EMS Feasibility Study

Summary &Analysis of the June I999 Project

INTRODUCTION ........................................................................................................... PAGE 3

Project Objective

Project Scope

Team Members

PROJECT DESIGN ....................................................................................................... PAGE 5

FACILITY AUDITS ........................................................................................................ PAGE 6

ASPECTS AND IMPACTS ............................................................................................ PAGE 8

MMHl Power Plant ............................................................................................... Page 8

DOA Fleet Shop ................................................................................................ Page 11

OBJECTIVES AND TARGETS ................................................................................... PAGE 15

PROJECT FINDINGS AND CONCLUSIONS ............................................................ PAGE 16

APPENDICES ......................................................................................... PAGE 19

Appendix A: Identification of Environmental Aspectsllmpacts .................. Page 20

Appendix B: Process Flowcharts ................................................................... Page 33

Appendix C: EMS Objectives & Targets ........................................................ Page 35

Appendix D: Objectives and Targets Charts ................................................ Page 48

REFERENCES ............................................................................................................. PAGE1 9

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In 1996, The lntemational Organization for Standardization (ISO) published IS0 14000 standards for environmental management systems (EMS). These voluntary standards established a framework for developing an effective EMS and methods for measuring its success.

Many industries and businesses have begun to consider the benefits of instituting EMS to improve their operations. The federal and state environmental regulatory agencies have reviewed these methods for improving environmental management and have indicated that facilities successfully adopting these methods may be granted regulatory flexibility in the future.

In order to determine if an EMS or portions of an EMS would improve state agency environmental performance, the Wisconsin Department of Administration Bureau of Risk Management formed a project team. The team brought together the expertise and experience of environmental managers from industry and state agencies as well as the employees of the two state facilities selected for the project.

The Department of Health and Family Services’ Mendota Mental Health Institute Power Plant and the Department of Administration Central Fleet operations were selected for this EMS feasibility study. These facilities were selected for the project for the following reasons:

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The facilities have been working on improving environmental management in the last four years Facility personnel are familiar with the requirements of applicable environmental regulations The middle and senior management of the facilities and their respective state agencies are interested in the potential benefits of implementing an EMS The operations and attitudes at these facilities are representative of agency operations throughout the state and therefore could be a good measure of the applicability to other state operations The level of environmental awareness and effectiveness of current environmental programs is not equal at the two selected facilities The close proximity of the facilities to the team members’ places of employment

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This project report, EMS Feasibildy Study: Department of Administration Central Fleet 8, Mendota Mental Health Institute Powerplant, documents the efforts of twelve project team members to determine the feasibility of an EMS for these state owned and operated facilities.

Project Objective

This project was designed to assess and evaluate the current environmental management practices at state agency pilot facilities. Following this assessment and evaluation, project team members were asked to:

0 Establish objectives and targets 0

Identify environmental aspects and impacts

Identify an environmental management system to achieve the objectives and targets

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Project Scope

The project scope was limited to three essential project team tasks:

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Assessment of the environmental management program including current compliance, record keeping and operational practices through an onsite audit of each facility Identification of activities, products and services that impact the environment Identification of measures and programs for improving environmental management and reducing environmental impacts

Team Members

Lynn Laszewski, DOA Environmental Manager Bret Wagner, Chemical Engineering Student UW-Madison Neil Howell, Power Plant Engineer DOA Division of Facilities Development Rob Sherman, Manager of the Environmental Engineering Operations Group Krafl Foods Tim Anderson, Senior Project Engineer for Environmental Affairs Rayovac Pam Christenson, Clean Air Specialist Department of Commerce John Shenot, Energy Business Sector Specialist and EMS Specialist, Department of Natural Resources Scott Smith, Safety and Security Manager Mendota Mental Health Institute Jack Barham, Assistant Power Plant Operator Mendota Mental Health Institute Jim Bogan, Fleet Manager DOA Bureau of Transportation Gordon “Gordy” Christy, Fleet Shop Lead Worker Robert “Bubba” Selheim, Refuel Crew Leader

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Pmject Design

The project procedures differed from lntemational Organization for Standardization (EO) methods developed to help organizations audit their environmental management systems (IS0 14010, IS0 1401 1, and IS0 14012). The standard was used as a guide but was not the basis for the project team’s activities. In both organizations, the EMS feasibility study included an onsite audit, identification of environmental aspects and impacts, ranking the significance of the impacts, and identification of objectives and target to address these impacts.

