aspects and impacts training - elsmar control 2008.pdfoperational control and ... procedure(s) to...
TRANSCRIPT
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Operational Control and Monitoring and Measurement
Module Training
September 17, 2008
N.C. Division of Pollution Prevention and Environmental Assistance
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Check In
Aspects, impacts and assessing significance• Were you able to complete 3 activity areas for
homework?• What challenges did you have in assessing
aspects and impacts?• What challenges did you have in choosing
significance criteria and determining significance?
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Check In (cont.)
• Do you have a list of operational procedures (work instructions or SOPs) already in place at your facility.
• How does your facility measures environmental performance currently.
• Questions?
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Step 4. Operational Control and Emergency Preparedness
and Response
(ISO 14001:2004 Clauses 4.4.6., 4.4.7)
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Design Tool Timeline and Module 2
EMS Elements
Mon
th 1
Mon
th 2
Mon
th 3
Mon
th 4
Mon
th 5
Mon
th 6
Mon
th 7
Mon
th 8
Mon
th 9
Mon
th 1
0
Mon
th 1
1
Mon
th 1
2
Management Review Board Meetings *
EMS Team Meetings
Gap Analysis **
Step 1: Roles and Responsiblities and Scope
Step 2: Initial Environmental Review (Legal & Other)
Step 3: Aspects, Policy, and Impact Analysis
Step 4: Operational Control & Emergency Response
Step 5: Monitoring and Measurement
Step 6: Objectives, Targets and Programs* First internal audit with results reported at next management review board meeting ** First MRB meeting covering all requirements of ISO 14001:2004
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Building on Significant Aspects
Activity Aspect (input or output)
Env. Impact
Significant Aspect
(volume, haz. characteristics, frequency, etc.)
Operational Control
Monitor/
measurement
Module 2 Module 2
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4.4.6 Operational Control
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The organization shall identify and plan those operations that are associated with the identified significant environmental aspects consistent with its environmental policy, objectives and targets, in order to ensure that they are carried out under specified conditions, bya) establishing, implementing and maintaining a documented
procedure(s) to control situations where their absence could lead to deviation from the environmental policy, objectives and targets, and
b) stipulating the operating criteria in the procedure(s), andc) establishing, implementing and maintaining procedures related to
the identified significant environmental aspects of goods and services used by the organization and communicating applicable procedures and requirements to suppliers, including contractors.
4.4.6 Operational Control
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Operational Control
• Huge “chunk” of the standard• On-going day-to-day EMS activities• Pre-requisite – identify significant
environmental aspects– Intent is that whatever you deem “significant”,
you have control over
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Why Are Operational Controls Important?
• To prevent or lessen environmental impacts• To maintain regulatory compliance• To safeguard against “informality” and its results
(word-of-mouth)• To avoid non-conformances in the EMS• To assist staff in achieving the environmental
objectives and performance measures
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Operational Control
Env Policy
Objectives& Targets
Aspects
DocumentControl
Monitoring &Measurement
Documentation
Training
OperationalControl
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Operational Control
• Various means of “control”– Physical – locked valves, equipment set-up– Computer – alarms, instrumentation– Procedural – standard operating procedures
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Operational Controls Can Be…
• SOPs … but what else?
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Example Operational Controls
• Checklists• Equipment• Sign, e.g. “Cardboard only”• Training• Work instruction or SOP
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Example Operational Controls (cont.)
Remove Berry Stains From: Cotton, LinenTest fabric for colorfastness. If color doesn't change, stretch the stain over a bowl; fasten in place with a rubber band. Pour boiling water through the fabric from the height of 2 or 3 feet. Avoid splatters. This procedure must be done immediately. If stain persists, soak in a solution of 1 quart warm water and 1/2 teaspoon detergent for 15 minutes. Rinse with water. Sponge the area with rubbing alcohol and launder as soon as possible.
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Criteria to consider in Operational Controls
May cover:• Operational procedure• Sampling and analysis activities• Reporting results• Emergency response• Qualifications or certifications of those performing
task• References to laws or regulations that apply
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Criteria to consider in Operational Controls (cont.)
• List step-by-step tasks. – What to do – How to do it
• Roles and responsibilities – Job titles, not names
• Consider including normal and abnormalconditions– Consider listing precautions to prevent
incidents/accidents
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May Include “Why” in SOP/Work Instructions
• Consequences of departure from specified operating conditions (clause a)
• Benefits of following the procedure
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Novozymes Integrating Environment Into SOP’s
“In order to support our Environmental Quality System (QS.EQ.1000NNBNA ENVIROMENTAL POLICY), this system will be operated according to this procedure to reduce environmental impact and conserve natural resources whenever possible. This operating procedure was written and this system designed to accomplish these goals. All items in this procedure pertaining to EQS will be in bold type.”
