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NASA Procedures and Guidelines |
This Document is Obsolete and Is No Longer Used.
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Cover
Preface
Chapter 1. Introduction, Roles, and Responsibilities and EMS Definitions
Chapter 2: Evironmental Policy
Chapter 3: Planning
Chapter 4: Implementation and Operation
Chapter 5: Checking and Corrective Action
Chapter 6: Management Review
Chapter 7: Management Review
Appendix A:áá Sample Risk Matrix
P.1 PURPOSE
This NPR describes NASA's Environmental Management System (EMS). An EMS is a system that (1) incorporates people, procedures, and work practices in a formal structure to ensure that the important environmental impacts of the organization are identified and addressed, (2) promotes continual improvement by periodically evaluating environmental performance, (3) involves all members of the organization as appropriate, and (4) actively involves Senior Management in support of the environmental management program. The purpose of the Agency EMS is to have a single overall Agency approach to managing environmental activities that allows for efficient, prioritized program execution.
This NPR provides overall direction for both NASA-wide EMS documentation and Center-level documentation. NASA-wide documentation, NASA Policy Directive (NPD) and NASA Procedures and Guidelines (NPR), are the minimum EMS performance criteria. Center EMS implementation planning activities will add content to reflect Center-specific needs. This NPR supports the NASA Safety and Health Program, including risk management and loss-prevention priorities.
P.2 APPLICABILITY
The EMS scope includes the following NASA Centers and Component Facilities:
a. Ames Research Center.
b. Dryden Flight Research Center.
c. Glenn Research Center at Lewis Field.
d. Glenn Research Center, Plum Brook Station.
e. Goddard Space Flight Center.
f. Goddard Space Flight Center, Wallops Flight Facility.
g. Headquarters.
h. Johnson Space Center.
i. Johnson Space Center, White Sands Test Facility.
j. Kennedy Space Center.
k. Langley Research Center.
l. Marshall Space Flight Center.
m. Stennis Space Center.
P.1á á á á áPurpose
P.2á á á á áApplicability
P.3á á á á áAuthority
P.4á á á á áReferences
P.5á á á á áCancellation
1.1á á á á áIntroduction
1.2á á á á áRoles and Responsibilities
1.3á á á á áEMS Definitions
3.1á á á á á Environmental Aspects and Impacts
3.2á á á á á Legal and Other Requirements
3.3á á á á á Objectives and Targets
3.4á á á á á Environmental Management Program(s)
4.1á á á á á Structure and Responsibility
4.2á á á á á Environmental Training, Awareness, and Competence
4.3á á á á á Communication
4.4á á á á á EMS Documentation and Document Control
4.5á á á á á Operational Control
4.6á á á á á Emergency Preparedness and Response
5.1á á á á á Monitoring and Measurement
5.2á á á á á Nonconformance, Corrective, and Preventive Action
5.3á á á á á Records
5.4á á á á á EMS Audit
6.1á á á á á Purpose
6.2á á á á á Roles and Responsibilities
6.3á á á á á Requirements
7.1á á á á á Purpose
7.2á á á á á Roles and Responsibilities
7.3á á á á á Requirements
Appendix B:áá Summary of Roles and Responsibilities Matrix
Appendix C:áá Documents, Procedures, and Records
Appendix D:áá Table of Acronyms and Abbreviations
Preface
Component Facility Management shall be responsible for implementation of an EMS commensurate with the environmental responsibilities delegated by the Center Director. The Component Facility EMS may be separate from the Center EMS.
- Ames Research Center
- Dryden Flight Research Center
- Johnson Space Center
- Stennis Space Center
- Marshall Space Flight Research Center
- Glenn Research Center at Lewis Field/Glenn Research Center, Plum Brook Station
- Kennedy Space Center
- Langley Research Center
- Goddard Space Flight Research Center
- Johnson Space Center, White Sands Test Facility
- Goddard Space Flight Research Center, Wallops Flight Facility
- Headquarters
Management at each Center is responsible for determining the applicability of this EMS to its contractors. When a determination is made that the EMS is applicable, the Center management must assure that a requirement for implementing this EMS be incorporated into all such contracts no later than the time of recompetition of the contracts.