EMS Audit: “A systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether an Organization’s environmental management system conforms to the environmental management system audit criteria set by the organization, and for communication of the results of this process to management.” -IS0 14001

The project team walked through each facility recording observations and asking questions of facility personnel to identify operations and procedures used at the facilities. Following the audit, the project team members compiled and analyzed the audit observations. The project team reviewed each of the activities, services and products and determined if and how they affected the environment. Assessing its degree of adverse effect on the environment determined the significance of the impact. Following ranking of the impacts, objectives and targets were identified to improve the organization’s environmental risk profile.

The two organizations, Mendota Mental Health Institution power plant and Department of Administration fleet shop, volunteered for this project to obtain additional information that could improve their current environmental management practices. They could consider suggestions made by the project team and attempt to implement those that they felt were feasible. This feasibility could be determined by considering cost, staff, time, and/or management support to implement these changes.

Mendota Mental Health Institute (MMHI) a state-operated psychiatric hospital that specializes in serving patients with complex psychiatric conditions, often combined with certain problem behaviors. Mendota Mental Health Institute Power Plant is located at 301 Troy Drive, Madison.

The main source of fuel for the power plant is coal. The two multi-fuel boilers can bum coal, oil, natural gas, coal and oil, or coal and natural gas. The number one and number two boilers are rated at 50,000 Ibs. per hour at 425 psi. The number three boiler is rated at 60,000 Ibs. per hour at 475 psi. The power plant operates at 175 psi.

The Department of Administration’s (DOA) Fleet Shop is a maintenance and housing facility for state-owned vehicles. DOA central fleet operations are located at 201 South Dickinson, Madison.

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The first activity for project team members was to tour each facility to identify operations, procedures and activities that could affect the environment. The team members walked through the facilities noting environmental issues and the manner in which they were addressed by the facility’s current procedures and personnel. These issues were categorized as aspects and impacts to the environment as recommended by EMS models.

Environmental ast)ect: the aspect of the activities, products and services that affects the environment. Environmental impact: how the activities, products and services interact with the environment.

Preparation for the onsite audits included the identification of the processes that could affect the environment at each of the facilities. A checklist was developed that summarizes these processes and the auditors used the checklist to record environmental impacts and aspects that they identified. Sample checklists are included in Appendix A of this report.

Areas and processes identified at the power plant include:

Fuel storage Coal management Facility maintenance Floor drains Equipment maintenance Drinking water treatment Power generation Written procedures & records

Areas and processes identified at the fleet shop include:

0 Maintenance & shop areas 0 Floor drains

Fuel storage 0 Fueling areas 0 Vehicle maintenance 0 New vehicle prep work 0 Written procedures & records

The processes of both facilities are detailed in process flow diagrams. These diagrams examine the four major activities at each facility and the wastes produced from these activities. The wastes are tracked to their place of final disposition. Wastes can be managed by one or a combination of methods including recycling, laundering, hazardous waste disposal, and burning for energy recovery (burning for energy recovery and asphalt production for fleet shop). Waste management can affect one or a combination of environmental media including the atmosphere, groundwater, landfill, and storm and sanitary sewer (surface water, storm and sanitary sewer for the power plant). These diagrams are included in Appendix B of this report.

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On June 2, 1999 the project team members toured the facilities to identify and record potential environmental aspects and impacts, as well as environmental issues that were evident or could be possible/ probable in the future. Facility audits were limited to 1 % hours onsite.

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Aspectsandlmpads

The EMS this study provides does not include air emission impacts from coal burning and fleet vehicles since these are not under the direct control of the facilities. The project focused on the aspects and impacts of the facilities’ activities rather than services. The results of the two audits are summarized below. Each activity, product, and/or service is grouped by process (Le. fuel storage, facility management). Each process section starts in bold type.

MMHI Power Plant ~~~ ~~~ ~ ~~~~~

~ ~~~ ~ ~ ~ ~ ~~ ~~~

Environmental aspects, impacts, and potential alternatives identified are as follows.

