Consistency in analysis is
assured through the use of a single QAPP for program and the
Statement of Work for the Waste Characterization and Sampling
Facility, the laboratory at which the analyses are perfonned
(HNF-EP-0835, rev. 11). CH2M HILL carries the QA requirements into
their internal document , NESHAPS Quality Assurance Program Plan
for Tank Farm Contractor Radioactive Air Emissions,
RPP-QAPP-004.
Observation 12: RPP-QAPP-004 was issued in October 2001; consider
review and, if necessary, update
The Groundwater program assures consistency in sampling and and
analysis of radionuclide samples through the use of a centralized
monitoring program; CH2M HILL facilities are monitored by this
program. The QA Project Plan for the Groundwater monitoring program
is PNNL-15014, January 2005.
a) an integrated sampling approach to avoid duplicative data
collection.
Environmental monitoring is organizationally integrated to avoid
duplicative data collection. All requests for groundwater analysis
or monitoring are coordinated within PNNL and scheduled for
sampling and analysis within a single organization in that company.
Air monitoring is coordinated though the Hanford Site Environmental
Monitoring Plan. The use of the Ozone Depleting Substances is
regulated pursuant to 40 Code of Federal Regulations, Part 82. The
control and phase-out of ODS is documented in Flour Hanford
procedures HNF-PRO-15333 and HNF-PRO-10468. Maintenance and repair
of refrigeration units at Hanford are performed by certified FH
repair technicians. The prohibitions on ODS are not reflected in
CH2M HILL procurement or environmental management procedures.
Finding: The control and phase-out of Ozone Depleting Substances,
pursuant to 40 CFR 82, are not reflected in CH2M HILL procurement
or environmental management procedures.
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Criteria (a) the procurement of Class I ODS for all
nonexcepted uses is discontinued by December 31, 2010 [See
Executive Order 13148], and
disposal of ODS removed or reclaimed from equipment (including
disposal as part of a contract, trade, or donation) is coordinated
within DOE and with DoD, and for situations in which the recovered
ODS is a critical requirement for DoD missions, the facility
transfers the ODS to DoD. (b) 11 . Assist the Department with
its
requirement under Executive Order 13148 by meeting reporting and
planning requirements under the Emergency Planning and Community
Right-to-Know Act (EPCRA or Title III of Superfund Amendments and
Reauthorization Act of 1986), 42 U .S.C. 11001 , and the Pollution
Prevention Act of 1990, 42 U.S.C. 13101.
Documentation and Observations
EPCRA - Assessed using interviews of: Robin Fogg, Chemical
Coordinator; John Guberski, Environmental Compliance Specialist,
and work process contact between Guberski and Chad Wheeler/Steve
Carlson, Construction [Demonstration Bulk Vitrification
Project].
EPCRA and SARA Title III reporting is driven by the annual call
letter from the Project Management Hanford Contractor [Flour
Hanford, Inc.] for chemical inventory information. CH2M HILL
procedures [TFC-PLN-58, Chemical Management Plan, and TFC-BSM-CP
_CPR-C-05, Procurement of Services, TFC-BSM-CP _ CPR-C-06,
Procurement of Items (Material)] require the involvement of
Industrial Safety to assure information need to support chemical
inventory reporting is provided as part of the procurement process.
The Chemical Coordinator maintains an ongoing inventory of
quantities of chemicals received and quantity on hand to support
input to these reports .
Environmental staff provided examples of how involvement of
Industrial Safety occurs by describing interaction amongst the
Demonstration Bulle Vitrification Project construction contractor
[George A. Grant], CH2M HLIL Construction, and Environmental.
George A. Grant contacted CH2M HILL Construction regarding applying
a chemical [herbicide] at the construction site, as required in
their statement of work. CH2M HILL Construction contacted
Environmental to determine if use of a herbicide was allowed, by
permit and what controls applied. Environmental referred the
question to Industrial Safety to address
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~ C ... " ... V
------- --~ ---- - -----------------------------
Criteria Documentation and Observations chemical inventory and
safety questions [i.e., use a herbicide already applied at Hanford
and inform the Chemical Coordinator of amount involved if
contractor brought material to site].
Observation 13: A potential improvement could be the addition of a
contract close out item for contractor to provide a report of
chemicals used and quantity used
222-S Laboratory controls its chemicals using the Fluor Hanford
Chemical Management System, as described in Fluor procedure,
Chemical Management, HNF-PRO-10468. The ATS Plan showing ISMS, ISMS
Implementing Document, ATS-MP-1014. Identifies this substitution.