In the case of a NASA-owned, contractor-operated facility, NASA officials responsible for the contract shall incorporate a requirement for implementing an EMS, if determined appropriate, into the contract for operating the NASA-owned, contractor-operated facility no later than the time of recompetition of the contract. The requirement need not be for this EMS but shall require an EMS that satisfies the EMS-related requirements of Executive Order 13148 (and applicable Federal Acquisitions Regulations). If the contractor does not satisfy this requirement, then the NASA official has discretion whether to specify the conditions pursuant to which the contractor must choose and administer an EMS. Such conditions may include restrictions as to the type of EMS and provisions for Government control or supervision of the EMS desired by the Center management. The Office of Space Science at Headquarters shall make this determination with regard to the Jet Propulsion Laboratory.
P.3 AUTHORITY
a. NPD 8500.1, NASA Environmental Management.
b. Executive Order 13148, April 21, 2000, Greening the Government Through Leadership in Environmental Management, 3 CFR (2000 Compilation)
P.4 REFERENCES
a. 48 CFR Subpart 23.10, Federal Acquisition Regulation (FAR) Federal Compliance with Right-To-Know Laws and Pollution Prevention Requirements.
b. NPD 1440.6, NASA Records Management.
c. NPD 2800.1, Managing Information Technology.
d. NPR 1400.1C, NASA Directives System Procedures and Guidelines
e. NPR 1441.1C, Records Retention Schedules.
f. NPR 7120.5A, Program and Project Management Processes and Requirements.
g. NPR 8580.1, Implementing The National Environmental Policy Act and Executive Order 12114.
h. NPR 8621.1, NASA Procedures and Guidelines for Mishap Reporting, Investigating, and Recordkeeping.
i. NPR 8715.2, NASA Emergency Preparedness Plan Procedures and Guidelines.
j. NPR 8715.3, NASA Safety Manual.
k. NPR 8820.3, Pollution Prevention.
l. Code of Environmental Management Principles (CEMP): Environmental Protection Agency, October 16, 1996.
m. ISO 14001: International Organization for Standardization (ISO) for Environmental Management Systems, 1996.
P.5 CANCELLATION
None.
/s/ Jeffrey E. Sutton
Assistant Administrator for
Institutional and Corporate Management
NPD 8500.1, NASA Environmental Management, applies to all Centers, employees, and activities performed on site. Environmental Excellence for the Twenty-First Century articulates the vision/strategy associated with the policy and includes four primary focus areas: prevention, compliance, restoration, and conservation. These four primary focus areas in turn lead to NASA-wide environmental goals and metrics.
1.2 Roles and Responsibilities
The role of the NASA Headquarters Environmental Management Division (HQ EMD) is to lead Agencywide issues and initiatives.
NASA HQ EMD is responsible for--
a. Establishing and maintaining NASA Environmental Policy and Guidelines.
b. Defining and maintaining NPR 8553, NASA Environmental Management System.
Each Center is responsible for--
a. Implementing NASA Environmental Policy and Guidelines.
b. Reporting to NASA HQ EMD on meeting EMS progress and metrics as requested.
c. Identifying planned contractor operations affected by this EMS and assuring specifications, statements of work, surveillance plans, deliverable data requirements, and other procurement terms and conditions are properly developed during acquisition planning.
1.3 EMS Definitions
1.3.1 The Code of Environmental Management Principles (CEMP) - an Environmental Protection Agency (EPA) document comprised of five principles:
a. Management commitment.
b. Compliance assurance and pollution prevention.
c. Enabling systems.
d. Performance and accountability.
e. Measurement and improvement.
1.3.2 Competence - a demonstrated ability to apply knowledge and skills (training, education, and experience) defined by the organization as appropriate for all personnel whose work may create a priority environmental impact.