Activities. products and services (AP&S): Fuel delivery; fuel storage in the tanks and fuel pumping to the boilers

Aspects: Spill and leak potential

Observations: Fuel is stored in a 30,000 gal. underground tank. The tank is constructed of double-wall fiberglass, and equipped with automatic leak detection monitoring. Fuel is gravity fed to the building. 30,000 gal. of fuel was delivered after tank installation. Approximately 3,000 gal. of fuel is delivered per year. Since the tank stores backup fuel for the boilers, additional fuel deliveries have not been necessary. Current fuel pumping practices include using oil dry on the floor near the pumps to absorb oil spills.

Impacts: Potential for tank and piping leaks to contaminate groundwater; disposal of oil dry in landfills; overfills of tank could contaminate groundwater

AP&S: Coal receiving; storage; preparation for burning

Aspects: Uncovered interim coal storage pile had no berms; coal storage without dust collection; coal dust generation; lubricating the coal conveyor with used oil

Observations: Current coal storage practices include receiving three loads of coal in the winter and two loads in the summer. These loads average 24.5-25 tons. Coal received in 1998 was 11,256.86 tons. Coal is shipped by barge from East Kentucky and then trucked from Prairie du Chien to the facility. Coal is stored temporarily outdoors (usually less than 24 hours) before indoor storage in hoppers and delivery to the boilers.

Impacts: Leachate from coal pile; fugitive dust; runoff discharge to sanitary sewers

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AP&S: Pump maintenance; painting; welding; facility cleaning; insulation maintenance; pallets; sewage; product and waste storage; housekeeping; floor cleaning; building physical condition; energy consumption

Aspects: Storing caustic soda and muratic acid for water treatment together; storing these two chemicals near floor drains; asbestos pipe insulation; mercury switches used on the boilers; solid waste; PCB ballasts; paint storage; use of paint thinner; disposal of used paint cans; unused paint disposal; used andlor broken pallets

Observations: Approximately 45 gallons of oil (+5 gallons) are used to maintain pumps at the facility. Jack Barham indicated during the audit that incompatible chemicals could be stored in separate rooms and that magnetic covers for floor drains had been purchased. Asbestos pipe insulation was identified in the facility. Approximately 15 linear ft. of asbestos is removed using glove bags each year. Extensive asbestos removal is done by an outside contractor. The contractor is responsible for the disposal of this material.

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-The power plant undertakes small painting projects as part of building maintenance. Current practices include using approximately 15 gallons of paint each year for these projects. Paint is stored in a designated paint storage room. Approximately 0.5 gallons of paint is disposed of each year. During the audit, it was observed that some paint containers may not be closed tightly. Unsecured gas tanks were also observed in this storage room. It is suggested that all cans are tightly sealed after use, and that the tanks be chained according to regulations.

Current housekeeping practices include recycling used fluorescent light bulbs, replacing PCB ballasts and replacing mercury-containing boiler switches. Less than five PCB ballasts are recycled every year. Before offsite shipment, these ballasts are stored in a 55-gallon drum. Several boiler mercury switches have been replaced with non-mercury switches.

Solid waste from the facility amounts to one 32-gallon trash bag per day.

Impacts: Contaminants into storm water drains; paint fugitive emissions; air emissions from asbestos removal and disposal; potential mercury contamination; potential PCB contamination; dangerous reaction of muratic acid with caustic soda; landfill disposal of waste paint brushes and paint containers

AP&S: Liquid collection (oil, water treatment chemicals); water collection; maintenance

Aspects: Storage of products and waste liquids within close proximity to floor drains; floor drains located near the boiler; floor drains on the loading dock used for chemical delivery and adjacent to chemical storage areas; cleaning floor drains

Observations: Sanitary sewer discharge is treated by the Madison Metropolitan Sewage District before discharge to Lake Monona.

Floor drains are cleaned twice per year.

Impacts: Releases and spills of chemicals in the plant could impact storm and sanitary sewer systems; landfill disposal of waste from floor drain cleaning

AP&S: Boiler scale cleanup; stack cleaning; laboratory equipment; shop rags; coolant; small parts cleaning

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Aspects: Chemical use; boiler scale and chemical disposal; management of used lubricants, cleaners and dirtied rags; disposal of fly ash; lubricants stored near floor drains; drip pan disposal

Observations: Approximately 830.8 Ibs. of polymer scale and 760 Ibs. of flake caustic are used each year to clean the boilers.

