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Policy Area

ESH-Environment Safety & Health

Procedure Number

ESH100.1.EP.3

Procedure Title

Complete an Environmental Life-cycle Management Evaluation

Procedure Manager

HWANG, HUE-SU A.

Status

Active

Subject Matter Expert

  • Michael D. Nagy—Subject Matter Expert
  • Stephanie A. Salinas—Subject Matter Expert
  • CA, Robert C. Holland—Subject Matter Expert

 

Applicability, Exceptions, and Consequences

This corporate procedure applies to all Sandia National Laboratories (SNL) organizations, all management elements, all SNL sites, and all Members of the Workforce.  The procedure applies to any member of the workforce who use or handle materials, which may potentially impact the environment, have a high-disposal cost, or are difficult to dispose of upon completion of the project (i.e., creation of SNL/NM legacy waste). Potential project activities may include, but are not limited to, destructive testing, explosions, or other activity that may result in dispersal and/or deposition of any of the following: hazardous substances, petroleum products, water, debris, or particulate matter. 

As part of the Life-Cycle Management Procedure:

  • All members of the work force will ensure that life-cycle management is a key component of their planning.
  • All members of the work force will ensure that the endpoint of the product, project, and material is considered prior to proposing the acceptance of work.
  • All members of the work force will ensure alternatives and/or substitutes to the product, project, and materials that have a high ES&H impact or cost have been considered.
  • All members of the work force will ensure how to appropriately dispose of and clean up product, project impacts, and materials. In addition, that the activity is appropriately funded (early in the project planning) by competition of the Environmental Life-cycle Management Form (SF 2001-LCM).

Exceptions to, or deviations from, this procedure must be approved through the Executive Policy Sponsor or Policy Area Manager, if delegated (see Contacts for Corporate Policies, Processes, and Procedures).   See CG100.1.7, Request an Exception to a Policy, Process, or Procedure, for directions on how to obtain an exception to this procedure.

Granting or permitting exceptions or violations of policy, process, or procedure without authority, regardless of position or title, may be cause for disciplinary action up to and including termination of employment. Violating a policy, process, or procedure may be cause for disciplinary action up to and including termination of employment.

IMPORTANT NOTICE: A printed copy of this document may not be the document currently in effect. The official version is located on the Sandia National Laboratories Sandia Restricted Network (SRN).

Procedure Overview

A life-cycle conception and disposition approach looks at all stages of products, projects, and materials’ life.  It provides a comprehensive view of environmental aspects and impacts.  With this procedure, SNL will minimize and account for a projects impacts to the environment. This procedure, through the completion of the Environmental Life-cycle Management Form (SF 2001-LCM), evaluates environmental impacts at all stages of the project and identifies approaches to minimize those impacts and ensures proper disposal and/or cleanup at the end of the project.

Procedure Requirements

Complete an Environmental Life-cycle Management Form via the NEPA Process

Step Responsible Individual Required Action
Step 1 Members of the Workforce

Follow SNL’s waste management hierarchy:

  • Waste should be reduced or eliminated at the source.
  • If waste cannot be reduced or eliminated at the source, non-hazardous waste or material should be reused or recycled. The division ES&H team environmental compliance coordinator (ECC) should be consulted for details on applicable requirements.
  • If waste cannot be reduced or eliminated at the source, reused, or recycled, contact the division ES&H team ECC for additional help.
  • Document waste minimization efforts.
  • Refer to ESH100.2.ENV.22 for further hazardous waste management requirements.
Step 2 Owner of a Proposed Action (Members of the Workforce)

Complete National Environmental Policy Act (NEPA) Checklist.

  • Use the Integrated Safety Management System (ISMS), NEPA Software process described in the subsection titled “NEPA Checklist Creation,” or a Sandia Site Office (SSO) approved equivalent process, to complete a NEPA checklist.
  • Log onto the ISMS Software home page and create a new record.
  • Complete all seven screens of the NEPA checklist.
  • Submit the checklist.
  • A NEPA determination must be received prior to initiating work.

For further information on the NEPA procedure, refer to ESH100.1.EP.2.
Step 3 Owner of a Proposed Action (Members of the Workforce)

Receive Notification of Environmental Life-cycle Management Form Requirement.

  • Upon review of the NEPA checklist, a determination will be made whether the proposed action will use or handle material that may:
    • Potentially impact the environment, including activities such as destructive testing, explosions, or other activities that may result in dispersal and/or deposition of any of the following: hazardous substances:  petroleum products, water, debris, or particulate matter.
    • Have a high-disposal cost.
    • Be difficult to dispose of or have no disposal pathway.
  • If the determination is affirmative, the owner of the proposed action will receive notification that an Environmental Life-cycle Management Form (SF‑2001‑LCM) is required.

