EMS Procedure: Environmental Aspect and Impact Evaluation
EMS Procedure: Environmental Aspects
I. Purpose
The purpose of this procedure is to provide guidance for evaluating the environmental aspects and impacts of the organization’s activities, services, and products. The evaluation should result in a determination of whether or not a particular aspect has any significant environmental impacts and if so, whether or not the organization can control or influence those impacts. Those activities, services, and products that are identified through this procedure as having significant and controllable impacts will then be reconsidered in the procedure to determine objectives and targets for controlling the identified impacts.
II. Scope
This procedure is applicable to all activities, services, and products of the organization. This procedure has been used to conduct an initial assessment of the organization and will be used in follow-up assessments at various points in time.
Each of the groups that make up the EMS organization shall identify and document the environmental aspects of the activities, services, and products under their control or influence and identify those that can have a significant impact on the environment.
At a minimum, this procedure will be used once a year to determine if there have been any changes to each of the aspects that have been identified. This procedure will also be used whenever a new activity, service, or product is being considered by the organization.
III. Definitions
Environmental Aspect – element of an organization’s activities, operations, product, or services that can interact with the environment. The environmental aspect of an activity, operation, product, or service is the part of it that creates a possibility for a direct or indirect environmental impact.
Environmental Impact – any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s environmental aspects.
Environmental Objective – overall environmental goal consistent with the environmental policy that the organization sets itself to achieve. Objectives should be measurable so that the organization can verify progress made toward their attainment.
Environmental Target – detailed performance requirement, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.
Significant Environmental Aspect – environmental aspect that has or can have a significant environmental impact.
IV. Approach
The EMS group leaders are each responsible for organizing a cross-functional team to perform the evaluation. When possible, each member of the team should bring a unique perspective to the table.
Consideration shall be given to both normal operating conditions and to emergency operating conditions.
Through a process of brainstorming and information gathering, the CON cross-functional EMS team shall develop a baseline list of CON activities and associated environmental aspects
CON determines its significant aspects by applying five criteria to the potential and actual environmental interactions of its activities, products and services. These criteria are used to evaluate the degree and the severity of impacts (either positive or negative) of these interactions on the natural environment, on the organization, and on others. If, upon applying the criteria, a threshold impact value is exceeded (described below) then the environmental interaction of the specific activity, product or service is considered “significant." The criteria for evaluating environmental interactions include:
• Legal and Other Requirements: -- is the activity controlled by or otherwise subject to regulations or other requirements to which CON subscribes?
• Impact to the Environment: -- to what degree does the activity potentially alter the natural environment (either positively or negatively)?
• Impact to Mission/Organization: -- to what degree does the specified activity potentially disrupt or support operations?
• Financial Impact: -- what costs or cost-savings does the activity potentially impose on or provide to the Agency?
• Impact to Community: -- to what degree does the activity potentially affect the views of outside interested parties, such as the local community and other federal agencies?
The above criteria (excluding Legal and Other Requirements) are assigned an impact value based on the following scheme. The impact values include:
• High Impact = 5: The resulting change to the environment, organization, or community is strong and/or has a high likelihood of occurring.
• Medium Impact = 3: The resulting change to the environment, organization, or community is moderate and/or has a moderate likelihood of occurring.
• Low Impact = 1: The resulting change to the environment, organization or community is weak or negligible and/or is unlikely to occur.
For the criterion Legal and Other Requirements, impact values are not assigned. Rather a “Yes” or “No” is assigned reflecting if legal and/ or other requirements apply to this environmental interaction.
CON assigns an impact value (i.e., 1, 2, 3, 4 or 5) to each criterion using the following impact descriptions as general guidelines:
1) Impact to the environment:
• High: Environmental consequences are irreversible or severely disrupting to the ecology or to human health and welfare. Environmental benefits to ecology or to human health and welfare are substantial.
• Medium: Environmental consequences are serious but reversible over time. Environmental benefits to ecology or to human health and welfare are moderate.
• Low: Environmental consequences are noticeable but brief or totally correctable in a relatively short time period. Environmental benefits to ecology or to human health and welfare are minimal.
2) Impact to mission/organization:
• High: Interruption of normal mission operation is likely and severe. Benefit to the organization is mission capability is substantially improved.
• Medium: Interruption of normal mission operation is likely but recoverable without significant repercussions. Benefit to the organization’s mission capability is moderately improved.