Fly ash is disposed of once every two years, and each cleaning results in approximately 16 tons of waste ash. Current practice is to dispose of this fly ash in the landfill.

Current management practices for oil spill cleanup materials includes disposing drip pans in the landfill and buming the used rags in the boilers. A pipe cutting machine used in the power plant had evidence of oil spills on the floor below it.

Currently parts are cleaned using a stoddard solvent that is recycled offsite. Approximately 20 gallons of parts cleaner is used each year.

Theefrigerants Lil3r and R-I lareused in the chillers: Approximately3350 tbs. oftheR-11 is used in the chillers. To date, there has been no waste or releases from the chiller systems.

Impacts: Sanitary sewer discharge of the chemicals and scale removed from boiler; fly ash disposal in the landfill; unanticipated releases of the LiBr and R-I 1 ; used drip pans are landfilled

AP&S: Laboratory testing; drinking water storage and supply

Aspects: Storage of water treatment chemicals; management of used laboratory chemicals

Observations: The AP&S of laboratory testing include determining the proper treatment levels of chloride, fluoride, and phosphate in drinking water. Drinking water treatment chemicals are used in the following quantities:

0 Chloride: 1986.2 Ibs./yr 0 Fluoride: 331 8.9 Ibs./yr 0 Phosphate: 2973.5 Ibs.lyr

Current practice is to sample the water daily, and treat the water with the appropriate level of chemicals. These chemicals are added to the water that is pumped from two wells. Both wells are approximately 700 ft. deep. Water pumped from Well # I is used at the facility. Water pumped from Well #2 is used to maintain water in the reserve tank.

Impacts: Spills and releases of drinking water treatment chemicals could affect sanitary sewer

AP&S: Coal buming and water use to create steam; backup generator use

Aspects: Release of heat; release of smoke in a pressure change; water consumption; stack emissions; production of heat in the summer; solid waste; backup generator emissions and noise; ash (fly, bottom)

Observations: Bottom ash generated in 1998 was 1,149.9 tons. The ash content varies. Current practice is to vacuum the ash into an ash silo before reusing the ash offsite as road surfacing material. Ash is removed from the facility one day per week.

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Impacts: Emissions impact the environment by contributing to local and regional air quality problems

AP&S: MSDS; waste inventory; product inventory; training; labeling; maintenance record; disposal and recycling; waste manifestlreceipt

AsDects: Lack of a waste inventory

Observations: Current MSDS practice is to display them near each of the products, as well as include scanned images online for easy reference.

No general tracking program was observed for the bottom ash disposal, however the recycling of the ash appeared to be effective.

Training was observed in both asbestos and maintenance areas, spill response, and confined space.

During the audit, several drums of spent resin and two drums of tank sludge from the fuel tank removal project were observed at the facility. These wastes had been stored for more than a year. It is suggested that the facility keep written records of product and waste inventories to aid in prompt disposal of hazardous and non-hazardous wastes. It is also suggested that all containers be labeled so that no question or hazard arises from the contents.

~~ ~~~ ~~ ~ ~

Impacts: Extended periods of waste storage and necessity for increased waste storage space increases the risk of spills

DOA FIeet Shop

Environmental aspects, impacts, and potential altematives identified are as follows.

AP&S: Product storage; housekeeping; floor cleaning; building physical condition; energy consumption; sewage; pallets; cardboard and paper

Aspects: Poor condition of paint on the ceiling; unlabeled drums; rainwater runoffblooding; disposal of floor sweepings; management of old or unused cleaners, gasoline and other materials generated by the shop

Observations: The ceiling had paint that was either peeling or had peeled off in the shop and warehouse areas. It is unknown whether any of this paint is lead based. Current practice is to sweep the paint flakes that fall to the floor and dispose of them in the landfill. Suggested altematives include checking the paint for lead content and repairing or repainting the ceiling.

In the product and waste storage areas, there were unlabeled drums, and an open and unlabeled drum was observed in the courtyard. A can of old, unused gasoline was observed in the shop area. Several storage rooms that had no light, broken lights, or inadequate light. It appeared that these rooms contained unaccounted for wastes, including tires and drums. Spill equipment and fire extinguishers were not located near these storage areas.