1.3.3 Consequence - the resulting potential (adverse or beneficial) effect associated with an environmental impact on, or resulting change to--
a. A natural or cultural resource,
b. A cost to NASA,
c. The NASA mission,
d. Reputation or stakeholder relationship,
e. Safety and health, or
f. An environmental legal/regulatory implication.
Consequences may occur as a component of normal operations where they are expected as a result of regularly planned operations. An abnormal consequence is associated with an unplanned or unexpected effect or change. An emergency consequence is associated with an emergency as defined by a Center in accordance with NPR 8715.2.
1.3.4 Continual Improvement - the process of enhancing the environmental management system to achieve improvements in overall environmental performance in line with NASA's environmental policy and mission.
1.3.5 Controlled EMS Documents - EMS documents specified in this manual (Appendix C).
1.3.6 Document - a written procedure or guideline that requires regular review or maintenance.
1.3.7 Environmental Management System (EMS) - a system that incorporates people, procedures, resources, responsibilities, and work practices in a formal structure to address the development, implementation, achievement, and review of the environmental policy.
1.3.8 EMS Audit - a systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether an organization is conforming to its environmental management system and for communicating the results of this process to management.
1.3.9 EMS Representative - the NASA individual who manages the EMS and is responsible for reporting to Senior Management and NASA HQ EMD on the following:
a. EMS Performance.
b. Results of functional assessments, audits, and management reviews.
1.3.10 Environmental Aspects - elements of NASA's activities, products, or services that can interact with the environment. NASA has determined that these elements fall into four major focus areas: Prevention, Compliance, Restoration, and Conservation.
1.3.11 Environmental Impact - any change to the environment, whether adverse or beneficial, wholly or partially resulting from NASA's activities, products, or services. Impacts can be prioritized as follows:
a. Priority Environmental Impact - a NASA environmental impact that shall be managed to avoid or prevent a serious adverse environmental effect or create a substantial beneficial effect. 1
b. High priority environmental impact - an environmental impact that shall be managed with an environmental management system objective and target, based on the most severe action priority level being high for all of its environmental consequence categories as determined by the Risk Ranking Matrix.
c. Medium priority environmental impact - an environmental impact that shall be managed to avoid becoming a high priority impact, based on the most severe action priority level being medium for all of its environmental consequence categories as determined by the Risk Ranking Matrix.
d. Low priority environmental impact - an environmental impact that shall be managed as appropriate, based on the most severe action priority level being no greater than low for all of its environmental consequence categories as determined by the Risk Ranking Matrix.
e. Very low priority environmental impact - an environmental impact that shall be managed as appropriate, based on the priority level being very low for all of its environmental consequence categories as determined by the Risk Ranking Matrix.
1.3.12 Environmental Objective - an overall environmental goal, arising from the environmental policy, that NASA sets for itself to achieve and which is quantified where practicable.
1Within Federal Government agencies such as NASA, compliance with the National Environmental Policy Act (NEPA) requires that if "major actions" might impose "significant environmental impacts," then measures for mitigating these adverse impacts shall be identified and evaluated. To avoid confusion, the NASA EMS will use the term "priority" instead of "significant" when describing environmental impacts.
1.3.13 Environmental Target - a detailed performance requirement, quantified where practicable, applicable to NASA, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.
1.3.14 Functional Assessment - a comprehensive, systematic, and documented verification, led by a Headquarters team, of a functional area whereby evidence is obtained and evaluated to determine whether specific environmental activities, events, conditions, management systems, or information about these matters conforms with criteria.
1.3.15 ISO 9000 - a series of international standards developed by quality experts from around the world for use by organizations that either want to implement their own in-house quality systems or to ensure that suppliers have appropriate quality systems in place. The standards were developed under the auspices of the International Organization for Standardization (ISO).
1.3.16 ISO 14000 - a series of environmental management standards developed by the ISO, one of the world's principal voluntary standards development bodies. The ISO 14000 standards are designed to provide an internationally recognized framework for environmental management, measurement, evaluation, and auditing. The standards are designed to be flexible enough to be used by any organization of any size and in any field. They address the following subjects:
a. Environmental management systems,
b. Environmental auditing,
c. Environmental labels and declarations,
d. Environmental performance evaluation, and
e. Life-cycle assessment.
