October 2005 Initial Environmental Assessment.pdf

Final Report

International Boundary and Water Commission, United States Section

Initial Environmental Assessment for Environmental Management System Development October 2005

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005

Contents

Introduction

1.1 Background and Purpose ........................................................................................1-1

1.2 Scope and Approach ................................................................................................1-1

Observations and Interviews

2.1 Observation and Interview Logistics.....................................................................2-1

2.1.1 Training Workshops .................................................................................2-2

2.2 Observation and Interview Findings.....................................................................2-5

2.2.1 Headquarters .............................................................................................2-6

2.2.2 American Dam...........................................................................................2-6

2.2.3 Nogales International Wastewater Treatment Plant ............................2-7

Initial Environmental Assessment Results

3.1 Environmental Management Review Response ..................................................3-1

3.2 Environmental Aspects and Impacts .....................................................................3-4

3.2.1 Significant Environmental Aspects.........................................................3-5

3.3 Objectives and Targets.............................................................................................3-6

3.4 Environmental Management Programs ................................................................3-6

Next Steps

4.1 Completion of Planning Phase ...............................................................................4-1

4.2 Next Steps ..................................................................................................................4-1

Appendices Appendix A Forms for Use Appendix B Aspects Identification SOP Appendix C List of Significant Environmental Aspects Appendix D Objectives and Targets SOP Appendix E List of Objectives and Targets

A 1-1

Section 1 Introduction

1.1 Background and Purpose

The United States Section of the International Boundary and Water Commission (USIBWC) is establishing an environmental management system (EMS) to satisfy the requirements of Executive Order 13148 “Greening the Government Through Leadership in Environmental Management” and that conforms to the ISO 14001:2004 international standard for continual improvement of environmental performance. As stated in the Executive Order, the USIBWC is required to develop and implement an EMS to:

“ensure that strategies are established to support environmental leadership programs, policies, and procedures and that agency senior level managers explicitly and actively endorse those strategies.”

The major elements of the ISO 14001:2004 standard include:

Environmental Policy;

Planning;

Implementation;

Checking; and

Management Review.

After documenting an environmental policy statement in May 2005, the USIBWC is currently in the planning phase of the EMS development process. The USIBWC has also established an initial EMS fence line encompassing the El Paso, Texas headquarters office, the American Dam field office in El Paso and the Nogales International Wastewater Treatment Plant (NIWTP) field office in Nogales, Arizona.

After this initial implementation, it is expected that the USIBWC will roll out the same or similar EMS at its other facilities. Therefore, the USIBWC is committed to minimizing its operational impact on the environment by complying with Executive Order 13148 and conforming to the ISO 14001:2004 EMS standard.

1.2 Scope and Approach

The USIBWC requested CDM to assist with the entire planning phase according to Clause 4.3 under ISO 14001:2004. Conformance to Clause 4.3 requires determining significant environmental aspects (SEAs), identifying applicable legal requirements, developing objectives and targets (O&Ts), and establishing environmental management programs (EMPs), which are essential to implementing an effective

EMS.

Section 1 Introduction

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005

Since the headquarters and the two field offices have not developed a formal EMS, CDM first conducted an initial environmental assessment (IEA) to provide information necessary to develop EMS components within Clause 4.3. The IEA presented in this report was conducted by CDM from October 11 to October 19, 2005 to gain an understanding of the USIBWC’s’ current position with regard to the environment in the following key areas:

organization identification of environmental aspects;

identification of applicable legal requirements;

examination of existing environmental practices and procedures; and evaluation of previous emergency situations and accidents.

The IEA consisted of document reviews, a kick-off meeting, on-site observations and interviews, and two training workshops at both the headquarters office and the NIWTP field office. The USIBWC participants in the IEA primarily included the EMS Coordinator, area managers and supervisors and operational staff. CDM conducted on-site interviews with personnel as much as practicable. The purpose of all interviews was to identify existing business processes, activities and environmental aspects and to review information such as the Environmental Policy and other policies and standards; operating and procedures manuals; measures and tools used to track and manage environmental programs and progress; organizational structure and staff responsibilities for environmental management; document and records management.

The kick-off meeting served as an introductory training session on development and implementation of an EMS. The two training workshops focused on determining significant environmental aspects and developing objectives and targets. Results from the on-site observations and interviews and two workshops were analyzed to create this report.

This report serves as a basis for continuing the development of the EMS components within Clause 4.3 under ISO 14001:2004. The remaining sections of this report present these findings. Section 2 describes the results of the on-site observations and interviews. Section 3 confirms the current position of USIBCW with regard to the EMS and presents the results from the workshops. Section 4 outlines the next steps necessary to complete Clause 4.3.

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Section 2 Observations and Interviews

2.1 Observation and Interview Logistics

The IEA began with a document review followed by on-site observations and interviews at the headquarters office and American Dam field office in El Paso and the NIWTP field office in Arizona.