The Environmental Life-cycle Management Form must be completed prior to approval of the NEPA checklist.
Step 4 Owner of a Proposed Action (Members of the Workforce)

Complete the Environmental Life-Cycle Management Form as follows:

  • First, download the Life-Cycle Management Form (SF 2001-LCM)
  • Complete all required sections.
  • Verify that the form has been signed by the owner of the proposed action and the department manager.
Step 5 Owner of a Proposed Action (Members of the Workforce) Submit the Life-Cycle Management Form as an attachment to the associated NEPA checklist through required permits.
Step 6 Long-term environmental stewardship (LTES) SME Verify the information within the Life-Cycle Management Form for completeness and track the project through completion.

Complete an Environmental Life-cycle Management Form Outside the NEPA Process

Step Responsible Individual Required Action
Step 1 Members of the Workforce

Follow SNL’s waste management hierarchy:

  • Waste should be reduced or eliminated at the source.
  • If waste cannot be reduced or eliminated at the source, non-hazardous waste or material should be reused or recycled. The division ES&H team environmental compliance coordinator (ECC) should be consulted for details on applicable requirements.
  • If waste cannot be reduced or eliminated at the source, reused, or recycled, contact the division ES&H team ECC for additional help. Document waste minimization efforts.
  • Refer to ESH100.2.ENV.22 for further hazardous waste management requirements.
Step 2 Owner of a Proposed Action (Members of the Workforce)

Need for Life-cycle Valuation:

  • A determination will be made if the proposed action will use or handle material that will:
    • Potentially impact the environment, including activities such as destructive testing, explosions, or other activity that may result in dispersal and/or deposition of any of the following: hazardous substances: petroleum products, water, debris, or particulate matter.
    • Have a high-disposal cost.
    • Be difficult to dispose of or have no disposal pathway.
  • The owner of the proposed action must fill out an Environmental Life-cycle Management Form (SF 2001‑LCM).
Step 3 Owner of a Proposed Action (Members of the Workforce)

Complete Life-Cycle Management Form:

  • First, download the Life-Cycle Management Form (SF 2001‑LCM).
  • Complete all required sections.
  • Verify that the form has been signed by the owner of the proposed action and the department manager.
Step 4 Owner of a Proposed Action (Members of the Workforce) Submit the Life-Cycle Management Form to the LTES SME.
Step 5 LTES SME
  • Verify the information within the Life-Cycle Management Form for completeness and relay additional requirements.

Implementing Tools

  • Life-Cycle Management Form, SF 2001-LCM. 

Guidance

  • NEPA guidance.

Websites

  • ISMS Software home page.
  • ISMS NEPA software.
  • Customer Funded Record Center.
  • Environmental Planning Department.
  • Environmental Programs and Assurance.
  • Long-term environmental stewardship (LTES).
  • ILMS: Provide Executive Leadership – see Structure.
  • Life-Cycle Management Form, SF 2001-LCM.

Guidance

  • NEPA guidance.

Websites

  • ISMS Software home page.
  • ISMS NEPA software.
  • Customer Funded Record Center.
  • Environmental Planning Department.
  • Environmental Programs and Assurance.
  • Long-term environmental stewardship (LTES).
  • ILMS: Provide Executive Leadership – see Structure.

Requirement Drivers (Prime Contract Baseline Directives)

DOE O 450.1A

Additional Drivers

N/A

 

Authorities and Accountabilities

For unique roles that need to be described, use the following sequence:

  1. Review the ILMS: Provide Executive Leadership – see Structure.
  2. If the role(s) described in this procedure is listed in the SNL Structure, do not enter authorities and accountabilities in this field.
  3. If the role is not listed in the SNL Structure, you may use this field to list the role and identify the authorities and accountabilities.

Training Requirements

 

Responsible Individual

Required

Recommended

Members of the Workforce responsible for use of Hazardous Material: Owners of the proposed action who are responsible for use of hazardous materials.

N/A

National Environmental Policy Act (NEPA) Awareness (ENV120)

Hazardous Waste Training (ENV112) (SNL/CA & SNL/NM)

LTES Subject Matter Experts

ENV120

ENV112

N/A

 

Related Processes and Procedures

Plan(s)

  • PG470328, SNL Long-Term Environmental Stewardship Program Plan.

Process(es)

  • ESH100.2, Analyze and Control Hazards.
  • ESH100.3, Perform Work.
  • IM100.2, Manage and Protect Information.

Procedure(s)

  • ESH100.1.WPC.1, Plan and Control Work.
  • ESH100.1.EP.1, Implement the Environmental Management System (EMS).
  • ESH100.1.EP.2, Implement NEPA, Cultural Resources, and Historic Properties Requirements.
  • ESH100.2.ENV.2, Comply with Environmental Requirements for Migratory Birds, Protected Species, and Other Biota.
  • ESH100.2.ENV.22, Manage Hazardous Waste at SNL/NM.
  • ESH100.2.ENV.23, Manage Radioactive Waste at SNL/NM.
  • ESH100.2.ENV.24, Manage Mixed Waste at SNL/NM.
  • ESH100.2.ENV.26, Manage Other Waste at SNL/NM.

Change Summary

Date Summary
04/09/2010

Substantive

Added 

This new procedure points to the requirements that are listed in the Environmental Management System (EMS).