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With the electricity market in flux, some power companies are turning to environmental management systems (EMSs) to improve operations, reduce liability, improve community relations, and diversify their markets. An EMS is concerned with the impacts of an organization’s operations on the environment, including air, water, land, wildlife, habitat, humans, and the ecosystem as a whole. Having an EMS means that consideration of the environment is integrated into all aspects of the organization, including organizational structure, resources, responsibilities, planning, practices, procedures, and processes. The most rigorous approach to EMS implementation is to conform to a recognized standard and undergo a thirdparty audit to be registered to that standard. EM recently described many of these EMSs and the general process of implementing an EMS (see EM March 2005, p 12). One of the most widely adopted international standards is the International Organization for Standardization (ISO) 14000 series, of which ISO 14001 defines the requirements for an EMS.1 Approximately 5600 organizations in the United States have been registered to ISO 14001.2 Power companies, both publicly- and investor-owned, have a corporate culture that focuses on product delivery to the public in a fluctuating electricity market, not always on strong environmental performance. While not usually directly impacting electric power delivery, poor environmental performance can result in significant costs, including employee time to deal with spills and waste; loss of trust with Donald R. Coody is an EMS coordinator and Gary K. Miller is a communications specialist, both with Energy Northwest in Richland, WA. Jill A. Engel-Cox, Ph.D., is a senior research scientist at Battelle in Arlington, VA. Elizabeth A. Zimmerman is principal environmental scientist with Battelle in Richland, WA. E-mail:
[email protected]. awma.org
the community and regulators; and financial costs for cleanup, waste disposal, and legal fees. An EMS is appealing to a power company as a means to improve environmental performance, lower costs, improve public service, and diversify toward clean energy sources. Several power companies have implemented and registered their EMSs to ISO 14001. For example, Detroit Edison has registered seven of its eight generating stations to ISO 140013 and Pacific Power has registered seven coal-fired power plants in the western United States.4 To illustrate the many successful and challenging activities involved in implementing an EMS in the power industry, we present the story of Energy Northwest,
An EMS such as ISO 14001 requires external registration, re-registration, and continual improvement, and should not be taken on lightly. one of the first public utilities in the U.S. Pacific Northwest to be registered to ISO 14001. Headquartered in Richland, a city located in South-Central Washington, Energy Northwest provides electricity to public utilities and municipalities (see Table 1 for more information). In 2000, when the company first considered implementing an EMS, their operations consisted of the Columbia Generating Station, a boiling water nuclear reactor, and Packwood Lake, a small hydroelectric project. Seeking expansion and improved operations, they began planning for alternative energy sources and an environmental management system. Their experiences illustrate the steps, challenges, and benefits of a power company implementing an EMS.
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IMPLEMENTING AN EMS IN THE POWER INDUSTRY
Implementing an EMS begins with management of an organization deciding whether an EMS is worthwhile for their business. If the answer is yes, they begin a process of planning, implementation, review, registration, and continual improvement (see Figure 1). Deciding on an EMS
Like other industries, there are a number of reasons why power producers might decide to implement an EMS: to improve environmental and overall performance, reduce operational costs, improve public relations, meet client requirements, and/or meet regulatory requirements/consent decrees. The decision to implement an EMS should be founded on a strong need for organizational improvement. An EMS such as ISO 14001 requires external registration, re-registration, and continual improvement, and should not be taken on lightly. The first steps are an evaluation of current business practices, delineation of general management and environmental goals, understanding of the costs and benefits of an EMS, and a decision by senior management to commit the resources for EMS implementation. In February 2002, after a preliminary investigation, senior management at Energy Northwest decided they wanted to implement an EMS to improve their operations, become better stewards of the environment, and continue to be good neighbors to the community. They sought to formalize the inclusion of environmental considerations into decision-making, improve their environmental performance, and reduce waste generation. With the endorsement of the company’s Board of Directors, Energy Northwest’s chief executive officer (CEO), Vic Parrish, spearheaded the decision to implement the EMS, and supported the project from beginning to end. There was no regulatory imperative, such as a consent decree, forcing implementation of the EMS. Energy Northwest’s member utilities did not demand an EMS, and the local community was relatively content with (or unaware of) Energy Northwest activities. Thus, one of the continual challenges for the CEO and the EMS project team was to impose a compelling internal need for middle management and staff to implement the EMS, especially in the early stages of the project. Forming the Team, Allocating Resources, and Planning the Project