Prior to the on-site assessment, the following documents and reference materials were reviewed:

Executive Order 13148;

USIBWC Environmental Policy, May 2005;

USEPA Environmental Management Review (EMR), August 2005;

USIBWC website http://www.ibwc.state.gov/;

USIBWC Report of Accomplishments for 2004;

USIBWC Boundary Marker, Summer 2005;

CDM conducted the observations and interviews from October 11 thru October 14 2005 in El Paso, Texas and then from October 17 thru October 19, 2005 in Nogales, Arizona. Table 2-1 presents the individuals and dates of these interviews.

Facility Staff Interviewed Date of Interview

Headquarters

Carlos Peña, Acting Environmental Management Division Engineer/EMS Coordinator

Gabe Duran, Civil Engineer

Sally Spener, Public Affairs Specialist/Acting Foreign Affairs Officer

Karen Williams, General Supply Specialist

Colleen Elliott, Contract Specialist

Gilbert Anaya, Geographic Information

October 11 – 14, 2005

Table 2-1

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005

Facility Staff Interviewed Date of Interview

Systems Coordinator

Hector Delgado, Construction Inspector

American Dam Tony Solo, Acting Project Manager

Mike Gonzalez, Heavy Equipment Operator

Ralph Kinner, Maintenance Worker

Carl Frietze, Maintenance and Operation

Dave Watrus, Supply Services Supervisor

Albert Ramirez, Security Guard

Frank Solis, Motor Vehicle Operator

October 11 – 12, 2005

NIWTP Glenn Hansel, Environmental Engineer

John Light, Acting Project Manager

Gerardo Federico, Acting Plant Supervisor

Javier Castro, Wastewater Treatment Plant Operator

Alison Lamb, Administrative Assistant

October 17 – 19, 2005

CDM Interviewers Johanna Jobin, CDM, Cambridge, MA

Peter Maynard, CDM, Cambridge, MA

Sarah Guemez, CDM, El Paso, TX

2.1.1 Training Workshops

CDM conducted a kick-off meeting and two training workshops at both headquarters office and NIWTP field office. The kick-off meetings served as an introduction to developing and implementing an EMS under ISO 14001:2004 and provided an overview of the IEA and the components of this project. The kick-off meeting presented an opportunity to describe what is involved with building an EMS and the

A 2-3 steps for implementation and eventually sustainability to top management personnel, including the Acting Commissioner.

Each workshop was designed to include working sessions. The second half of the kick-off meeting presented an overview of the process to identify environmental aspects and impacts and was attended by the initial Core EMS Team. The working session included:

Identifying business processes and applicable legal requirements; and

Identifying activities and environmental aspects.

The first workshop described the process for identifying significant environmental aspects (SEAs) and then included a work activity for rating environmental aspects and determining SEAs. The working session included:

Defining criteria for rating environmental aspects;

Rating each environmental aspect; and

Ranking aspects to determine significance.

Based on the results of the first workshop, the second workshop included a work activity to establish objectives and targets (O&Ts). The working session included:

Reviewing significant environmental aspects;

Defining criteria for setting objectives and targets; and

Developing objectives and targets;.

The second workshop at NIWTP did not fully occur. Rather, a summary of setting objectives and targets was given to the Environmental Engineer and Acting Plant Manager. Table 2-2 presents the dates and individuals who participated in the kick-off meetings and workshops.

Facility and Workshops Staff Present Date of

Meeting/Workshop

Headquarters – Kick-off meeting

EMS Overview

Environmental Aspects & Impacts

Carlos Peña, Acting Environmental Management Division Engineer/EMS Coordinator

Ken Rakestraw, Acting Principal Engineer, Operations Department

Cesar Boisselier, Acting O&M Division

October 11, 2005

Table 2-2

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005

Facility and Workshops Staff Present Date of

Meeting/Workshop

Engineer

Jose Nuñez, Acting Engineering Services Division Engineer

Steve Smullen, Acting Principal Engineer, Engineering Department

Carlos Marin, Acting Commissioner

Diana Forti, Acting Chief Administrative Officer

Headquarters – Workshop #1

Significant Environmental Aspects

Carlos Peña, Acting Environmental Management Division Engineer/EMS Coordinator

Jose Nuñez, Acting Engineering Services Division Engineer

Cesar Boisselier, Acting O&M Division Engineer

Glenn Hansel, Environmental Engineer (via conference call)

October 13, 2005

Headquarters – Workshop #2

Objectives & Targets

Carlos Peña, Acting Environmental Management Division Engineer/EMS Coordinator

Cesar Boisselier, Acting O&M Division Engineer

October 14, 2005

NIWTP – Kick-off meeting

EMS Overview

Environmental Aspects & Impacts

Glenn Hansel, Environmental Engineer

John Light, Acting Project Manager

Gerardo Federico, Acting Plant Supervisor

Alison Lamb, Administrative Assistant

October 17, 2005

NIWTP –

Workshop #1

John Light, Acting Project Manager

Gerardo Federico, Acting Plant

October 18, 2005

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Facility and Workshops Staff Present Date of

Meeting/Workshop

Significant Environmental Aspects

Supervisor

Javier Castro, Wastewater Treatment Plant Operator

Alison Lamb, Administrative Assistant

NIWTP –

Workshop #2

Objectives & Targets

Glenn Hansel, Environmental Engineer

John Light, Acting Project Manager

October 19, 2005

CDM Presenters Johanna Jobin, CDM, Cambridge, MA

Peter Maynard, CDM, Cambridge, MA

Sarah Guemez, CDM, El Paso, TX

Results from the workshop activities are presented in Section 3. Forms for use during the workshop activities and for use in subsequent workshops are also attached in Appendix A.