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During heavy rains, rainwater runoff enters the shop through the gap below the exterior door and floods the shop floor.

Impacts: Disposal of paint flakes in landfill; paint in floor drains; water from floor cleaning could affect the environment through discharge of chemicals, oils, and cleaners to the sanitary sewer that discharges to surface water; used mops, brooms, rags, floor dry and floor sweepings are disposed of in a landfill; laundering of shop rags and mops offsite; discharges from offsite commercial laundries impact the sanitary sewer system; recycling of discarded cardboard and paper offsite

AP&S: Liquid collection; rainwater collection; maintenance

Aspects: Oil, fuel and chemicals entering floor drains

Observations: Current floor drain maintenance practice is to clean the drains from “time-to-time” on an “as ~needed” basis. The grit containment drain in the vehicle washing area i s cleaned once every 1-2 years. It i s

suggested that the locations and types of spill materials in the shops and near the fueling areas be reviewed to determine if it is adequate.

Impacts: Oil, fuel and chemicals carried by rainwater to storm sewer

AP&S: Fuel delivery; 1,000 gal. LP tank; 1,000 gal. ethanol tank; 10,000 gal. petrol tank

Aspects: Fuel vapors; fuel spills; potential for leaks from piping and tanks; fire hazards

Observations: While there is an automatic shut-off and overfill protection for the underground tank, there is no automatic tank gauging. There was one extinguisher noted by the ethanol tank.

Fueling demands for fleet vehicles include approximately 650-700 gallons of ethanol per week. When the facility is at its busiest, the fuel demand is 1,000 gallons of ethanol per week. Petrol demand is approximately 400 gallons per day.

Suggested altematives to reduce environmental impacts include containment berms around the aboveground tank, instituting procedures to prevent overfills, and keeping accurate product inventory.

Impacts: Storm water and groundwater contamination by potential leaks; vapors impact the environment by contributing to local and regional air quality problems; spills impact the environment by contaminating the land, surface water and/or groundwater

AP&S: Vehicle fueling; solid waste; insect control; rainwater runoff

Aspects: Release of vapors during fueling; potential for fuel spills; fueling vehicles with the wrong type of fuel; pesticide vapors; wasted pesticides and containers if cans are disposed of only partly used

Observations: An automated inventory control or leak detection system could give early waming of leaks.

Minimal instruction for fuel dispensing is provided in the area of the tanks.

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A storm drain is located very near to the fueling stations. Current practice does not provide an effective response to this runoff. A suggested altemative is to provide a covered (not enclosed) area for fueling and suitable protection for the storm drain.

Insects are a nuisance near the garbage cans in the fueling area. Current practice is to spray pesticides in this area. A suggested practice could be to include a recycling bin in this area and tightly covered containers.

Impacts: Release of fuel vapors to the atmosphere; spilled fuel to the storm sewers (this area is prone to rain and snow); dispensing the wrong fuel could result in wasted fuel and potential harm to the driver and vehicle; worker exposure to pesticides; landfill space used for pesticide container disposal

VehDcle Malntenance

AP&S: Brake maintenance; windshield wipers/fluid replacement; oil changes; tire, antifreeze, belt and hose replacement; spark plugs; air filters; battery and headlight replacement; lubrication of equipment; vehicle washing; vacuuming and carpet cleaning; small parts cleaning

AsDects: Used filters; used antifreeze; used oil; oil spills and overflows; used lubricants and cleaners; dirtied rags; used tires and tire weights; storage and disposal of old batteries; acid leaks from batteries; replacing batteries too early; grit, soap and oil in the wastewater from car washing; salts (chlorides) in wastewater during the winter

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Observations: All bodywork and other labor-intensive work (Le. replacing glass, chassis work) is contracted out of the shop.

Current practice for brake maintenance is wash brakes with hexane. Environmental aspects associated with brake washing are solvent vapors and spills, worker safety and possibly affecting local and regional air quality. Spills stem from the observation that the brake wash is bought in 20 gal. drums and must be transferred to hand-held spray cans. It is suggested that a less toxic alternative to hexane should be investigated and/or hexane be purchased in smaller quantities.

The Fleet Shop disposes of approximately 500 tires each year. There is currently no inventory of used tires. The waste tire storage room appeared to have no nearby fire control equipment. Storing waste tires in a number of locations in the facility for an extended period may cause problems with insect and rodent control.

