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DLA Strategic Materials: ESOHMS Management Review FY18
Terry Leland Chief, Environmental November 29, 2018 FOR OFFICIAL USE ONLY
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SM ESOHMS Model: Continual Improvement
ESOH Policy Plan Aspects and impacts Risk Assessment Legal Requirements Objectives and Targets Management Programs Do Policies, Procedures, and Plans Training and Awareness Communication Document Control Operational Controls Emergency Preparedness and Response Check Monitor and Measure Nonconformance Corrective and Preventative Action Records Audits Act Management Review
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ESOHMS Management Review
Environmental, safety, and occupational health policy Environmental compliance and audits Status of corrective actions Objectives and targets Environmental performance External communications from interested parties Status of follow-up actions from previous management reviews Recommendations for improvement FOR OFFICIAL USE ONLY
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Environmental Policy The Environmental, Safety, and Occupational Health Policy needs to be signed for 2019. Conforms to ISO and ISO 45001 Commits DLA-SM to: Environmental management, safety and occupational health stewardship, pollution prevention, injury and ill health prevention Compliance with legal requirements Collaboration with field activities and Headquarters Continual improvement FOR OFFICIAL USE ONLY
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Audit Findings Audit Key Findings Scotia, NY (external) July 18
1 SPCC Requirement 2 EPCRA reporting 3 Hazardous Waste EPA (Multi media) Scotia Oct 18 1 EPRCA 2 and 3 SPPC 4 Stormwater Hawthorne, NV (internal CAPP) Sep 18 1 SOP Hawthorne, NV (internal) Sep 18 None Hawthorne, NV (external CAPP) Oct 18 1 MOC 1 Evaluation and Documentation of Compliance Hammond, IN (internal) Aug 18 1 Toxic Substances 2 OSHA Haz Comm Requirements EPA (Air) Hammond Jul 18 none
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Health & Safety Inspections
No significant findings Location Date Scotia, NY June 2018 Hawthorne, NV December 2018 Hammond, IN October 2018 Youngstown, OH March 2018
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Environmental Updates and Policies
Q Depot Audit/Training Q1 Hawthorne Safety & Occup. Health Inspection √ Scotia Radiation Review Little Owl Germanium Inspection Oversight Q2 Youngstown Resp Prot Annual Review Annual resp. training and fit testing Q3 √ Q4 All HAZWOPER 8 hr refresher training Annual resp. training & fit testing External EPR Forklift Certification CAPP, Env Comp/Conf Audit & Report Hammond DMR (Depot Manager Review) Annual resp.training & fit testing Comp/Conf Audit & Report Resp Prot Annual review Goal 1: Conduct 100% of required audits and trainings.
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Annual Respiratory Reviews and Training
Trainings Training Location Date # Employees Annual Respiratory Reviews and Training Scotia, NY July 2018 5 Hammond, IN August 2018 7 Hawthorne, NV June 2018 Youngstown, OH March 2018 3 HAZWOPER Training
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FY 18 Objectives and Targets
Goal 2: Meet or exceed 100% of objectives and targets. Objective Results Reduce energy usage and cost (natural gas and electricity) Sent global to all employees directing them to these tools for Energy Awareness Month Divert 50% of solid waste from landfill in FY18 30% recycling rates Mercury no reportable spills or safety incidents Maintain mercury air emission levels below tons/year No spills or safety incidents reported Air emission levels of mercury below tons/year
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Waste Disposal Reporting (lbs)
Depot Solid Waste Recycled Waste Recycling Rate Hazardous Waste Universal Waste Used Oil Hammond 22000 5460 20% 42 Scotia 3660 3680 50%
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Site Specific Accomplishments FY18
Hammond Turned in 546,000 pounds of excess material to Disposition Services this calendar year to make room for commodity storage. No Environmental or Safety mishaps this year. No NOVs during our surprise EPA Region 5 Air visit. Scotia Received permission from NRC to continue usage of NRC permit. Initiated preparation for receipt of radioactive materials No NOVs during our surprise EPA Region 2 Multi-media visit, however; four observations are being addressed. Somerville Completed soil and groundwater delineation and submitted Final RI/FS to NJ State
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NEPA and CTCs Material Acquisitions and NEPA
Full environmental and safety review of all proposed materials. Provide technical support as needed. Member of acquisition team and attend all Gate meetings as applicable Coordinate with depots for site-specific concerns or needs. FY18 acquisition teams: Antimony Ferrodysprosium EMM SEG SMRRP Tantalum Wenden rail line revitalization Energetics – Process initiated FY18, full review in FY19 Complete rigorous process to identify and document environmental liabilities (ELs) and cost-to-completes (CTCs) for SM. Maintain full audit file.
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FY 19 Environmental Objectives
Target Divert 50% of solid waste from landfill in FY19 Revise Recycling Procedures and increase awareness of recycling program Mercury no reportable spills or safety incidents Maintain mercury air emission levels below tons/year No spills or safety incidents reported Air emission levels of mercury below tons/year Implement Earth Day environmental awareness Conduct awareness and activities.
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FY 19 Environmental Plans
Trainings and audits Annual HAZWOPER training Safety & Health Inspections Ergonomics Training Respiratory Training and Fit Tests Respiratory Protection Reviews Internal Audits at Hawthorne,Scotia,and Hammond Internal CAPP Audit in Hawthorne Radiation review at Scotia Forklift Certification at Hawthorne Met all ESOH Plan internal metrics and audit and training goals Implement, maintain and update all elements of the ESOHMS and maintain the I am the Key website FY19: Revise Spill Prevention Controls and Countermeasures Plans (SPCCPs)for the Depots
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FY19 Projects Somerville Complete wetland delineations
Develop Remedial Action Work Plan (RAWP) Delineate contamination on Somerset Co property and submit RI/FS to NJ Implement soil remediation Implement groundwater Scotia Radiation Program RSO Training and Radiation Safety training Implement Dosimeter program Review and revise Radiation Safety Program (RSP). Maintain annual monitoring and implement quarterly monitoring Hawthorne Initiate 5-year revalidation of the to Process Hazard Analysis (PHA) program, and complete a news PRS.
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Voluntary Protection Program (VPP) Certification FY19
Perform crosswalk of the 30+ components of the VPP and SM’s existing ESOHMS programs and the CAPP at Hawthorne Four elements: Management Leadership and Employee Involvement; Worksite Analysis; Hazard Prevention and Control; and Safety and Health Training. Timeline: Gap analysis and action plan (6 months); Deploy (12-18 months). Operate the sites for one full year (12 months). Undergo OSHA onsite review (6 months).
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Concerns and Recommendations
Concerns Expressed by interested Parties Somerville, NJ Remediation Questions on Status of Remediation Provide information/updates GSA uses for congressional updates Provide information/updates to Hillsborough Township/Somerset County as requested Wenden, AZ Local Water Board and School Board Status of any follow-up from FY17 Management Review None required Recommendations for FY19?
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FOR OFFICIAL USE ONLY
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