1.3.17 ISO 14001 Environmental Management Systems - Specification with Guidance for Use - outlines the requirements for an EMS as developed by and agreed to the ISO.
1.3.18 Legal and Other Requirements - those requirements that the organization is regulated to or has committed to meeting. These include Federal, State and local laws, regulations or policies; Office of Management and Budget (OMB) circulars; Executive orders; and international obligations (legal). They also include internal standards, Agency agreements, Presidential initiatives, industry codes or practice, contractual obligations, and nonregulatory guidelines (other)
1.3.19 NASA Online Directives Information System (NODIS) - an Internet application used for creating NASA directives and for automating the coordination/clearance process. Approved NASA directives will be maintained in the NODIS, enabling users to retrieve, view, and print NASA directives electronically.
1.3.20 Noncompliance - a failure to meet legal or other requirements.
1.3.21 Nonconformance - a failure to meet an EMS-specified requirement.
1.3.22 Operational Controls - documented procedures that limit adverse impacts to the environment and are needed in order to manage NASA's environmental policy and compliance activities.
1.3.23 Record - a written or printed object that cannot be revised and provides evidence of what was done or has occurred.
1.3.24 EMS Record - a record that has been identified as pertaining to the EMS.
NASA Policy Directive (NPD) 8500.1, NASA Environmental Management, is NASA's environmental policy. This policy is available to both the public and the NASA community through NASA's Web pages and NODIS at http://nodis3.gsfc.nasa.gov/library/main_lib.html.
NPD 8500.1 includes a commitment to continual improvement and prevention of pollution. NPD 8500.1 also includes a commitment to comply with relevant environmental legislation and regulations and with other requirements to which NASA subscribes. In addition, NPD 8500.1 establishes responsibilities of each NASA employee, each NASA organizational element, and appropriate Headquarters and Center organizations and managers.
3.1 Environmental Aspects and Impacts
3.1.1 Purpose
To identify environmental aspects and priority environmental impacts essential to developing NASA's EMS.
3.1.2 Roles and Responsibilities
NASA HQ EMD is responsible for--
a. Establishing the Agency list of environmental aspects.
b. Establishing NASA EMS priority impact risk criteria.
NASA Centers are responsible for--
a. Identifying and documenting Center activities (past, present, and future), products, and services (in the context of normal, abnormal, and emergency conditions).
b. Determining the environmental aspects category and associated impact(s) of the documented activity, product, or service.
c. Applying the EMS priority impact risk criteria to impacts.
d. Establishing and documenting the objectives and targets for the EMS high priority impacts.
e. Periodically reviewing and updating the results of steps a. through d. above.
3.1.3 Requirements
Centers shall follow each of the steps described below and complete the Risk Matrix Form (RMF) contained in Appendix A (or a similar form containing at a minimum the components of the RMF).
Centers shall complete every box in the RMF. Center staff is expected to apply best professional judgment when applying this process. The following flow diagram and series of steps are the recommended order.
Note:
A Center at its own discretion may choose to use the Focus Areas in step 5 and the Aspect Categories in step 4 to assist in defining the Center's Impacts, in effect conducting steps 2 through 5 in reverse. |
3.1.3.1 Step1: List all activities, products, and services
Each Center shall consider all activities, products, and services under its control, as well as those activities, products, and services over which it should be expected to have control pursuant to its mission, for example:
a. Construction and modifications of facilities.
b. Facility maintenance, operations, and repair.
c. Contract management.
d. Research and development.
e. Testing.
f. Assembly.
g. Equipment maintenance and modification.
h. Programs.
i. Mission deployment.
j. Manufacturing, training, and disposition.
Below are examples of activities, products, and services at a Center:
ACTIVITY, PRODUCT, or SERVICE |
R and D: Aircraft engine testing ![]() ![]() |
Facilities Maintenance: Landscape Maintenance ![]() ![]() |
Construction of Facilities: Building a road ![]() |
Mission Deployment:![]() |
Personal Property Disposal Operations:![]() |
Equipment Maintenance: Engine Repair ![]() |
3.1.3.2 Step 2: Identify Impact(s)
Centers shall determine the impacts associated with step 1. Environmental impacts are changes to the environment whether adverse or beneficial and wholly or partially resulting from NASA's activities, products, or services.