222-S Laboratory continues to use the FH Chemical Management system
because the FH system was developed to accommodate the extensive
and diverse chemical inventory maintained at the laboratory and
provides useful management functions for chemical management that
the CH2M HILL process does not offer. The EPCRA reporting is
performed using the Chemical Inventory Tracking System.
The Chemical Management System at 222-S is described in procedure,
Chemical Management, LO-150-163. This procedure describes the
process to procurement, storage and disposition of chemicals, how
to perform a facility chemical inventory, and the required process
to review and justify continued use of high hazard chemicals.
Other procedures used at 222-S Laboratory that defines the use and
disposition of chemicals are: HNF-RD-10994, Occupational Carcinogen
Control HNF-RD-13299, Hazard Communication HNF-PRO-259, Graded
Approach HNF-PRO-10468, Chemical Management Process ASP-200,
Section 4.01, "Analytical Services Hazard Communication Program" A
TS-310, Section 1. l 2, "Administration of 222-S Laboratory Complex
Criticality Safety Program" ATS-310, Section 4.5, "222-S Laboratory
Complex Chemical Hygiene Plan" ATS-310, Section 6.4, "222-S
Laboratory Complex Waste Management Process" LO-120-001, Labeling
of Standards and Reagents by Standards Laboratory Personnel
Standards Laboratory Quality Affecting Operations Chemical
Management Program webpage, httn://www.rl.1rnv/cmo/.
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Criteria Documentation and Observations LO-120-007, Proper Labeling
of Secondary Containers at 222-S Complex and WSCF LO-150-062,
Management of Shock-Sensitive and Peroxide Forming Chemicals in the
Laboratory LO-180-105, Operation of the MBAs at 222-S Laboratory
and Transfer of Nuclear Material.
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Executive Summary
Attached are the results of the June 2005 Standards/Requir~ments
Identification Document (S/RID) Phase 1/Phase 2 Assessment
performed in accordance with TFC-BSM-AD-C-07,
"Standards/Requirements Identification Document Process", Revision
A. The assessment was conducted during the period of January
through June 2005 by Portage Environmental, Inc. on behalf of CH2M
Hill Environmental Protection (EP) Functional Area, and resulted in
the following general conditions:
• A majority of requirements identified in HNF-SD-MP-SRID-001,
Section 20.0 (EP S/RID) are appropriately implemented and evidence
of compliance is available. The applicable
· requirements without evidence of implementation are identified
per requirement in the attachment of this report. Corrective
actions associated with compliance 'Yill be documented using the
Problem Evaluation Request (PER) process as described in TFC
ESHQ-Q__ C-C-01.
• Examination of records, interviews with key personnel, and
observations of activities were conducted between January and June
2005 to corroborate that implementation and compliance either was
or was not successfully achieved.
• Each requirement, and its implementing document was examined and
the results are provided in the attachment to this report.
( ) BasisA1f..Phase 2 Assessment
)
. .. .. . . ~ -~ - .. .
1. That new requirement~ at the federal , state, and local levels
are reviewed for applicability in a timely manner.
2. That interfaces at the appropriate organizational level are
established with regulators to ensure notification of new and
changing commitments and/or requirements . These · interfaces allow
a means of clarifying and interpreting requirements and address the
preparation, review, submittal and approval of exemptions.
3. That new or revised requirements are formally integrated into
the management system through modifications or development of
appropriate policies and procedures.
4. That a centralized system exists for tracking all requirements
applicable to the Functional Area and the contractor' s work
activities . The tracking system facilitates maintenance of the
requirements database and provides a cross reference to policies
and procedures incorporating the requirements to allow a consistent
updating process.
Enclosure 3
•
ASSESSMENT PLAN EMS and DOE O 450.1 IMPLEMENTATION BY CH2M
HILL
PURPOSE: This assessment evaluates CH2M HILL'S implementation DOE O
450.1, Environmental Protection Program . Attachment 2 of DOE O
450.1, Contractor Requirements Document (CRD), imposes specific
requirements on CH2M HILL. These requirements are intended to
ensure the implementation of a documented and structured
environmental Management system (EMS) and the implementation of the
EMS into the Integrated Safety Management System (ISMS). CH2M HILL
has committed to the Office of River Protection (ORP) to have a
functioning EMS in place and integrated into their ISMS by October
31, 2005. This assessment supports ORP's verification that CH2M
HILL has implemented the EMS/CRD requirements of DOE O 450.1.