EMS implementation typically takes one to three years, depending on the initial state of management systems and availability of staff and financial resources. While it is possible to implement an EMS through an ad hoc process led by an environment, health, and safety (EH&S) organization, the preferred approach is as an interdisciplinary project. With this approach, a project leader manages implementation, adequate resources can be specifically allocated, and a team formed from all the major divisions responsible for implementation throughout the organization. Energy Northwest treated the EMS as a project, designating a project manager, who formed a team of 12 EMS representatives, consisting of staff from all major operations 18
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and support groups. Recognizing a need for additional staff resources during implementation, Energy Northwest enlisted outside contractor support from Battelle Memorial Institute, a nonprofit science institute. Battelle manages neighboring Pacific Northwest National Laboratory for the U.S. Department of Energy and several other facilities that are registered to ISO 14001.5 Staff from Energy Northwest and Battelle worked together to develop a detailed project management plan used to guide the project activities, set the schedule, and estimate needed resources. The use of outside contractor support allowed Energy Northwest to access EMS expertise that would have taken considerably longer for them to develop internally, as well as avoid hiring new full-time staff. While this was necessary for the success of their EMS, they still needed to commit adequate Energy Northwest resources for actions that only staff could take, such as implementing procedures, running the pollution prevention program, and administrative support. Defining the Right EMS and Its Scope
Each organization must decide which EMS model best fits their organization. Several of the EMS models are suitable for the electric power industry, including ISO 14001 and the Code of Environmental Management Principles. In some cases, a core EMS may be selected for third-party registration and enhanced with additional initiatives to meet the organization’s mission. For example, an electric power organization may want to emphasize alternative energy, energy conservation, and hazardous/radioactive waste prevention as most relevant. Additionally, a key consideration when defining an EMS is deciding its scope; specifically, if it will include only a single facility, several facilities, or the entire company. This decision may be dictated by available resources, geography, organizational issues, and stakeholder perception. Energy Northwest investigated the different EMS standards and developed a composite EMS model. Energy Northwest’s EMS is based on a model that fully conforms to ISO 14001 requirements, is compatible with the company’s mission and values, and emphasizes pollution prevention, training, and communication.6 The commitment to ISO 14001 gave Energy Northwest a milestone to achieve and a recognizable program to reference in communication with stakeholders. Ultimately, third-party registration helped motivate Energy Northwest staff to complete implementation and re-registration ensured that the EMS would not be put on the shelf after implementation. Energy Northwest also decided to implement its EMS companywide, rather than site-specific, including a new wind project and solar station. A corporate approach enabled a clear message to employees and stakeholders, but required a “graded approach” to create a consistent but workable program across uniquely different facilities. Creating an Environmental Policy
As simple as an environmental policy may seem, its development, endorsement, and communication by the senior management mark the visible beginning of the EMS project for most staff. The development of the general concepts of the
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Table 1. Key facts about Energy Northwest. Operations Net generation (2004) 9.74 GWh Nonoperating expenses and debt service $330 million Operating expenses (2004) $345 million Number of employees 1134 Energy Northwest has diversified their energy production facilities. They operate the Columbia Generating Station, Nine Canyon Wind Project, Packwood Lake Hydroelectric Project, and White Bluffs Solar Station, as well as provide operations and maintenance services for other facilities. EMS Project Timeline Began considering EMS August 2001 Funded EMS project July 2002 Registration to ISO 14001 April 2005 More Information EMS Web site www.energy-northwest.com/ems/
policy should be a group effort, since they should reflect the approach by the EMS team and the divisions involved. For the electric power industry, the policy should reflect its desired relationship to the community, to the natural resources it consumes, and the electricity it produces for the region. Energy Northwest established an environmental policy in the early 1990s; however, few employees were familiar with it. To develop a new policy, Battelle conducted brainstorming
Figure 1. EMS timeline.