Below is an example of identifying impacts:
ACTIVITY, PRODUCT, or SERVICE | IMPACT |
R and D: Aircraft engine testing ![]() |
NOx and CO2 air emission |
Haz waste generation | |
Hearing degradation/wildlife disturbance | |
Hearing degradation/wildlife disturbance | |
![]() | Haz waste generation |
Spills/solvent run off | |
VOC emissions | |
Less VOC's/ Less haz waste | |
Facilities Maintenance: Landscape Maintenance ![]() | Less solid waste generation |
![]() | Haz waste disposal |
Construction of Facilities: Building a road ![]() | Loss of wetland habitat |
Mission Deployment:![]() | Less HCFC's (beneficial) |
Personal Property Disposal Operations:![]() | Less Material to landfill (beneficial) |
Equip. Maintenance: Engine Repair ![]() | Increase in haz waste generation/disposal |
3.1.3.3 Step 3: Group Impacts for Manageability
Centers may group impacts to ensure that the number of impacts carried forward for further analysis is manageable.
Grouping may be conducted using the following guidelines:
a. Similar impacts arising from several distinct activities, products, or services should be grouped into one impact. If, for example, hazardous wastes are collected and disposed of under several activities, their determined impacts may be combined into one group.
b. Ensure that as impacts are grouped, it is not done to the extent that the resulting objectives, targets, management programs, and operational controls are incapable of managing these impacts.
Chapter 3.3.3 includes a graphical representation of impact grouping options in conjunction with objectives and targets.
Below is an example of grouping impacts:
ACTIVITY, PRODUCT, or SERVICE | IMPACT | GROUP IMPACTS |
R and D: Aircraft engine testing ![]() | NOx and CO2 air emission | |
Hazardous waste generation (grouped together with engine cleaning and small parts cleaning which have similar impacts) | - |
|
Hearing Degradation/Wildlife Disturbance | - |
|
![]() | Haz Waste Generation | |
Spills/Solvent Run Off | ||
VOC Emissions Less VOC's Less Haz Waste | ||
Facilities Maintenance: Landscape Maintenance ![]() | Less Solid Waste Generation | |
![]() | Haz Waste Disposal | |
Construction of Facilities: Building a road ![]() | Loss of Wetland Habitat | |
Mission Deployment:![]() | Less HCFC's (beneficial) | |
Personal Property Disposal Operations:![]() | Less Material to landfill (beneficial) | |
Equip. Maintenance: Engine Repair ![]() | Increase in Haz Waste Generation/disposal | - |
3.1.3.4 Step 4: Categorize the impacts into appropriate aspects
Each Center shall take the output from step 3 and assign aspects as appropriate. Where multiple aspects may apply, the primary aspect(s) shall be selected based on best professional judgment. The Center is free to determine the focus area (step 5) where an individual aspect belongs but may not add or change the following list of aspects:
a. Asbestos and Lead Paint Management.
b. CERCLA Site Remediation.
c. Clean Air Management.
d. Clean Water Management.
e. Closure (Non-CERCLA, Non-RCRA, nonstorage tank activities).
f. Emergency Planning and Response.
g. Endangered Species.
h. Energy Efficiency.
i. Environmental Justice.
j. Hazardous Materials Management (including risk management).
k. Hazardous Waste Management.
l. Hazardous Waste Permitted TSD Facility.
m. Historical, Archaeological, and Cultural Resources.
n. Innovative Remediation Technologies.
o. Materials Substitution/Reduction/Elimination.
p. National Environmental Policy Act.
q. Natural Resources Management.
r. Noise and Vibration.
s. PCB Management.
t. Pesticide and Herbicide Management.
u. Pollution-Prevention Integration into NASA Systems.
v. Process Changes.
w. Radioactive Materials and Nonionizing Radiation.
x. RCRA Site Remediation.
y. Recycling.
z. Safe Drinking Water.
aa. Solid Waste Generation Management.
bb. State and Local Ordinances and Regulations.
cc. Storage Tank Management.
dd. Storage Tank Site Remediation.
ee. Sustainability
ff. Water Conservation.
gg. Wetlands and Floodplains.