Work Instruction Comment
When precoat touches the knife, open the knife water valve at the drum to approximately 2m3/hr
Use only enough water to transport precoat from trough. Reduces depletion of a renewable resource
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Example 1Significant Aspect = Air Emissions
• Most likely have an air permit• Operational control details how to run/maintain
pollution control equipment to stay in compliance• Have SOPs – standard operating procedures
– Operation of baghouse– Operation of scrubber– Operation of boiler– Operation of _________
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Example 1 Procedures
SOPs need to include/address• How to start-up• How to shut-down• Normal operation
• What is method of control• How are parameters changed
• Abnormal operation• What to do if a parameter goes high/low
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Example 1 Procedures (cont.)
Are log sheets used?• Document control clause applies also• Are sheets filled out consistently• In INK• Ranges specified• Consequences specified
• Do log sheets specify actions to take if a parameter is out of range, high/low, etc?
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Example 2 Significant Aspect = Water Usage
Operational control details how you control usage• Do you let water flow just happen?• Recycle triggered above a certain point?• How is it monitored?• If water flow is high/abnormal, how do you react, where is this
specified?Mon Tues Wed Thur Fri
Area X (10-25 gpm)
Area Y (2-12 gpm)
Area Z (3-15 gpm)
If out of range, notify ______________
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Example 3Significant Aspect = Hazardous Waste
Operational control details how you handle waste• SOPs should address
– How to load/unload/dispose– Personal protective equipment– Who handles
• Specific training required?– What happens if?
• Spill/release• Mixing• Unknown substance
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Class Examples
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Control Considerations
• Being practical and straight-forward. (K.I.S.S)
• Linking WI/SOP to significant aspect• The workforce – are allowances needed
for non-English speakers or illiteracy or other?
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Also consider…
• Are operational controls available at point-of-use? – Ex. Laminated procedure at work
station– If on a computer or intranet, is there
a back-up?
• How do you control external references such as equipment manufacturer’s calibration documents and other references?
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Who needs to know procedures?
• Employees!• Anyone else?
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Training on Procedures
1. Identify who needs to be trained.2. Conduct training.3. Verify procedures are being followed. It is
important to follow your own procedures and update as appropriate.
4. Evaluate competence.5. Track training.
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What an EMS auditor should look for:• evidence that operations/activities linked to
significant aspects have been identified• appropriate documented procedures and work
instructions• applicable communication with suppliers and
contractors pertaining to significant aspects
Operational Control Audit
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Pitfalls
• Nonconformance“A review of the Inventory Audit
form for April and July 2007 indicated that the forms were initialed inconsistently. Examples include: Operators initialing when supplies were low and contacts were made for replacement. Operators initialing when inventory check was done not withstanding the result. Operators using check marks or OK in place of initials.”
Rev. Date: 6/4/07 Inventory Audit Doc Owner: John Doe
Initials: __ JHA____ Date: _7/3/07__
Hydrogen – Really Big Gas Co, Inc.
South Trailer #1 North Trailer #2
Pressure: __350__psi Pressure: __ 800 _ psi (500 – 2400 psi)
(800) 234-2323 Joe Smith – Ext. 34, or Barry Bonds – Ext. 3230
Initial: __ _______
LP Gas - National Gas Corp.
Empty tanks: __ 3____ Full tanks: __2___
To be called in every Monday and Thursday
Note: If less than 4 FULL tanks of LP Gas, contact Carol, Herb, Bobby
Phone: 234-2323 - ask for Counter Sales
Initial: ___TWH____ Vendor must be contacted BEFORE 10:00 A.M.
Salt – Morton
Number of bags in inventory: ___3_______
(910) 345-2341 (Call to re-order ONLY when inventory is down to one pallet of bags)
Initials: __ OK_________
Comments:
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Pitfalls (cont.)
• How are contractors made aware of operational control issues?– Identify appropriate records to be kept
• Ensure documented procedures match actual practice– Example: SOP says “Water samples are taken daily”.
However, since area is not staffed on weekends, samples are not taken on Sat/Sun. SOP does not match practice.
– Conversely, permit says to monitor a parameter monthly. You choose to monitor more frequently – say weekly. Documented procedure should specify the more frequent practice.
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Pitfalls (cont.)
• If operational control includes alarms/interlocks, is it documented how to respond to those events?– Are alarms/interlocks tested? Connects to
monitoring & measurement clause– Are alarm set-points above or below permit
parameters?