Current practice is to have the batteries recycled by Northem Battery & Recycle, at a rate of approximately 105 batteriedyr. There are between 3 and 15 batteries in storage on pallets at any given time at the facility. There is currently no spill protection in the storage areas.

The shop disposes of approximately 20-oil filtershnreek and 500 gallons of used oil/ 3 months. Used filters, the oil that remains in the filter, and the oil spill cleanup materials are disposed of in the landfill. Suggested altematives include investigating the possibility of using 100% recycled motor oils for fleet vehicles. A suggested altemative to disposing of the oil filters in a landfill is to recycle the filters, as these are readily recyclable.

Changing the antifreeze produces approximately 100 gallons of used antifreeze each year. Current practice is to blend the antifreeze with waste oil and burn it offsite for asphalt production. A suggested alternative to burning antifreeze is to recycle it.

Car wash water is discharged to the sanitary sewer. Grit is disposed of in the landfill. A suggested practice is to install an oilhnrater separator to decrease the oil discharge to the sanitary sewer.

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A biodegradable citrus-based metal cleaner is used for small parts cleaning. The shop recently switched to this cleaning system. It is anticipated that the parts cleaner will be reused until it is no longer suitable for cleaning. Then it will be discharged to the sanitary sewer. A suggested altemative to the current method of small parts cleaning is to use a filtering system to lengthen the useful life of the cleaner.

Impacts: Wom brake shoes disposed of in the landfill (shop disposes of an average one brake shoeheek); waste tires use landfill space; used as fuel, tires contribute to local, regional, and global air quality impacts; batteries are recycled via smelting which can affect air and soil near the smelting facility; wasted resources if batteries are replaced too early; leaking battery acid could damage floors; inadvertent release of waste antifreeze to sanitary and storm sewers; materials contained in wash water could place burden on sewage treatment plants; buming antifreeze and used oil contributes to air quality impacts; oil spills on floors that are not promptly cleaned up could increase the burden on sanitary sewers and can contribute to local surface water quality impacts

-AP&S: Replacing old decalswitkfleet &cats; oil and antif-eezechecks

Aspects: Waste from new decal backing; preparing the vehicle surface for decal adhesives; spills during antifreeze/oil checks

Observations:

Impacts: Solid waste disposal in landfill

AP&S: MSDS; training; maintenance; waste manifestlreceipt; spill prevention and cleanup; storage tank inventory; waste inventory; product inventory

Aspects: Lack of a waste inventory; lack of spill prevention or spill emergency planning

Observations: Not all MSDS were readily available in the service areas. Records for maintenance, waste inventory, and product inventory were not observed. Storage tank inventory was reported to be a “stick inventory method, and it is felt that this method is unreliable for leak detection.

Impacts: Extended periods of waste storage and necessity for increased waste storage space increases the risk of spills

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After the team members identified activities, products and services that affect the environment, the team met to determine the significance of these issues. In order to determine the significance of each aspect and impact, the team members considered:

0 Frequency of occurrence 0

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0 Feasibility of implementing change

Potential for substantial harm to the environment Current methods to remedy the impact

After the significance of each aspect and impact was determined, the team established environmental objectives and targets in order to reduce their effect on the environment. Objectives and targets also provide a measure of the effectiveness of its environmental efforts and improve the performance of the EMS. In establishing environmental objectives and targets, the team members considered:

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Applicable laws and regulations (and requirements of other programs) Environmental aspects and impacts of the organization’s activities, products and services Technological, financial, operational, and other business requirements The views of employees and other interested parties

Environmental obiective: A site goal that is consistent with the environmental policies and considers significant environmental impacts and applicable laws and regulations. Objectives are quantified wherever practicable. Environmental taruet: A detailed performance requirement (quantified wherever practicable) based on an environmental objective. A target should be met in order for the underlying objective to be achieved.

The most significant aspects and impacts identified at the MMHl Power Plant include activities, products and services associated with waste inventory, product storage, sanitary sewer use, floor drain management, painting, stack emissions, and stack cleaning. Less significant aspects and impacts include pumps, MSDS record keeping, coal storage, housekeeping, floor cleaning, insulation maintenance, and shop rags. MMHl impacts, objectives, and targets are detailed in Appendix D.