Below is an example of identifying aspects:
ACTIVITY, PRODUCT, or SERVICE | IMPACT | GROUP IMPACTS | ASPECT |
R and D: Aircraft engine testing ![]() |
NOx and CO2 air emission | Clean Air Mgmt |
|
Hazardous waste generation (grouped together with engine cleaning and small parts cleaning which have similar impacts) | - | Haz Waste Mgmt |
|
Hearing Degradation/Wildlife Disturbance | - | Noise & Vibration |
|
![]() | Haz Waste Generation | Haz Waste Mgmt | |
Spills/Solvent Run Off | Clean Water Mgmt | ||
VOC Emissions Less VOC's Less Haz Waste | Clean Air Mgmt Material Substitution/Reduction/Elimination |
||
Facilities Maintenance: Landscape Maintenance ![]() | Less Solid Waste Generation | Recycling |
|
![]() | Haz Waste Disposal | Pesticide Mgmt | |
Construction of Facilities: Building a road ![]() | Loss of Wetland Habitat | Wetlands/Floodplains |
|
Mission Deployment:![]() | Less HCFC's (beneficial) | Clean Air Quality Pollution Prevention |
|
Personal Property Disposal Operations:![]() | Less Material to landfill (beneficial) | Recycling |
|
Equip. Maintenance: Engine Repair ![]() | Increase in Haz Waste Generation/disposal | - | Haz Waste Mgmt |
3.1.3.5 Step 5: Categorize the aspects and impacts into the appropriate four focus areas.
Centers shall categorize the activities, products, and services identified in step 4 into the following four focus areas:
a. Prevention-Fostering a holistic approach to pollution prevention to instill an environmental ethic that will avoid future compliance and restoration problems.
b. Compliance-Ensuring that NASA's current and future operations meet all Federal, State, and local environmental regulations.
c. Restoration-Addressing all contaminated sites as rapidly as possible to protect human health and the environment. Actively seeking public involvement in the decisionmaking process.
d. Conservation-Exercising responsible stewardship for all the resources NASA controls.
Where multiple focus areas may apply, the primary focus area(s) shall be selected, based on best professional judgment. Below is an example of categorizing aspects and impacts into focus areas:
ACTIVITY, PRODUCT, or SERVICE | IMPACT | GROUP IMPACTS | ASPECT | FOCUS AREA |
R and D: Aircraft engine testing ![]() |
NOx and CO2 air emission | Clean Air Mgmt | Compliance |
|
Hazardous waste generation (grouped together with engine cleaning and small parts cleaning which have similar impacts) | - | Haz Waste Mgmt | ||
Hearing Degradation/Wildlife Disturbance | - | Noise | Prevention |
|
![]() | Haz Waste Generation | Haz Waste Mgmt | Compliance | |
Spills/Solvent Run Off | ||||
VOC Emissions Less VOC's Less Haz Waste | Clean Water Mgmt Clean Air Mgmt Material Substitution | Prevention |
||
Facilities Maintenance: Landscape Maintenance ![]() | Less Solid Waste Generation | Recycling | Conservation |
|
![]() | Haz Waste Disposal | Pesticide Mgmt | Compliance | |
Construction of Facilities: Building a road ![]() | Loss of Wetland Habitat | Wetlands/Floodplains | Conservation |
|
Personal Property Disposal Operations:![]() | Less Material to landfill (beneficial) | Recycling | Prevention |
|
Mission Deployment:![]() | Less HCFC's (beneficial) | Clean Air Quality Pollution Prevention | Compliance Prevention |
Once impacts have been grouped and categorized into aspects, and the four focus areas, the next step is to determine which impacts are priority environmental impacts. A priority environmental impact is a NASA environmental impact that--
a. shall be managed to avoid or prevent a serious adverse environmental effect, or
b. create a substantial beneficial effect. 2
3.1.3.6 Step 6: Categorize environmental consequence
Centers shall classify each individual or grouped impact from step 5 into one or more of the six consequence categories listed below:
a. Safety and Health (S&H)
b. Natural and Cultural Resources Impacts (NCR).