SCOPE: This assessment will look for evidence that the applicable
elements of the DOE O 450.1 CRD have been incorporated into the
Standards and Requirements Document (SRIDS), flow down into
policies, procedures and plans (as appropriate), and implemented in
the field. The assessment will also evaluate how well the EMS
itself is described in program documentation, and how well it is
understood by CH2M-HILL staff and management. This assessment, and
the CH2M HILL management assessment certifying implementation of
EMS, will be used as the supporting documentation for a December
2005 declaration by the ORP Manager that the contractor has
implemented the applicable EMS requirements of DOE O 450.1 .
ASSESSMENT TEAM:
Assessment Lead Rick McNulty ORP-ED RCRA Permitting Lead, Tank
Farms ISO 14001 Lead Auditor
Lori Huffman ORP-ED Senior Contributor and RCRA Permitting Lead
WTP
Gae Neath ORP-ED P2 Lead
ASSESSMENT SCHEDULE: This assessment is to be connected
11/14-17/2005. An assessment report will be completed by
12/14/2005.
DOCUMENTATION: The source document is DOE 0450 .1, Attachment 2.
Primary review documents included:
RP-MP-003, Integrated Environmental, Safety, and Health Management
System Description for the Tank Farm Contractor, Revision 5
(Draft). Note: ED submitted RCR comments on the EMS component of
the ISMS 09/05 to ES&H .. However, the EMS comments were not
provided to CH2M HILL until 11/05.
TFC S/RID
TFC-POL-30 , Environmental Management Policy
Assessment Approach and Methodology:
The ORP has previously conducted staff reviews of RP-MP-003,
Revision 5 (ISMS)and TFC PLN-73A documenting the incorporation of
the EMS requirements of DOE O 450.1 into the ISMS Program
Description, and the Environmental Program Description . The actual
EMS system is documented in TFC-PLN-73 which includes a matrix
roadmap between EMS CRD elements, RP MP-003, and program/field
implementing procedures. CH2M-HILL completed a management aud it in
10/2005 concluding that the CRD requirements of DOE Order 450.1 had
been successfully completed . Additionally, CH2M HILL conducted a
Phase I and Phase II SRIDs Assessment in 2005 which concluded that
the CH2M HIILL SRID requirements had been successfully implemented
. ED reviewed ORP's incorporation of the DOE 450.1 CRD requirements
into SRIDS in 2004. ·
EM facilities undergoing closure are authorized to utilize a graded
approach for EMS implementation (See DOE G 450.1-1). However, DOE
HQ has provided little to no guidance on graded implementation
other than stating that credit can be taken for alternative
documentation analyzing environmental aspects and significant
impacts (e .g., CERCLA and NEPA documentation). Additionally, DOE O
450.1 does not require the development of new environmental
management systems where pre-existing systems effectively
exist.
During the early stages of EMS implementation, ORP determined that
it would be appropriate for CH2M HILL to take credit for the
extensive regulation of site closure activities via environmental
permitting (e.g ., tank post closure permits), the TPA, CERCLA
studies, and NEPA EIS documentation in lieu of conducting any
extensive environmental aspect and significant impact analysis. As
a practical matter, ORP concluded that CH2M Hill's activities and
operations are so heavy analyzed, regulated, and documented in
these alternative sources that there was no practical necessity for
CH2M-HILL to engage in extensive new analysis to identify
environmental aspects and significant impacts. In this same regard,
with the exception of specific P2 requirements , a graded approach
is also adopted for measurable environmental targets and goals.
Using the graded approach, the measurable targets and goals for
CH2M HILL are principally described in TPA requirements,
environmental permit requirements, and incentive contract direction
by ORP (e.g., accelerated tank closure).
Although all of the CRD requirements of DOE O 450.1 are captured in
the CH2M HILL S/RID's, there are function areas in which CH2M
Hill's actual responsibilities are limited and/or nominal because
the primary function is performed by the Hanford site landlord, the
Richland Operations Office and its site contractors . Examples of
these limited responsibilities include wild fire management,
watershed management, groundwater monitoring, and cultural resource
management. Where operation interfaces exist because