2.2 Observation and Interview Findings

The on-site observations and interviews were recorded and evaluated to confirm the USIBWC status with regard to the EMS as defined in USEPA’s EMR as well as to gather the information necessary to engage and guide the USIBWC in developing its EMS so that it meets the requirements of Executive Order 13148 and conforms to the ISO 14001:2004 standard.

Since the USIBWC is in the initial stage of the planning phase under Clause 4.3, it was evident that the organization understands its requirement to implement an EMS and has made some effort towards that commitment. The EMS Coordinator recently attended the ISO 14001 Lead Auditor Training and is establishing the Core EMS Team. The Environmental Policy signed in May 2005 is slowly becoming communicated to the USIBWC staff, but significant progress remains for both internal and external communication of the policy. USEPA highlighted some key observations and recommendations for improvement and provides a good baseline for developing the EMS components. This project will help in addressing these recommendations in the EMR.

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005

The USIBWC has begun the process of EMS planning more than once. Organizational issues have hampered progress but recent changes appear to have the program back on track with upper management support and organizational structure for environmental management being put in place.

From the observations and interviews, the Environmental Policy and Planning elements of ISO 14001:2004 are well on their way to be in good shape. Staff were aware of the EMS program and the environmental policy. Challenges for the implementation of the EMS will include establishing effective communication, both internal and external, and formalizing an environmental awareness training program.

Because the three offices are quite different in function, the observation and interview results are described below for each facility.

2.2.1 Headquarters

Most of the activities at the headquarters office revolve around general administration. Thus, the environmental aspects identified were the result of energy use for powering office equipment, materials use like paper and supplies, solid waste generation from everyday activities, and fuel use from transporting personnel and materials. Headquarters staff were well aware of the environmental policy but there was not a copy of the policy in any offices observed. The staff were willing to participate in the EMS development and implementation since meeting the Executive Order 13148 relates to their personal job functions. Identification of applicable legal requirements and a formal tracking system seems to be a top priority for the Engineering Department, while updating contract specifications and green procurement requirements were a concern for the Administration Department. Some pollution prevention activities included recycling paper and toner cartridges and even refurbishing and donating used computer equipment to local schools.

Some key recommendations include:

Developing a formal compliance tracking system for applicable legal requirements, including Executive Orders;

Communicating legal requirements to all field offices;

Expanding the recycling program to include aluminum cans, plastic bottles and cardboard;

Promoting the environmental policy to all employees; and

Ensuring green procurement is integrated into all purchasing activities.

2.2.2 American Dam

There is a wide variation of processes and activities for the operation and maintenance of American Dam compared with the other facilities. Processes include

A 2-7 operation and maintenance of the dam’s infrastructure, maintenance of the international boundary, security, hydrologic sampling and monitoring, and equipment repair and maintenance. Most of the staff were aware of the environmental policy but could not relay what it said or meant for the organization.

American Dam has made some efforts in pollution prevention with their recycling efforts of waste oil and anti-freeze and some hazardous waste when the City of El Paso offers hazardous waste drop-off days. Staff could not convey what applicable legal requirements applied to their operation and thus relied heavily on headquarters for tracking that. Maintenance processes are generally reactive in nature rather than predictive and preventive. This was attributed to staffing shortages, which may result in either increased fuel consumption in equipment, increased disposal of parts, or more rigorous intervention to restore compromised areas of the river bed and flood plain.

Some key recommendations include:

Establishing a formal training program, including collection of training records;

Publicizing the EMS through the mobile promotional trailer;

Moving towards increasing predictive and preventive maintenance;

Communicating to contractors about the environmental policy and environmental considerations;

Identifying and communicating legal requirements; and

Establishing formal SOPs to address best management practices in operating and maintenance of the plant, international boundary, roads, etc.

2.2.3 Nogales International Wastewater Treatment Plant

NIWTP staff were aware of their environmental aspects which revolved around operating the wastewater treatment plant. The Environmental Policy was hanging in the break room, but most staff were not aware of it. Training of staff is recorded by the administrative assistant, however, a formal system does not exist. A challenge for NIWTP is working to meet its NPDES permit because of the high phosphate content of the influent coming from Mexico. As a means to correct this problem, NIWTP management could use existing communication channels for educating the local communities and its counterparts in Mexico of the environmental policy and general environmental awareness. The lagoons create habitat for many species of birds and is a local attraction for bird watchers. Currently, there is no formal recycling program except for waste oil and some hazardous waste when contractors pick it up. In addition, until the upgrade of the plant is complete, there is not much room for improvement in terms of energy and fuel use.