c. Cost to NASA (Cost).
d. Mission Impacts (MI).
e. Reputation and Stakeholder Relationships (R&S).
f. Environmental Legal/Regulatory Implications (L&R).
Environmental Consequence Categories
Note: Both adverse and beneficial consequences should be considered within this framework3.
Safety and Health(S&H) 4 |
1. Death or disabling injury |
2. Severe injury/lost time or human health impact |
3. Minor injury or human health impact |
4. No injury or other health effect |
3 The magnitude of an adverse or beneficial consequence is to be described using the same series of possible consequence categories. For beneficial impacts the consequence may be the consequence avoided.
4 Safety and health relates to safety and health effects for individuals including those performing an environmental function (for example: handling of hazardous waste).
Natural and Cultural Resources Impacts 5(NCR) |
1. Irreparable damage to natural or cultural resources |
2. Impact on natural or cultural resources |
3. Minimal impact on protected natural or cultural resource |
4. No impact in natural or cultural resources |
Cost to NASA (Cost)6 |
1. Greater than $250,000 |
2. $100,000 to $250,000 |
3. $50,000 to $100,000 |
4. Zero to $50,000 |
Mission Impacts (MI) |
1. Delay in mission-critical activity |
2. No delay, but large cost to avoid delay |
3. No delay, but minimal cost to avoid delay |
4. No delay, no cost |
Reputation and Stakeholder Relationship (R&S) |
1. Increase in negative public inquiries/mandatory meeting attendance |
2. Adverse effect on NASA reputation or stakeholder relations |
3. Minimal effect on NASA reputation or stakeholder relations |
4. No effect on NASA reputation or stakeholder relations |
Environmental Legal and Regulatory Implications (L&R) 7 |
1. Any fine, consent agreement, unilateral order, or noncompliance with legal and other requirements |
2. Notice of violation with no fine |
3. Informal notice |
4. No regulatory action |
3.1.3.7 Step 7: Determine the severity of the problem
For each impact, Centers shall use the environmental consequence category table to determine the lowest numerical severity score for each applicable consequence category associated with failing to properly manage the environmental impact. Normal, abnormal, and emergency scenarios, where applicable, will be considered.
Example:
If hazardous air pollutant emissions were not properly managed by a Center, it is likely to receive a fine and/or consent agreement in association with normal operations. Therefore, under L&R, the severity would be a 1. |
6 The cost to NASA is the cost impact of not meeting the environmental requirement. For example, the "cost to NASA" of an oil spill would include the cost of cleaning up the spill, the cost of the downtime to the Center, and the cost of the fines (if any).
7 A consequence of 1 includes an internally identified noncompliance (that it is believed would have resulted in a fine if externally identified) and a 2 or 3 recognizes the different degrees of external enforcement intensity that might exist.
3.1.3.8 Step 8: Evaluate the likely frequency of occurrence
Centers shall assign a numerical probability to each impact, based on the above consequence categories and potential frequency of occurrence for normal, abnormal, and emergency situations as appropriate.
Example:
An impact with which the three operational situations are associated would be solvent waste handling. Normal operation results in hazardous waste with the frequency category 1. Abnormal impacts would include solvent waste generated during special events and added solvent waste streams when small spills occur during maintenance operations. This type of situation historically has occurred once in the past 5 years for frequency of category 2. A potential emergency would be a fire involving flammable solvent waste, which has not historically occurred at the Center, and therefore, category 4 applies. The potential for all three situations is part of the rationale for storage and handling practices already in place . |
Centers shall use the table below (take into account the historical record of such an incident occurring) to determine the most probable frequency of the scenario occurri