Environmental Compliance

Draft 1/11/2006

FUNCTIONAL AREA GOAL:  The site has an Environmental Management System (integrated into the site's Integrated Safety Management System) (ISMS/EMS) which ensures compliance with regulatory requirements through identification of environmental compliance requirements, incorporation of requirements into site policies and procedures, periodic assessment of regulatory compliance, and identification and implementation of corrective action where needed.

REQUIREMENTS:

Compliance Management Requirements

Underlying Legal Requirements:

Note: these requirements are intentionally not enumerated;  compliance is required with all applicable requirements.

GUIDANCE:

Performance Objective 1: Contractor Program Documentation

The contractor's ISMS/EMS includes procedures to identify all applicable legal requirements. It includes policies and procedures to ensure compliance with these requirements. The ISMS/EMS includes a program to assess regulatory compliance, identify potential non-compliances, and implement corrective actions.

Objective 1.1: All Applicable Legal Requirements and Identified: Identify activities with significant environmental impacts'; 'Identify the hazards

Criteria:

  1. The ISMS/EMS includes policies and procedures to identify activities which are subject to regulation. (DOE O 450.1 §4.a.(2)).
     
  2. Before work is performed, the associated hazards are evaluated and an agreed-upon set of ES&H requirements is established. (DEAR Clause 970.5223 (a)(5))

[Lines of inquiry to be developed]

Objective 1.2:  Ensure that Policies and Procedures are in Place to Assure Compliance: Manage control and mitigate the impacts of activities with significant environmental impacts'; 'Develop and implement hazard controls

  1. The ISMS/EMS provides for the systematic planning of programs for compliance with applicable requirements. (DOE O 450.1 §4.a.(1)).
     
  2. The ISMS/EMS includes policies and procedures to ensure compliance with regulatory requirements. (DOE O 450.1 §4.a.(2))
     
  3. The ISMS/EMS includes procedures to manage, control, and mitigate the potential impacts of site activities with significant environmental impacts. The ISMS/EMS provides for the integrated execution of programs for compliance with applicable requirements. (DOE O 450.1 §4.a.(2); .DOE O 450.1 §4.a.(1))

[Lines of inquiry to be developed]

Objective 1.3 Processes are established to assess compliance and implement corrective actions where needed:  Assess performance and implement corrective actions where needed'; 'Provide Feedback and Continual Improvement

Criteria:

  1. The ISMS/EMS includes policies and procedures to assess performance of programs for compliance with applicable requirements. (DOE O 450.1 §4.a.(1)(c); §4.a.(2))
     
  2. The ISMS/EMS includes policies and procedures to implement corrective actions where needed. (DOE O 450.1 §4.a.(2))
     
  3. Contractor compliance assessment programs are established as part of ISM/EMS, within the framework of DOE P 226.1 and DOE O 226.1. (DOE O 450.1 §5.d.(16))

[Lines of inquiry to be developed]

Performance Objective 2: Contractor Program Implementation

Work is conducted in compliance with all applicable legal requirements. The contractor is assured that legal requirements are being met.

Objective 2.1: Work is Performed in Compliance with all Applicable Requirements:  Manage control and mitigate the impacts of activities with significant environmental impacts'; 'Perform Work within Controls

Criteria:

  1. Before work is performed, the associated hazards are evaluated and an agreed-upon set of ES&H requirements is established. (DEAR Clause 970.5223 (b)(5))
     
  2. The ISMS/EMS includes training
  3. The contractor complies with, and assists the DOE in complying with, ES&H requirements of all applicable laws and regulations. (DEAR Clause 970.5223)

[Lines of inquiry to be developed]

Objective 2.2 The contractor assesses compliance with legal requirements, and implements corrective actions where needed.

Criteria:

  1. Contractor submits, for DOE annual review and approval, detailed contractor assurance system program descriptions to address aspects of operations including environment, safety, and health among others. (DOE O 226.1)
     
  2. Compliance is assessed as a component of the implementation of DOE P 226.1 and DOE O 226.1. Contractor compliance assessment programs are established within the framework of DOE P 226.1 and DOE O 226.1, and continue to be effective. (DOE O 450.1 §5.b.; DOE O 450.1 §5.d.(16))
     
  3. ISMS/EMS environmental goals, objectives and targets are reviewed and updated annually. (DOE O 450.1 4.a.(3)

[Lines of inquiry to be developed]

Performance Objective 3: DOE Line Management Oversight

DOE line management assures that all operations under their purview are operating in compliance with applicable legal requirements. DOE is in compliance with legal requirements applicable to DOE.

Criteria:

  1. DOE ensures compliance with legal requirements. (DOE P 411.1)
     
  2. DOE assesses ISMS/EMS implementation, including regulatory compliance, as a component of the implementation of DOE P 226.1 and DOE O 226.1. (DOE O 450.1 §5.b.)
     
  3. Contractor compliance performance is reviewed as part of the performance objectives, performance measures, and commitments through the annual ISM review process established pursuant to DEAR 970.5223-1 (e). (DOE O 450.1 §5.d.(17))

[Lines of inquiry to be developed]



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