Some key recommendations include:

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005

Educating the surrounding communities of Nogales, Arizona and Nogales, Sonora in Mexico about the environmental policy and general awareness for wastewater best practices (i.e. what citizens can and cannot put down their drains);

Offering more support and expertise through education to Mexico for coping with the influent and minimizing combined sewer overflows;

Implementing a recycling program for paper, aluminum cans, plastic bottles, and cardboard;

Ensuring that the design specifications for the plant upgrade include environmental considerations, including an analysis of the energy source for the new generator; and

Establishing formal SOPs to address best management practices in operating and maintenance of the plant, international boundary, roads, etc.

A 3-1

Section 3 Initial Environmental Assessment Results

3.1 Environmental Management Review Response

One objective of the IEA was to confirm the USIBWC’s current position wth regard to the EMS and the “Areas for Improvement” listed in the USEPA’s Environmental Management Review (EMR). In July 2005, the USIBWC requested USEPA Regions 6 and 9 to conduct the EMR in order to evaluate its existing management system for the environmental program. The USEPA conducted on-site interviews and tours at the headquarters office, American Dam field office and the NIWTP field office for one week and submitted a report presenting an overview of observations and improvements for conforming to the ISO 14001:2004 standard.

The key observations and recommendations for improvement in the EMR were evaluated prior to beginning the on-site activities for the IEA. From the document reviews, observations and interviews, an appropriate response to the EMR’s eight steps for implementing a comprehensive EMS at the USIBWC was determined. Table 3-1 presents CDM’s observations and initial response to those major steps outlined in the EMR.

Steps for Implementation Observations and Response

Disseminate the environmental policy to all headquarters and field elements and make the policy available to the public.

The USIBWC has taken steps to communicate the environmental policy to its staff. The policy has been added to the USIBWC website (http://www.ibwc.state.gov/EnvPolicy.pdf) and emails to the staff announcing the policy have been distributed when the policy was signed. Framed copies of the Environmental Policy should be made available in all facilities.

Establish an EMS committee that includes representatives from headquarters and the field offices and ensure that committee members receive EMS training.

The EMS Coordinator position has been established and that person has taken initiative in educating management and staff about the EMS development. The EMS Coordinator recently attended 40 hour ISO 14001 Lead Auditor Training and is in the progress of forming a Core EMS Team and an oversight Steering Committee. The EMS Coordinator has taken steps to identify personnel into joining the Core EMS Team, but has only notified some personnel and

Table 3-1

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005

Steps for Implementation Observations and Response needs to solidify the rest of the members.

Some team members were present during the IEA and participated in the training workshops. On November 2, the EMS Coordinator will further educate management and personnel about the EMS development at the annual meeting. By this time, the EMS Coordinator should have the Core EMS Team fully established and he may engage top management into oversight of the EMS.

Identify and verify compliance with applicable environmental regulations and requirements for all USIBWC operations.

The EMS Coordinator has determined as a need that identification and tracking of legal requirements were high priorities and thus is working on a system to verify compliance.

CDM presented the EMS Coordinator with an initial list of applicable local, state, federal and international regulations which can be used as a starting point for formalizing a compliance program.

Identify the environmental aspects and the associated significant environmental impacts of USIBWC operations over which it has control.

As part of this project, the environmental aspects and impacts of the USIBWC processes and activities were identified. A procedure for identifying aspects and impacts and determining significant environmental aspects was also developed.

A description of the aspects and impacts is found below and the SOP and list of significant environmental aspects are attached as Appendices B and C, respectively.

Establish measurable environmental objectives and targets based on the significant environmental impacts.

A procedure for setting objectives and targets was also developed and the USIBWC worked to establish them for the significant environmental aspects. The objectives and targets are currently in draft form and will be finalized by the USIBWC. A description of the objectives and targets is found below and the SOP and list of preliminary objectives and targets are attached as

A 3-3

Steps for Implementation Observations and Response

Appendices D and E, respectively.

Formalize the environmental management program to define roles, responsibilities and training needs and to collect and monitor environmental data.

CDM developed a template for formalizing environmental management programs to meet the objectives and targets set for the USIBWC. CDM will develop environmental management programs for up to five objectives and targets. The suggested list of objectives and targets to develop action plans are described below. The template form for use in developing environmental management programs is attached as part of Appendix A.

Formalize environmental checking and corrective action.

From the observations and interviews, it was evident that the USIBWC has an internal audit program, but does not have a formal program for monitoring and measuring nor corrective actions. The USIBWC will need to focus efforts on developing this element to conform to the ISO 14001:2004 standard.

CDM will outline steps for developing this EMS element in the final EMS Implementation Report.

Establish a management review cycle to periodically evaluate progress towards meeting EMS goals and implementation schedules.

There is a system in place for internal and external reporting on activities for American Dam and NIWTP, but it is not clear to what extent top management is involved. NIWTP must report to its counterparts in Mexico and to headquarters weekly. American Dam must report to its counterparts in Mexico as well. Major incidents are also reported to headquarters, but again it is not evident if top management reviews this information.

CDM will include steps for developing a management review cycle program in the final EMS Implementation Report.

CDM, with the help of the EMS Coordinator, filled out the EMR Response Matrix to help the USIBWC respond to USEPA’s observations and areas for improvement. The

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005 completed EMR Response Matrix will be included as an attachment to the final EMS Implementation Report.