• Low: Interruption of normal mission operation is either unlikely or the consequences are very slight or easily corrected. Benefit to the organization is mission capability is minimally improved.
3) Financial impact:
• High: Cost of a fine, control or remediation is over $1 million. Benefit to the organization is over $1 million.
• Medium: Cost of a fine, control or remediation is between $100K and $1 million. Benefit to the organization is less than $1 million and greater than $100K.
• Low: Cost of a fine, control or remediation is less than $100K. Benefit to the organization is less than $100K.
4) Impact to community:
• High: Significant negative (e.g. lawsuit, front-page press coverage) or positive (award) public response is highly likely. Community interest is likely to be persistent and long-term.
• Medium: Public interest is likely to be moderate (e.g. phone-in complaints; back-page press coverage) and not sustained over long-term.
• Low: Public interest is negligible or non-existent.
CON determines the overall impact of each interaction by adding together the scored values of each of the criteria. CON considers an activity’s potential impact significant if either or all of the following conditions are met:
• The overall impact measures "10" or greater,
• The activity is subject to a legal or other requirement
• Neither of the above conditions is met, but CON nonetheless considers the activity in need of management within the EMS framework.
CON uses the relative scores of all significant activities as a basis for prioritization. "Significant" scores range from 10 to 20. Higher scored activities indicate that greater resources will be applied to addressing these activities relative to lower scored activities.
The Aspects, Impacts, Objectives, and Targets Identification Form is designed to identify activities and determine the effects of activities and the extent to which the activities will impact the environment. The form is designed to be completed by a team within each group to determine objective information on the aspects and impacts of the organizational groups’ activities. The details of the form will provide valuable information for prioritizing and determining the order in which allocation of resources will occur. The form is an on going document that will be reviewed and revised on an annual basis. The analysis worksheets are designed for teams from each group to evaluate their operations and rank each identified aspect according to its legal, environmental, financial, organizational, and community impact. Aspects are determined to be significant aspects and impacts. Although some aspects are not ranked as significant, the teams may develop operational controls as part of our best management practices. Determinations and rankings will be reviewed and revised as needed on an annual basis.
The list of CON activities, operations, processes, products, and services and associated aspects and impacts for the EMS groups are updated in the following manner:
• When changes in CON activities or operations are proposed (e.g., new activities/operations will be introduced or existing activities/operations will be modified or discontinued), the proponent shall communicate the proposed change to the EMS Management Representatives and Group Leaders in the organization to evaluate potential environmental impacts.
On at least an annual basis, the CON cross-functional EMS team shall update the list in accordance with any changes in CON operations and/or services at facilities and any associated legal or other requirements that may apply to such activities.
On at least an annual basis, the CON cross-functional EMS team shall review and reevaluate the aspects.
V. Records
Aspects Identification Procedure: Significant Aspects Documentation that lists aspects, associated activities, operations, processes, products, and services and EMS group; legal and regulatory requirements, environmental, mission, financial, community, and overall impacts; and a designation of significance (see Attachment A for table template)(Attachment B for aspect definitions).
Identification Form that lists aspects, impacts, objectives, and targets, associated with external and internal activities.(see Attachment C for template).
Potential Impacts Effects Analysis (PIEA) (See Attachment D for analysis template)
VI. Attachments
Attachment A: Aspects Identification Procedure: Significant Aspects Documentation template
Attachment B: Aspect Definitions
Attachment C: Identification Form template.