sessions with staff from all parts of the company. The resulting policy focused on stewardship of the environment and the “triple bottom line” that balances environmental and social factors and business needs.7 Revising and Writing Procedures
Procedures instititutionalize an EMS, as opposed to relying on staff experience and on-the-job training. If the organization already has well-documented procedures, merely revisions
Planning for the Future: Climate Change, Greenhouse Gas Inventories & Clean Energy Linkages Meeting the challenge of climate change will require collaborative and integrated approaches that recognize the links between advanced energy technologies and their potential for reducing emissions. This conference will address these links, as well as emerging federal and state initiatives and their global implications. The conference will examine new U.S. energy legislation, the “Gleneagles Plan of Action” (G8), the new Asia-Pacific Partnership on Clean Development and Climate, and various state climate action plans.
March
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Table 2. Procedures developed/modified and training conducted for the Energy Northwest EMS. Procedures
• Document control
Developed
• Corrective action program
and Modified
• Employee recognition and rewards • Performance improvement
Determining Impacts and Aspects
• Performance appraisal/performance planning • Pollution prevention program • Aspects procedure • EMS communications • EMS management review • Environmental compliance assessments • Environmental emergency preparedness • Environmental performance measurement • Work planning and control • EMS audits • Review and management of environmental requirements and commitments • Processing of incoming regulatory and industry correspondence and commitment screening • Communications desk procedure—Data entry for EMS public inquiry log • Employee environmental stewardship recognition and awards desk procedure • Pollution prevention communications desk procedure Training Conducted
• EMS overview training for EMS representatives (3 days) • EMS management training (1 day) • EMS overview training for managers (1 hour) • EMS job-specific training (1 hour) • Pollution prevention basics (1.5–3 hours) • Pollution prevention opportunity assessments (2 hours) • EMS aspects and impacts (4 hours) • ISO 14001 lead auditor training (5 days) • General employee training with EMS enhancements (computer-based training) • Succeeding on an EMS audit (online and staff meetings)
are needed to ensure inclusion of environmental management into operations and decision-making. Just as important as documentation, the revision of procedures forces staff who will be required to incorporate consideration of the environment in their activities to plan the steps to routinely implement the EMS. Involvement and approval of these staff in the procedure revision process increases buyin and further develops staff knowledge of the EMS. Energy Northwest has always had a strong focus on nuclear and industrial safety, but many existing programs did not extend to environmental protection, or did not include nonnuclear operations outside Columbia Generating Station. The EMS project team chose to incorporate the EMS into existing management systems that staff understood and relied upon, only creating new processes or programs when absolutely necessary. The decision to maximize the use of existing systems, particularly the 20
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corrective action process and the procedures and records control systems, lessened the administrative impact of the EMS implementation. Table 2 lists the procedures that Energy Northwest revised or rewrote to implement its EMS.