3.2 Environmental Aspects and Impacts

CDM developed a procedure for identification of environmental aspects and to prioritize significant environmental aspects (SEAs). SEAs are those that have or potentially could have a significant impact on the environment and which the USIBWC could control.

During the kick-off meetings, the USIBWC area managers and supervisors and operational staff worked to list the business processes and applicable legal requirements for the operations for the three facilities. Relevant activities for those processes and their associated environmental aspects were then identified using process diagrams. A business process form is attached in Appendix A, and a process diagram form is attached in Appendix B for use in future EMS activities.

From the process diagrams, a final table of all processes, activities and associated environmental aspects were compiled and presented to USIBWC for determination of significant environmental aspects. A list of environmental impacts, positive and negative, associated with these aspects was identified. The positive and negative environmental impacts that were used in determining significant environmental aspects are presented below:

Air quality degradation;

Water quality degradation or improvement;

Water consumption or conservation;

Soil and water contamination;

Natural resource depletion/damage;

Cultural, historical or archaeological items or sites damage;

Nuisance to public;

Energy consumption or conservation;

Contribution to global warming;

Materials consumption or conservation;

Solid waste disposal or recycling;

Hazardous waste disposal or recycling; and

A 3-5

Natural resource enhancement.

3.2.1 Significant Environmental Aspects

The first workshop included presenting the complete list of processes, activities and environmental aspects and then determining SEAs. The current Core EMS Team reviewed the proposed process for rating environmental aspects and agreed on the following criteria for determining significance for each aspect:

Frequency;

Severity;

Regulatory Requirement;

Environmental Risk; and

Human Health and Safety Risk.

For each aspect and impact, the Core EMS Team rated each criterion as either: High, Medium-High, Medium, Medium-Low, or Low. The ratings were evaluated in aggregate and a list of significant environmental aspects was produced.

This rationalization was documented on the aspects rationale ID form, which can be found attached as part of Appendix A. Table 3-2 lists the SEAs according to the facility they apply. In most instances, the SEA applies to all three facilities. The complete list of SEAs with their ratings is attached in Appendix C.

Facility Significant Environmental Aspects

Headquarters, American Dam, NIWTP Hazardous Waste Generation

Headquarters, American Dam, NIWTP Solid Waste Generation

Headquarters, American Dam, NIWTP Contract Specifications addressing Environmental Management

American Dam, NIWTP Damage to Natural Resources

American Dam, NIWTP Disposal of Sediments

NIWTP Air Emissions

American Dam, NIWTP Chemical Handling/Storage

NIWTP Combined Sewer Overflows Release

Table 3-2

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005

Facility Significant Environmental Aspects

NIWTP Effluent

Headquarters, American Dam, NIWTP Fuel Use

Headquarters, American Dam, NIWTP Materials Use

NIWTP Odors

NIWTP Obsolete Equipment

NIWTP Storage and Dispensing of Chlorine Tablets

NIWTP Vectors

3.3 Objectives and Targets

In another training workshop, the final list of SEAs was reviewed and draft objectives and targets (O&Ts) were determined. Draft O&Ts and performance indicators for each SEA and additional O&Ts that addressed other elements of the EMS were discussed. The participants then formalized a preliminary list of O&Ts and performance indicators, which is attached in Appendix D.

The draft list of O&Ts at NIWTP have not yet been discussed. This list and the other preliminary O&Ts will be reviewed by the USIBWC and a final list of O&Ts will be included in the final EMS Implementation Report.

3.4 Environmental Management Programs

Once the O&Ts are finalized, CDM will develop environmental management programs (EMPs) for up to five O&Ts as identified by the EMS Coordinator and Core EMS Team. EMPs are environmental improvement action plans for meeting the set O&Ts. An EMP will define the means for meeting the objectives, resources required, schedule, including key milestones, as well as critical success factors. The template for the development of EMPs is attached in Appendix A.

From the preliminary list of objectives, CDM recommends the following five and will seek approval from the EMS Coordinator and Core EMS Team to begin development of EMPs:

Develop EMS Awareness Training Program for all the USIBWC staff and general public;

A 3-7

Document and review existing emergency preparedness and response practices and communicate those to employees and contractors;

Establish a training program and tracking system to include environmental knowledge and responsibilities for both existing employees and new hires;

Formalize procedures to identify and comply with regulatory requirements and other programs or standards; and

Optimize existing recycling program in headquarters and field offices.

A 4-1

Section 4 Next Steps

4.1 Completion of Planning Phase

CDM will continue to work the USIBWC in completing the planning element of Clause 4.3 under ISO 14001:2004. The next steps include the following:

Formalizing the Core EMS Team and Steering Committee;

Finalizing objectives and targets;

Agreeing on five objectives and targets for development of environmental management programs; and

Implementing those five environmental management programs.

The last deliverable will be a final EMS Implementation Report which the USIBWC will use to undertake in continuing to develop and sustain its EMS.