The most significant aspects and impacts identified at the DOA Fleet Shop include activities, products and services associated with brake maintenance, lead acid batteries, waste inventory, fuel storage, floor drain management, MSDS record keeping, oil changes, and housekeeping. Less significant activities, products and services include insect control, solid waste, floor cleaning, tires and fuel storage. DOA Fleet Shop impacts, objectives, and targets are detailed in Appendix D.

Targets for meeting the objectives were developed by the team members after consideration of:

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Associated regulatory compliance issues

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The level of significance of the aspect and impact to the environment

The facility’s current workload and project schedule Level of monetary and personnel resources needed to accomplish the objectives

Each target is a quantified goal of when the objective is to be accomplished. Either a specific date was listed as the goal or the time frame was given to meet the objective.

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Ppject Findings & com=lusions

Feasibility of EMS. It is the consensus of the project team that an EMS would heighten environmental awareness and improve environmental performance at the facilities. However, development of an EMS as outlined by the IS0 14001 standard would not currently be advantageous or necessary to achieve these results. The facility’s customers who include the community, legislature and agencies do not require certification. However, improved environmental performance through phased implementation of an EMS could improve employee involvement in environmental issues and improve their relationships with their customers.

It would be not be feasible to expect rapid implementation of a complete EMS at either facility. As the facilities began phasing in pieces of an EMS, there would be barriers to complete, or even partial, implementation of an EMS. Significant barriers to going beyond compliance include the budget process and the limited control facilities have on important aspects of the services they provide. Reducing costs through environmental performance does not directly benefit the facility. Money saved through reduced operational costs reduces the money the facility receives for its operating budget. Therefore, cost savings generated by an EMS do not directly provide additional money for other uses at the facility.

The facilities in this project provide services for other State operations. The fleet shop provides vehicles for state employees to use in the course of their business and the power plant provides steam and electricity for the MMHl facility. The most significant environmental impacts identified by the project team members for these services are the car emissions and the power plant emissions. In both instances, the factors directly responsible for air emissions are not under the direct control of the facility. The Department of Administration or the legislature selects coal, fuel and vehicles for these services. Therefore, unlike private industry, the facilities do not have direct control of their most critical environmental aspects and impacts.

The level of effort required to implement an EMS depends on the complexity of the EMS. The facilities in this study could improve their current systems with relatively simple modifications to existing procedures. Environmental aspects, impacts and objectives identified for their activities were basic and would not require capital improvements or equipment purchases to achieve objectives and targets. If a facility wished to consider air emissions associated with providing vehicles and power, the EMS would become more complex.

DOA Fleet. Due to their limited resources, DOA Fleet Shop may not be amenable to an extensive EMS. An EMS for Central Fleet could consist of a notebook and file that contain a list of wastes generated and hazardous materials used, a waste inventory log, spill prevention and response plan and procedures, and a list of persons responsible for implementing and maintaining these documents. This notebook should also contain any existing documents and procedures for environmental compliance and copies of waste disposal/ recycling receipts and manifests.

One problem that the DOA Fleet Shop staff communicated was the lack of cooperation between the different facilities using the building. The DOA Fleet Shop is located in a large warehouseloffice facility used by at least four different organizations. Responsibility for each building area and room is poorly defined. This has led to maintenance, housekeeping and material storage problems that have not been addressed.

In order for the EMS to be successful, DOA Fleet Shop should develop and implement the pieces of their EMS incrementally. Developing and implementing pieces of an EMS as the facility is ready to undertake another task would allow more time to properly implement and adjust the previous element. Phased implementation will also allow the staff to plan to meet their next objective while continuing routine tasks at the shop.

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MMHl Power Plant. This facility has a strong commitment to improving its operations and implementation of an EMS could become part of this improvement initiative. Incorporation of a formal EMS at MMHl Power Plant could begin with adopting the targets proposed by the project team (see Appendix D). A leader for this effort should be designated and management support would be required. The EMS should include mechanisms for periodic review to assure targets are met and to assure new aspects, impacts and targets are added with plant changes.