Environmental impacts and aspects are some of the most difficult concepts to understand for most organizations implementing an EMS. An environmental impact is any adverse or beneficial change to the environment (including resource use) wholly or partially resulting from an organization’s activities, including local, transboundary, and global effects. An environmental aspect is the part of an organization’s activities, products, or services that can interact with the environment and cause an impact on the environment. ISO 14001 and other EMSs have specific guidelines for an organization to identify, prioritize, and address how its activities impact the environment. For electric power facilities, impacts are likely to be air emissions, cooling water use, hazardous and radioactive waste, and industrial footprint. Energy Northwest approached impacts and aspects by developing a procedure for the identification and assessment of the significance of environmental aspects. The team also conducted walkthroughs of organizations to validate activities and aspects. The key considerations for determining whether an aspect was significant included the severity and frequency of the environmental impact, relevance to regulatory compliance, and both internal and external stakeholder interest. Energy Northwest identified five significant aspects: waste generation, atmospheric emissions, liquid discharges, land use, and storage/use of petroleum, chemical, or radioactive materials.8 Performance indicators were developed in these five key areas to track reduction of potential impact through enhanced operational controls and pollution prevention. These performance indicators augmented an existing monitoring and measurement program and enabled Energy Northwest to monitor their progress. Strengthening Pollution Prevention Programs
As federal and state government environmental agencies continue to emphasize cleaner production and pollution prevention reporting, pollution prevention is often included in an EMS. Pollution prevention enables an organization to achieve visible, cost-effective environmental success in the near term, such as reducing hazardous waste generation and disposal, expanding an office recycling program, conducting energy efficiency initiatives, or reducing purchase of hazardous chemicals. When developing the EMS composite model, Energy Northwest’s EMS project team added emphasis on pollution prevention. Implementation started with training on pollution prevention opportunity assessments. Four pollution prevention opportunity assessments were conducted, addressing some of Energy Northwest’s most costly waste streams: diesel generator maintenance (including a major
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REFERENCES 1.
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Environmental Management Systems— Specifications with Guidance for Use; ISO 14001:1996; International Organization for Standardization, September 1996. North American ISO 14001 Certificates Pass 7500; Environmental Systems Update 2005, January–February. “Event at Detroit Edison’s Greenwood Energy Center Celebrates Facility’s ISO 14001 Certification”; New Release; Detroit Edison, Februar y 11, 2005; available at www.dteenergy.com/about/environment/edisonPowerPlants.html. ScottishPower, Environmental Performance Report 2003/04, undated; available at www.pacificpower.net/Article/Article48334.html. Briggs, S.L.K. ISO 14001 Implementation at a National Laboratory. In Proceedings of the 94th Annual Conference of the Air & Waste Management Association, Orlando, FL; June 2001. Environmental Management System Program Description, EMS-01, Energy Northwest, Rev. 0, December 22, 2004; available at www.energynorthwest.com/downloads/EMS01%20R0%20%28Dec04%29.pdf. Energy Northwest Environmental Stewardship Policy, PSM-5.7, Energy Northwest, Rev. 3, July 22, 2003; available at www.energy-northwest.com/ ems/policy.php. Energy Northwest Environmental Aspects. See www.energynorthwest.com/ems/aspects.php (accessed November 2005).
hazardous desiccant waste stream), energy efficiency, spill management, and arc spray pipe restoration. Implementation of the recommendations from these assessments has the potential to save the company nearly $120,000 per year, reduce more than 400 pounds of hazardous and radioactive waste, 400 pounds of nonhazardous waste, and 350 MWh/yr in energy usage. Training and Communication
An EMS needs to be pervasive in the organization, with all staff understanding their role in environmental management. This requires training and extensive communication programs. Training programs should
be tailored to specific staff, including management, individuals implementing the EMS, internal auditors, and general staff. In addition to training, open and recurring communication reinforces the program to staff and tracking of interactions is a required part of most EMSs, including ISO 14001. For a power utility, communications with external stakeholders may include press releases or open meetings with the community on issues that may have an environmental impact (such as a new generation facility). Building on existing safety training programs, Energy Northwest launched an intensive training and communication program designed and implemented in timed stages before the audits. They conducted management training early in the EMS process to help their senior management understand the EMS and their role in its implementation. Customized EMS training was held for the managers and EMS representatives implementing the EMS. Several staff were also trained as internal EMS auditors. General employee training for all staff and key contractors was conducted a few months prior to the third-party audit to remind everyone of the details of the program. Table 2 lists the types of training that Energy Northwest conducted to implement its EMS. The communications department published a series of articles in their internal newsletter, prepared posters, brochures, and
Vapor Intrusion – The Next Great Environmental Challenge January 25-27, 2006 • Philadelphia, PA This specialty conference will address the vapor intrusion (VI) pathway, an emerging concern that may impact thousands of hazardous, brownfield, and commercial/industrial waste sites across the nation, as well as residential buildings near the sites. Defined by the U.S. Environmental Protection Agency (EPA) as the “migration of volatile chemicals from the subsurface into overlying buildings,” VI may represent a health risk – even when remedial measures have already been implemented.