4.2 Next Steps

It is expected that the USIBWC will implement the five EMPs prepared under this project and continue with the development and implementation of the EMS elements (Clause 4.4 Implementation, Clause 4.5 Checking and Clause 4.6 Management Review). These elements include the following components:

Training;

Document control;

Communication;

Control of records;

Checking; and

Management Review.

CDM will draft a final EMS implementation report which will serve as a roadmap for defining the activities that the USIBWC should take in continuing to develop and sustain the EMS. The report will also recommend resource allocation and schedule for implementation. The IEA Report and the EMS Implementation Report will feed into the development of an EMS manual which will be instrumental in guiding the USIBWC in completing and sustaining its EMS.

By the end of December 2005, the USIBWC should have the Clause 4.3 components completed and a draft EMS manual developed. Overall the USIBWC is in good

Section 4 Next Steps

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USIBWC – EMS – Initial Environmental Assessment – October 24, 2005 status to continue development of its EMS and meet the requirements of Executive Order 13148 and conform to the ISO 14001:2004 standard. This pilot EMS at Headquarters, American Dam and NIWTP will serve as a demonstration to roll out to other facilities.

A

Appendix A Forms for Use

Prepared By: Core EMS Team Prepared Date: 10/11/05

Approved By:

INTERNATIONAL BOUNDARY AND WATER COMMISSION

UNITED STATES SECTION

Environmental Management System (EMS) Approved Date:

Business Processes Applicable Legal Requirements

Date Prepared: 10/13/05

Date Approved:

Frequency: The probability that an impact might occur, or how often it actually occurs will affect the significance of the impact.

Severity: When evaluating severity of an impact, it may be helpful to consider: proximity of impact to people or environmentally sensitive areas; toxicity of substances involved; quantities of substances involved; effects from startup and shutdown conditions; duration of exposure or effects; size of the area affected; potential for migration of the hazard.

Regulatory Requirement: Impacts subject to local, state, federal regulations are automatically significant. Situations involving a high risk of noncompliance demand increased priority.

Environmental Risk: When evaluating environmental risk, it may be helpful to consider: proximity of impact to environmentally sensitive areas; toxicity of substances involved; quantities of substances involved; effects from startup and shutdown conditions; duration of exposure or effects; size of the area affected; potential for migration of the hazard.

Human Health Risk: When evaluating human health risk, it may be helpful to consider: proximity of impact to people; toxicity of substances involved; quantities of substances involved; effects from startup and shutdown conditions; duration of exposure or effects; size of the area affected; potential for migration of the hazard.

ENVIRONMENTAL ASPECTS ID RATIONALE

PURPOSE To establish rationale behind ratings for each environmental aspect. The following ratings will be used: High (H), Medium-High (M-H), Medium (M), Medium-Low (M-L), Low (L).

CORRESPONDING ASPECT:

Date Prepared: 10/19/05

Objective: Target:

Background/Purpose: Scope:

Tasks/Activities (3-5 per project):

Timeline/Milestones: Deliverables (e.g. report, training plan, new equipment):

Responsible Parties and Roles: Resources Needed (funding, training, days/week):

Issues:

ENVIRONMENTAL MANAGEMENT PROGRAM (EMP)

PURPOSE: To establish, implement and maintain environmental management programs for meeting objectives and targets.

EMP NAME: PROPOSED DATE: DATE COMPLETED:

Appendix B Aspects Identification SOP

Document ID: EMS-4.3.1-SEA Revision No: 001 Date Effective: 10/14/05

Revision Date: 10/14/05

Significant Environmental Aspects Identification

This SOP was prepared by

Print Name

Signature

Date

And approved for use by

Becoming effective

Previous versions of this SOP should be discarded and not used after the above effective date.

1 Purpose This procedure defines the steps to be taken to identify environmental aspects and potential impacts associated with work processes and associated activities and then assigning significance to those aspects and impacts.

The identification of significant environmental aspects provides the basis for development of objectives and targets [SOP EMS-4.3.3-OT] and then the establishment of environmental management programs (EMPs).

2 Scope This procedure applies to the determination of IBWC activities at the Headquarters in El Paso, Texas, the American Dam field office in El Paso, Texas and the Nogales International Wastewater Treatment Plant (NIWTP) field office in Nogales, Arizona.

3 Definitions

3.1 Activity

A work action that occurs within the IBWC operations or processes within the scope of facilities defined in Section 2. Identified activities should be discrete and focused enough to be managed but sufficiently broad to encompass one or more environmental aspect.

3.2 Environmental Aspect

A component of IBWC activities, products or services which can interact with the environment and which IBWC can directly control. An aspect represents a real or potential cause.

3.3 Environmental Impact

Any change to the environment, whether adverse or beneficial, wholly or partially resulting from IBWC activities, products or services. An impact represents a real or potential effect.

3.4 Process

A series of activities taken together to achieve a business objective.

3.5 Process Diagram

A pictorial representation.

3.6 Significant Environmental Aspect

An environmental aspect that has or could have a significant environmental impact.

Significance of impact and thus the aspect is determined through a structured approach (contained herein).

4 Procedure

4.1 Identify processes, activities, products and services

For each functional area within each facility, the area manager or operational supervisor will create a list of the operations, products or services performed. For each operation, product or service, identify the processes involved.

