NASA Procedures and Guidelines

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 Engine Run Ups Engine Cleaning

Facilities Maintenance: Landscape Maintenance Mulching Pesticide Use

Construction of Facilities: Building a road Crossing Wetlands

Mission Deployment: External Tank Foam Blowing

Personal Property Disposal Operations: Waste Paper Recycling

Equipment Maintenance: Engine Repair Small Parts Cleaning

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 Engine Run Ups	NOx and CO2 air emission
	Haz waste generation
	Hearing degradation/wildlife disturbance
	Hearing degradation/wildlife disturbance
Engine Cleaning	Haz waste generation
	Spills/solvent run off
	VOC emissions
	Less VOC's/ Less haz waste
Facilities Maintenance: Landscape Maintenance Mulching/Composting	Less solid waste generation
Pesticide Use	Haz waste disposal
Construction of Facilities: Building a road Crossing Wetlands	Loss of wetland habitat
Mission Deployment: External Tank Foam Blowing	Less HCFC's (beneficial)
Personal Property Disposal Operations: Waste Paper Recycling	Less Material to landfill (beneficial)
Equip. Maintenance: Engine Repair Small Parts Cleaning	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 Engine Run Ups	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	-
Engine Cleaning	Haz Waste Generation
	Spills/Solvent Run Off
	VOC Emissions Less VOC's Less Haz Waste
Facilities Maintenance: Landscape Maintenance Mulching/Composting	Less Solid Waste Generation
Pesticide Use	Haz Waste Disposal
Construction of Facilities: Building a road Crossing Wetlands	Loss of Wetland Habitat
Mission Deployment: External Tank Foam Blowing	Less HCFC's (beneficial)
Personal Property Disposal Operations: Waste Paper Recycling	Less Material to landfill (beneficial)
Equip. Maintenance: Engine Repair Small Parts Cleaning	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 Engine Run Ups	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
Engine Cleaning	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 Mulching/Composting	Less Solid Waste Generation		Recycling
Pesticide Use	Haz Waste Disposal		Pesticide Mgmt
Construction of Facilities: Building a road Crossing Wetlands	Loss of Wetland Habitat		Wetlands/Floodplains
Mission Deployment: External Tank Foam Blowing	Less HCFC's (beneficial)		Clean Air Quality Pollution Prevention
Personal Property Disposal Operations: Waste Paper Recycling	Less Material to landfill (beneficial)		Recycling
Equip. Maintenance: Engine Repair Small Parts Cleaning	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 Engine Run Ups	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
Engine Cleaning	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 Mulching/Composting	Less Solid Waste Generation		Recycling	Conservation
Pesticide Use	Haz Waste Disposal		Pesticide Mgmt	Compliance
Construction of Facilities: Building a road Crossing Wetlands	Loss of Wetland Habitat		Wetlands/Floodplains	Conservation
Personal Property Disposal Operations: Waste Paper Recycling	Less Material to landfill (beneficial)		Recycling	Prevention
Mission Deployment: External Tank Foam Blowing	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

² Within 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 uses the term "priority" instead of "significant" when describing environmental impacts.

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.

⁵ Natural and Cultural Resources include, but are not limited to, protected habitat and species, wetlands, historic and archeological sites, and excessive use of raw materials including energy and water consumption.

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 , ng. Assign the category number that corresponds with the potential frequency of occurrence.

3.1.3.9 Step 9: Determine overall risk ranking level

Centers shall determine the priority of the impact based on the consequence versus probability matrix listed below.

Note: An impact may have one or more consequence categories associated with it and with differing severity and frequencies depending on normal, versus abnormal, or emergency situations.

Overall risk ranking is determined by assigning the risk of each impact based on the most severe action priority category. The overall risk ranking determination shall be made by the Government. If contractor personnel conduct steps 1 through 8, NASA personnel shall review and approve, modify, or reject the data, or request further analysis. Once NASA personnel accept the data, NASA personnel shall determine overall risk ranking.

Note: Remember to note any activity, product, or service that has a beneficial impact on the environment and designate it appropriately on the Risk Matrix Form.

3.1.3.10 Step 10: Determine which activities require objectives and targets

Centers shall determine which activities require objectives and targets (refer to section 3.3). Objectives and targets shall be assigned to all High Priority Impacts.

The determination of the need for objectives and targets shall be made by the Government; however, the actual objectives and targets may be suggested by other interested parties.