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Operational Control –Key Points
• Operations relate to significant aspects• Documented procedure(s)• Specify operating criteria• Communicate to contractors• Pay attention to the details
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Example EMS Procedures and Forms
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EMS Linkages to Operational Control 4.4.6
• Have documented procedures (where absence could lead to deviation from policy or O&T) for identified significant aspects - 4.3.1
• Identify and provide training on “benefits of improved personal performance” related to significant aspects and related actual or potential impacts and “potential consequences of departure from specified procedures” – 4.4.2
• 4.4.7 Emergency Response and Preparedness• 4.5.1 Monitoring and Measurement
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4.4.7 Emergency Preparedness and Response
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Emergency Preparedness and Response 4.4.7
• Identify potential emergency situations and potential accidents and how organization will respond
• Seek to prevent or mitigate adverse environmental impacts
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Tell those on-site
Ensure contractors/suppliers can access emergency information (and procedures if needed)• Current phone number (s)• Map• __________
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Test and Revise Procedures
• Periodically test procedures where practicable
• Review and revise procedures as needed. – Periodically – After drills – After an accident
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AMMONIAOR OTHER
INSIDE OROUTSIDE
BLDG.
OTHER CHEMICAL
DO SAFELYSOURCE IF POSSIBLE TO
IF ONGOING - STOP
(4290) TO NOTIFY ALL TOSTAY OUT OF AREA
USE PLANT-WIDE PAGING
OUTSIDE INSIDE
LARGEUNCONTROLLEDOR SMALL
CONTROLLED
LARGE UNCONTROLLED
DO SAFELY
IF ONGOING - STOPSOURCE IF POSSIBLE TO
IN BUILDINGSTAY OUT OF AREA
NOTIFY EVERYONE
BARRIER TAPEWITH
ISOLATE AREA
SHIFTNOTIFY
SUPERVISOR
IN BLDG.IF DANGER EXISTS
ACTIVATE FIRE ALARM
CALL FIRE DEPARTMENT
IF NEEDEDAND NOTIFY SECURITY
IS CLEARWAIT UNTIL AREA
TO ENTER
MANAGEMENT WITHSPILL INFORMATION
REPORTS AND OTHERCOMPLETE INCIDENT
NOTIFY SUPERVISOR
CALL WASTE
APPLICABLE REPORTS
ISOLATE
WEARING PPE (SEE MSDS)(GOGGLES, GLOVES, APRON)FLUSH SPILL TO NEAREST
AREATHE SPILL
SUPERVISORSHIFT
NOTIFY
SMALL CONTROLLED
PROCESS DRAIN
TO STAYNOTIFY PERSONNEL
CLEAR OF AREA
CONCENTRATEOR
DUST
SUPERVISORSHIFT
NOTIFY
(RESPIRATOR & GOGGLES)CLEAN W/LOW PRESSURE
FLUSH OR WET VACUUM
WEARING PPE
NO HIGH PRESSUREOR BROOMS
OF WATER
CLEAN THOROUGHLYWITH LARGE AMOUNT
MATERIAL GOING TOMANAGEMENT OF
NOTIFY WASTE
PREPARE INCIDENTREPORTS AND OTHERAPPLICABLE REPORTS
SUPERVISORCLOSE D
NOTIFY T
VEOPE
CHAN
PERSONDUST SH
EVALUATE SIZE
FULL FACERESPIRATOR,
OPEN DOORSTO STAY AWAYNOTIFY OTHERS ACTIVATE SITE-WIDE
ALARMFIRE ALARM
EVACUATE BLDG.ACTIVATE
SUPERVISOR
NOTIFYSHIFT
AMMONIA
ENZYME, BROTH, DUST, OR CONCENTRATE
& LOCATIONOF RELEASE
SMALL
LARGE
CATASTROPHIC(SITE AFFECTED)
IN GranTDUST RELEAS
SUPERVISOR
?
?
?
?
?
CONCENTRATE
AREAGO TO GATHERING
PERFORM HEAD COUNT
GO TO SITE-WIDE
PERFORM HEAD COUNTGATHERING AREA
SPILL RESPONSE AND NOTIFICATION
SPILL
(Blue)STORM SEWER
?
IS SPILL
NO
REACHING SOILOR GOING DOWN
YES
(Red)PROCESS SEWERFLUSH TO
MANAGEMENTWASTE
(SEE PROCEDURE)
CALL
YES NO
SUPERVISORSHIFT
NOTIFY
NOTIFY SUPERVISOR
SHIFTSUPERVISOR
NOTIFY
REPORTS AND OTHERCOMPLETE INCIDENT
APPLICABLE REPORTS
EMERGENCY - STOPAMMONIAACTIVATE
EMERGENCY - STOP
ACTIVATEAMMONIA
ENZYME
CHEMICAL
WEARING
ISOLATE AREA
BROTH OR
BROTH
SUPERVISORAPPROVAL
AFTERPROCESSSEWER
ORSTORM
?
STORM SEWER
STORMSEWER
SEWERPROCESS
TO PROCESS SEWER
TO PROCESS SEWER
?
(RED)
(Blue)
CALL 911OR SECURITY
SHIFT SUPERVISOR
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Example EMS Procedures and Forms
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Exercise 1.PB&J
• Read and complete exercise.