Complete a process diagram (Figure 1) for each process, identifying inputs (materials, information, tools), activities, and outputs (products, by-products, waste). The manager or supervisor may rely on operational staff to complete the process diagrams. The diagrams should quantify to the extent possibly inputs and outputs, for example an input at the headworks of the NIWTP would be raw wastewater (12 MGD).

The list of processes and the process diagrams will be delivered to the EMS Coordinator.

4.2 Identify aspects

The EMS Coordinator will use the completed process diagrams to list all aspects associated with the organization’s operations. Aspects may arise from purchasing or managing inputs (materials), conduct of activities, or managing or delivery of outputs (products, by-products and waste). Aspects may also include resources consumed (electricity or fuel) and may include energy emitted (heat, light, radiation). Aspects may result from activities of people as part of organizational operations (for example: travel to work sites, lunch breaks).

An activity may result in more than one aspect.

Only those aspects which can be controlled by IBWC will be listed.

The list will include denotation of control mechanisms or processes currently in place for respective aspects.

Define aspects narrowly enough so that they could be reasonably controlled, but generally enough that control would have a measurable result.

4.3 List Impacts

The EMS Coordinator will identify potential impacts for each aspect identified. The EMS rep may discuss activities with operational staff to identify potential impacts.

Impacts of IBWC aspects generally fall into one of the following categories:

• Emissions to air

• Releases to water

• Releases to the ground

• Damage or depletion of natural resources (for example: erosion, loss of vegetation)

• Damage to cultural, historical, or archaeological items or sites

• Nuisance to the public

• Energy consumption or conservation

• Energy emission (heat, light, radiation)

• Consumption of natural resources or reuse

• Solid waste disposal or recycling

• Hazardous waste disposal

The list of impacts will include both positive and negative aspects; positive aspects would include recycling or reuse of materials.

4.4 Determine Significance

The Core EMS Team will develop a list of criteria against which to determine significance. In determining significance of aspects and potential impacts, some criteria to consider include:

• Impact to local environment

• Impact on global environment

• Severity of Impact

• Frequency of Occurrence

• Probability of Occurrence

• Duration of impact

• Regulatory and/or legal exposure

• Impact on human health and safety

• Effect on public relations

• Cost of control

• Difficulty of control

The number of criteria chosen should be sufficient to characterize the aspects and impacts but small enough to be manageable. Four or five is a sufficient number. Some evaluation criteria may be combined to form a single criterion; for example local and global environmental impacts may be combined to a single rating for environmental impacts.

The implementation team will rate each aspect and impact for the criteria chosen. The rating scale will be based on:

• Low

• Medium-Low

• Medium

• Medium-High

• High

Ratings for criteria which represent challenges such as cost or difficulty of control will be reversed such that a high rating indicates cost of control is economical or a high rating for difficulty of control indicates a relatively simple solution.

The EMS Coordinator will tally the ratings for each aspect by summing the number of high ratings for each, where two medium high ratings equal one high and two medium ratings equal one medium-high and so forth.

The overall ranking of significance will depend on the number of ranking criteria used – for example, using four criteria, significance may be indicated by those aspects with two or more high rankings including combinations as described above.

The significant environmental aspects are then taken from the rated and ranked aspects and submitted to the Core EMS Team for review and acceptance.

5 Responsibilities Area managers and operational supervisors are responsible for ensuring that the processes and activities listed and defined through the process diagrams are an accurate reflection of current operations.

Area managers and operational supervisors are responsible for ensuring that the processes and activities listed and defined through the process diagrams are updated for any change in operations or for any addition or deletion of an activity. They will ensure that these changes are reported to the EMS Coordinator within 30 days of the change.

The EMS Coordinator is responsible for conducting the rating of significance for aspects through the Core EMS Team and reporting these results to the core team for review and approval.

The EMS Coordinator will initiate a review and updating of the list of activities and rating of significance at least annually. The annual review must include review by the Core EMS Team of the criteria used to rate significance of aspects and potential impacts.

6 Records The following records must be maintained as part of the environmental management system, and in accordance with the procedure for control of records.

6.1 The initial list of operational processes, products and

services.

6.2 Copies of process diagrams including designation of inputs, activities, products and by-products.

6.3 The list of activities and environmental aspects.

6.4 The list of aspects rated for significance with the aspects designated as significant identified.

6.5 Updates and revisions to records specified in 6.1 – 6.4.

Figure 1. Process Diagram Complete a diagram for each process. If the output of one process proceeds to another place the name of that process under Output and provide a diagram for that process.