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badge cards, developed and maintained internal and external Web sites, and facilitated communication about the program from the CEO, management, and the EMS project manager. EMS Audits and Third-Party Registration
Internal audits help identify and correct weaknesses and prepare for the third-party registration audit. Choosing a thirdparty registrar usually requires requesting proposals, review of their qualifications for similar industries, and cost comparisons. For ISO 14001, registration typically costs $25,000– 50,000 and is available to the power industry from several leading registrars.
operating two new alternative energy facilities—the Nine Canyon Wind Project and the White Bluffs Solar Station— and included these facilities with their nuclear and hydroelectric facilities and support operations in a corporatewide EMS. The ISO 14001 registrar auditor commented on the company’s excellent training system, which resulted in increased employee knowledge of environmental management. As a direct result of the EMS, Energy Northwest received regulatory relief from the State of Washington Department of Ecology for pollution prevention reporting requirements and has started to reduce costs by reducing hazardous waste and improving energy conservation. They also received the 2005 Environmental
Energy Northwest identified five significant environmental aspects: waste generation, atmospheric emissions, liquid discharges, land use, and storage/use of potentially hazardous materials.
As implementation of the EMS neared completion in August 2004, the Energy Northwest EMS project team and management conducted an internal audit. Issues and their disposition were entered into Energy Northwest’s internal action tracking system, where they received high priority from staff. The project culminated in a third-party audit of all facilities in spring 2005 and registration of Energy Northwest’s environmental management system to ISO 14001 in March 2005. Commitment to Continual Improvement
With annual registration required and an organization’s operations always changing, an EMS is a process not an end goal. Organizations receiving registration often face a challenge to maintain momentum of the EMS program. Energy Northwest is now looking at continual environmental improvement as its next objective. At an employee recognition ceremony after registration was received, CEO Vic Parrish stated: “One of the cornerstones of our EMS is continual improvement, so this effort, this dedication to environmental stewardship, will be part of our organizational culture.” This type of senior management support sustains an organization over the long-term as the EMS becomes increasingly institutionalized into the corporate culture. CONCLUSION
With an EMS registered to the ISO 14001 standard and continuous environmental improvement programs launched, how does an electrical power company benefit from implementing an EMS? For Energy Northwest, the three-year EMS project resulted in a new environmental policy, more visible commitment to renewable energy, revitalized pollution prevention program, and revamped procedures to incorporate environmental considerations into all activities. Energy Northwest constructed and is 22
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Innovator of the Year award from the Association of Washington Business. As Energy Northwest seeks to expand energy production diversity, consideration of the environment is included in key decision-making. Energy Northwest’s success is attributed to • consistent CEO support, which ensured funding through reductions in force and other organizational challenges that arose during the project; • a strong EMS project team, consisting of an EMS project manager, EMS representatives from throughout the organization, and external expert support; • highly effective training and communications; • use of existing and respected internal management systems; and • third-party registration as a defined milestone. While there are near-term benefits, the Energy Northwest’s CEO has a long-term vision, stating at an employee celebration of EMS registration that “this program is noteworthy now, but the real benefit will come 20, 30, and 100 years in the future.” The keys to success and the rewards and costs are consistent for other electric power utilities. They must have committed executive leadership, a compelling need (either internal or external) for the EMS, a dedicated team that has the authority and resources to implement the EMS, strong communication, and a long-term focus. ACKNOWLEDGMENTS
The authors would like to acknowledge all the employees of Energy Northwest, especially the line organization EMS representatives, for their hard work to implement their EMS. Special thanks to Jim Chasse of Energy Northwest; Kim Fowler, Kathy Poston, and Sue Briggs of Battelle; Joe Cascio of Booz Allen Hamilton Inc.; and Jeff Omelchuck of Zero Waste Alliance. em
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