Attachment D: Potential Impacts Effects Analysis (PIEA) template
Attachment C
City of Norman Utilities and Public Works Departments Environmental Management System
EMS Group Identification Form
EMS Group: _____________________________________
| |Activity/Product/Service |Aspect |Impact |Objective |Target |
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|External Activity | | | | | |
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|External Activity | | | | | |
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|Internal Activity | | | | | |
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|Internal Activity | | | | | |
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Attachment A: Aspects Identification Procedure:
Significant Aspects Documentation
|ASPECT IDENTIFICATION | |
| |SIGNIFICANCE DETERMINATION |
|Aspect |
|Aspect |Definition |Examples of Potential Impacts |
|Air emissions |Gas emitted into the air from industrial and chemical processes, such |Air pollution (smog, acid rain, dust, visual |
| |as ODS [CFCs in building chiller systems], VOCs [fugitive emissions |impairment) |
| |from vehicle fueling operations and painting activities], criteria |Ozone depletion |
| |pollutants [facility engine generators], dust, vehicle exhaust, |Greenhouse gas contribution |
| |aircraft exhaust, odor. | |
|Biological waste generation |Generation/ disposal of biological products that can be infectious or |Human health impact |
| |biohazardous, such as sharps, infectious substances and autoclave |Biological material dispersal |
| |wastes. | |
|Cultural disturbance |An event or circumstance that interrupts the relationship between the |Damage to native American resources |
| |environment and cultural resources, such as impacts historic |Damage to archeological resources |
| |properties, socioeconomic impacts, environmental justice impacts, and |Loss of public access to recreational |
| |visual impacts. |resources |
|Ecological disturbance |An event or circumstance that interrupts the relationship between the |Migration of indigenous species |
| |environment and organisms, such as hydrological alteration, vegetation |Introduction of non-native species |
| |alteration, habitats, wetlands, threatened and endangered species, |Species habitat alteration |
| |invasive species, coastal resources, prime farmlands, soil erosion and | |
| |food waste. | |
|Energy consumption |The use of energy as a source of heat or power or as a raw material |Greenhouse gas contribution |
| |input to a manufacturing process, including electricity, petroleum |Air pollution |
| |products, and alternative fuels. | |
|Fuel consumption |The amount of fuel used for gross generation, providing standby |Greenhouse gas contribution |
| |service, start-up and/or flame stabilization. |Air pollution |
|Hazardous materials releases |The release of hazardous materials (substances that are harmful to |Human health impact |
| |human and environmental health and/or safety in relatively small |Soil contamination |
| |quantities. Such materials include flammable, combustible, corrosive, |Hazardous material dispersal |
| |reactive, and toxic substances as well as any other substance defined | |
| |as "hazardous" by the state or federal government) into the | |
| |environment. | |
|Hazardous waste generation |The generation of hazardous material (substances that are harmful to |Hazardous material dispersal |
| |human and environmental health and/or safety in relatively small |Human health impact |
| |quantities. Such materials include flammable, combustible, corrosive, | |
| |reactive, and toxic substances as well as any other substance defined | |
| |as "hazardous" by the state or federal government) into the | |
| |environment. Examples include degreasing solvents, waste paints, used | |
| |oil, hazardous batteries [lead-acid, lithium, NiCd], empty chemical | |
| |containers, fluorescent bulbs. | |
|Natural resource consumption |The consumption of a natural resource (a naturally occurring material |Resource depletion |
| |such as coal, wood and minerals that can be exploited by people). | |
|Noise emissions |The emissions of human-created noise harmful to health or welfare such |Noise damage |
| |as aircraft operations, vibration, visual impairment, light emissions. |Vibration damage |
|Non-hazardous waste generation |The generation of waste that is non-hazardous and does not pose |Solid material dispersal |
| |substantial or potential threats to public health or the environment | |
| |such as (scrap, pallets, cardboard, paper, rags, construction debris | |
|Radiation emissions |The emissions of radiation (energy from heat, light, sound) that is |Radiation damage |
| |emitted from operations such as the use/disposal of sealed sources, |Heat damage |
| |use/disposal of isotopic solutions, and generation of ionizing or | |
| |nonionizing radiation. | |
|Oil spills/releases |The spill or release of oil into the environment. |Species habitat alteration |
| | |Ecological damage |
| | |Hazardous material dispersal |
|Stormwater runoff |Surface water runoff that flows into storm sewers or surface waters. |Surface water contamination |
| | |Soil contamination |
| | |Watershed alterations |
|Toxics substances releases |The release of poisonous substances known or believed to be harmful to |Human health impact |
| |people's health, often producing chronic, irreversible physical |Toxics contamination or addition to air, |
| |problems and possibly harming subsequent generations including PCBs, |land, waterway |
| |asbestos and lead based paint. | |
|Wastewater discharge |The discharge or release of wastewater into the environment from |Groundwater contamination |
| |operations including painting operations, metal etching/plating, small |Sedimentation of water courses |
| |photographic activities, vehicle maintenance areas, sewage, and storm | |
| |water. | |
|Water consumption |The consumption of water for daily operations. |Resource depletion |
|Water quality |The quality of water provided to staff for drinking. |Human health impact |
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