Procedures that could enhance the EMS include creating a spill and storm water management plan, and a materials inventory to track material consumption. Coal use could also be targeted. Tracking how much coal is used, the levels of contaminants generated by different types of coal, the coal buming efficiency, and amount of ash produced by the coal could be considered. Goals could be set for exceeding the regulatory requirements for emissions control and energy efficiency. This may require assistance from the Department of Administration, which is responsible for coal purchases. Development of a record keeping system would entail consolidation of the facility’s existing procedures, programs, readings, monitoring activities and documents. It would also include developing tracking and measuring methods for the objectives and targets.

Recommended actions. Actions that MMHl Power Plant must take first to implement an EMS include developing a product inventory, documenting responsibilities and procedures, and creating a waste log. After developing these documents, the facility could refine them into standard operating procedures.

The first action of DOA Fleet Shop should be to schedule a meeting with all parties who use the Fleet Shop building. The purpose of this meeting is to determine the responsibility for each part of the building. This could improve improper or unknown waste storage and define housekeeping responsibilities for each area of the facility. Other actions of importance include training the facility staff on compliance issues and the consequences of noncompliance, and fostering an improved in attitude toward environmental issues.

Team members noted a number of positive attributes at the MMHl Power Plant and DOA Fleet Shop. Personnel at the power plant kept a positive attitude throughout the project, demonstrating enthusiasm and an understanding that an EMS could make their work easier. Housekeeping at the facility was very good, exhibiting pride in their facility.

DOA Fleet Shop’s most notable attribute is the organization and cleanliness of the shop area. Attempts to reduce products was a positive step, along with installation of a suction system for the used oil tank. The voluntary use of alternative fuels in fleet vehicles is a good indication that the shop is thinking environmentally rather than strictly economical.

Project applicability to other state facilities. The team members felt that the broad spectrum of environmental aspects identified at the facilities would make this project a good model for any state facility considering development of an EMS. A state facility contemplating developing an EMS and assessing its potential impact on operations could use the forms and flow charts from this project as a model for identifying aspects and impacts, as well as objectives and targets. The majority of the planning and implementation of an EMS should be done by the organization. Employees at the facility have the greatest understanding of the needs and objectives of its operations.

Project modifications. Project team members suggested modifications to this project‘s format and scope so that similar projects could have improved project design. They suggested that the team have more time for pre-project preparation, including review of the facility’s processes and documentation. They also suggested a pre-audit questionnaire requesting information on processes and procedures could be completed so that these questions would not have to be asked in the noisy work areas of the facilities during the audit. It was also critical that key personnel and specified records be available during the audit. The project team would have liked to spend more time auditing the facilities. The scope of the project should have included vehicle emissions and power plant emissions even though these are not under the direct control of the facilities, these aspects are the key environmental impacts attributable to the facilities.

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Follow-up activities. The project team recommends that both facilities evaluate the objectives and targets identified by the project team and consider the feasibility of each target. If the facility feels the target is feasible (feasible meaning having the necessary resources and management support), it could be implemented. If the facility evaluates the target and concludes that it is not possible, they may want to modify the target to fit their schedule.

Specific actions that DOA Fleet Shop may want to take include performing periodic audits to check the facility’s progress. The shop may also want to perform a study on vehicle emissions to help make informed choices on vehicle purchases.

Specific actions that MMHl Plant Power may want to take include communicating periodically with DOA to obtain assistance in both clarification and implementation of an EMS. Assigning a team to specifically design and implement a documentation system could begin the process of formalizing the EMS.

Current plans are to schedule a follow-up to this project in six months to report if and how the facilities have made the changes suggested by the project team. Other follow-up activities include evaluating a Department of Natural Resources facility for EMS feasibility and assisting MMHl with evaluation of their current document control system.

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Appendix A Identification of Environmental Aspectdlmpacts

Appendix B Process Flowcharts

Appendix C EMS Objectives & Targets

Appendix D Objectives and Targets Charts

Davis, S. P. Implementing and Environmental Management System in Commundy-Base Organizations Part 1: Project Report NSF Intemational: Ann Arbor, 1998.

Stapleton, Philip J., Anita M. Cooney and William M. Hix Jr. Environmental Management Systems: An Implementation Guide for Small and Medium-Sized Organizations. NSF International: Ann Arbor, 1996 and 1998.

IS0 14001 : 1996. Environmental management systems- Specifications with guidance far use.

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