When listing activities, break down to manageable units but only small enough to identify potential environmental aspects (actions, materials used, products, by-products)

Activities

Inputs Outputs

Process: _____________________

To be completed by EMS Coordinator Aspects:

Signed _________________________ Date _________________

Operational approval ____________________ Date_____

By-products

Significant Environmental Aspect Identification

S te er in g C om m itt ee

E M

C oo rd in at or

C or e Te am A re a

M an ag er s, up er vi so rs

S ta ff

Deliver List of Processes and Activities and

Associated Process Diagrams to EMS

Coordinator

Create List of Operational Processes, Products, or Services

Lisit activities associated with the processes

Complete Process Diagram for each;

identifying inputs, activities and outputs

New or Changed Process Initiated

(30 day communication requirement)

Identify Environmental

Aspects of Activities

Identify Environmental Impacts (real or potential)

Rate each Aspect and Impact to Determine which are

Significant based on Defined Criteria and

Rating Scale (H, M-H, M, M-L, L)

Define Criteria to Prioritize Aspects and Determine Significant

Environmental Aspects (SEAs)

Tally Ratings and Determine Overall Score (Sums High

Ratings) on Aspects ID Spreadsheet

Rank SEAs and Submits Ranking for

Review and Acceptance

Team Reviews and Approves SEAs and

Notifies EMS Coordinator of any

Changes

Maintain Documents and

Records Aspects ID

Process Completed

Annually Initiates Review and Update of Activities List, SEAs and Rating Criteria with Core EMS Team

Document List of Processes and Process

Diagrams Document Aspects ID

Document Ranking of EAs and List of Final

SEAs

Appendix C List of Significant Environmental Aspects

SIGNIFICANT ENVIRONMENTAL ASPECTS

PURPOSE To determine which environmental aspects are significant consistent with the SOP # and based on the following criteria: frequency, severity, regulatory requirement, environmental risk and human health risk.

SYMBOL H M-H M M-L L

RATING High Medium-High Medium Medium-Low Low

Aspect Frequency Severity Regulatory Requirement

Environmental Risk

Human Health Risk

Score (Sum of Hs)

Significant 2 or more Hs =

Hazardous Waste Generation H H H H H 5

Air Emissions H M H H H 4 Chemical

Handling/Storage M H H H H 4

Combined Sewer Overflows Release M-H M-H H M-H M-H 3

Storage and Dispensing of Chlorine Tablets H M-L H M-H M-H 3

Solid Waste Generation H M H M M-L 2 Contract Specifications M M H M M 2

Damage to Natural Resources H M-L H M-L L 2

Disposal of Sediments M-H M-L H M-H L 2 Effluent H L H M-L L 2 Fuel Use H M H M-L M-L 2

Materials Use H L H L L 2 Odors H L H L L 2

Obsolete Equipment H M H M L 2 Vectors H M H L M 2

Appendix D Objectives and Targets SOP

Document ID: EMS-4.3.3-OT

Objectives and Targets Development

This SOP was prepared by

And approved for use by

Becoming effective

Previous versions of this SOP should be discarded and not used after the above effective date.

1 Purpose This procedure defines the steps to be taken to develop objectives and targets for environmental performance.

The driving force behind the development of environmental objectives and targets is contained in the phrase “What gets measured gets managed”. The development of objectives and targets for environmental performance is informed by the determination of significant environmental aspects and impacts (refer to SOP EMS-4.3.1-SEA) and should be consistent with the environmental policy including a commitment to pollution prevention and regulatory compliance.

Objectives and targets should be specific and measurable, where possible, and cover both long-term and short-term issues.

The objectives and targets developed then give rise to the establishment of environmental management programs (EMP).

2 Scope This procedure applies to the development of environmental objectives and targets at USIBWC Headquarters in El Paso Texas, at the American Dam facility and at the Nogales International WWTP (Nogales, AZ)

3 Definitions

3.1 Environmental Management Programs (EMP)

A structured approach to control activities that may impact the environment in a beneficial or detrimental way.

3.2 Objective

An environmental goal set by the IBWC, at a specified functional and organizational level, to achieve a desired environmental result. Objectives arise from the environmental policy, significant environmental aspects, regulatory requirements, and those voluntary programs in which the organization participates.

3.3 Measure

A means of determining change in an environmental condition, measures are used to monitor progress in achieving targets.

3.4 Target

A detailed performance requirement that is specific and measurable, arising out of the established objectives. Targets are tied to a specific time frame.

4 Procedure

4.1 Compile list of significant environmental aspects (SEA)

A list of SEA must be developed consistent with SOP EMS-4.3.1-SEA and be approved by the EMS steering committee for development of objectives and targets.

4.2 List existing environmental programs

The EMS Coordinator should compile a list of existing environmental programs and existing objectives and targets. At the outset of EMS implementation, existing programs, objectives or targets may not be specifically defined as such; however, existing approaches to address environmental issues should be listed. Revision of existing programs to accomplish objectives and targets is the preferred approach.

4.3 Establish objectives

The EMS Coordinator working with the Core Team will develop a list of objectives addressing the compiled list of significant environmental aspects (SEA) as well as environmental goals established by the policy statement, regulations or other requirements to which USIBWC may subscribe. There may not be a one-to-one relationship between SEA and objectives. One objective may address more than one SEA. A single SEA may require more than one objective to be properly addressed.

Objectives should be stated in general terms, such as “increase the amount of recyclables” or “reduce the amount of hazardous waste generated”.

The Core Team should also review the environmental policy and identify any additional objectives that may be needed to keep the overall system aligned with the environmental policy, even if a specific SEA is not defined in that regard.

4.3.1 Select a manageable number of objectives

The specific number of…