NASA Procedural Requirements |
NPR 8553.1C Effective Date: July 20, 2020 Expiration Date: July 20, 2025 |
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a. Center management shall follow each of the steps described below to identify priority environmental aspects essential to developing the EMS. Center employees are expected to apply best professional judgment during this process.
b. Figure 3-1 and notes illustrate the recommended order of steps for this process. Center management will complete all steps.
Figure 3-1, Flow Diagram of Overall Process for Identifying Environmental Aspects and Impacts, Identifying Risks and Opportunities, and Determining High-Priority Environmental Aspects
a. In Steps 1 to 3, a list of environmental aspects and impacts is developed, and the environmental aspects are grouped into categories.
b. Once environmental aspects have been categorized, Steps 4 to 6 assign applicable risks/opportunities and associated severity and frequency.
c. To establish the level of priority for an environmental aspect, the priority associated with the environmental impact is defined in Step 7 using a combination of the severity and probability of the associated risk or opportunity.
3.2.1 Step 1: List all activities, products, and services.
Within the scope of its EMS, each Center Director shall identify all activities, products, and services under NASA's direct control, as well as those activities, products, and services over which it has control or influence, based on the nature and scale of its operations.
3.2.2 Step 2: Identify environmental aspects and impacts.
a. Center management shall determine the environmental aspects and impacts associated with the activities, products, and services identified in Step 1, considering:
(1) Past activities, products, and services with environmental aspects and impacts that potentially require management in the present or future.
(2) Environmental aspects and impacts associated with activities, products, and/or services that are planned for the future, with a reasonable degree of certainty.
(3) In the identification of present and future environmental aspects and impacts, normal, abnormal, and emergency conditions that can be reasonably foreseen as well as lessons learned from past activities.
(a) Where separate environmental aspects and impacts have been identified based on consideration of normal, abnormal, and emergency conditions, each environmental aspect and impact is subject to Steps 4 through 7 below.
(b) Where risks or opportunities or their severity or probability (see Steps 4, 5, and 6) vary, depending on different conditions, these variations should be considered as separate environmental aspects and impacts when determining priority level. Alternatively, the highest severity and frequency scores may be selected.
3.2.3 Step 3: Group environmental aspects and impacts for manageability and assign environmental aspect categories.
a. Where practical, Centers may group environmental aspects and associated environmental impacts to ensure that further analysis is manageable.
b. Center management shall take the output from Step 2 and any grouping that has been conducted in Step 3 and assign environmental aspect categories, as appropriate.
c. Where an environmental aspect and its associated environmental impacts may apply to more than one environmental aspect category, the category selection is based on best professional judgment.
d. The Center is free to determine the category into which an individual environmental aspect is placed within the list of 17 categories in Table 3-1. Category 17 will be used for the addition of Center-specific environmental aspects or unique compliance obligations, such as mutual aid agreements, host-tenant agreements, concessionaire agreements, memoranda of understanding, Space Act agreements and Commercial Space Launch Act agreements, as well as land use agreements, programmatic agreements with the SHPO, and Center-specific Biological Opinions.
Table 3-1, Environmental Aspect Categories
1 | Air Emissions, including: Stationary and point sources Mobile sources Ozone-depleting substances Fugitive emissions Greenhouse gases |
2 | Cultural Resources, including: Archaeological resources Historic resources |
3 | Efficient Fleet Management, including: Acquisition of alternative-fuel vehicles Alternative-fuel infrastructure Fleet size reductions Fuel use reductions |
4 | Energy/Water Consumption, including: Reduction in energy use Reduction in water consumption Use of renewable energy |
5 | Environmental Review, including: Environmental justice National Environmental Policy Act (NEPA) Noise Non-ionizing radiation Odors Socioeconomic impacts |
6 | Fuel, Oils, and Lubricants, including: Container storage Aboveground storage tanks Underground storage tanks Generators Transformers Hydraulic systems Spill prevention control and countermeasures Spill response |
7 | Hazardous Materials, including: Hazardous materials storage Emergency planning and response Community right-to-know Reduction in the quantity of toxic and hazardous chemicals and materials acquired, used, or disposed (e.g., reuse) |
8 | Regulated Waste, including: Collection and storage Off-site shipment and disposal Hazardous waste Hazardous waste recycling Hazardous waste treatment, storage, and disposal facilities Medical waste State-regulated industrial or chemically contaminated wastes Universal and special wastes |
9 | Natural Resources, including: Land use and resources Wetlands and floodplains Threatened and endangered species Wildlife Ecosystems Oceans and coastal zones |
10 | Remediation/Restoration, including: Comprehensive Environmental Response, Compensation, and Liability Act sites Resource Conservation and Recovery Act sites Tank sites |
11 | Solid Waste (non-hazardous), including: General trash Construction waste Solid waste landfills Waste prevention and recycling |
12 | Sustainable Acquisition, including: Purchasing green goods and services Electronics stewardship |
13 | Sustainable Facilities, including: Encroachment High-performance and sustainable buildings |
14 | Toxic Substances, including: Asbestos Lead products (including paint) Mercury Polychlorinated biphenyls Pesticides/herbicides Radioactive materials |
15 | Water Quality, including: Drinking water Groundwater Storm water Sanitary or domestic wastewater Industrial wastewater Eutrophication |
16 | Executive Order (EO) Monitoring and/or Reporting Requirements |
17 | Center-Specific Obligations |
3.2.4 Step 4: Categorize environmental risks/opportunities.
a. Center management shall manage "high-priority environmental aspects" so as to:
(1) Avoid or prevent a serious adverse environmental risk.
(2) Create a substantial beneficial environmental opportunity.
b. Each individual or grouped environmental aspect will be classified into one or more of the following categories by assigning associated environmental risks/opportunities:
(1) Safety
(2) Natural and cultural resources (NCR)
(3) Compliance obligations
(4) Performance
(5) Reputation and stakeholder relationships (R&S)
(6) Cost
(7) Schedule
c. Center management shall consider both adverse risks (R) and beneficial opportunities (O) within the framework in Table 3-2.
d. The Center may adjust the EMS risks (R) and opportunities (O) scoring in Table 3-2 to meet the needs of the site. The objective of this scoring system is to ensure that only a few aspects will receive the highest scores in any category. Center management shall ensure that the adjustments to the scoring are geared to drive this objective and are documented.
Table 3-2, NASA EMS Risk (R)/Opportunity (O) Categories
Safety | Score |
(R/O) Negligible risk or opportunity. | 1 |
(O) Avoids source of nuisance or irritant.(R) Nuisance or irritant. | 2 |
(O) Avoids minor injury or human health impact. (R) Minor injury or human health impact. | 3 |
(O) Eliminates source of substantial injury/lost time or human health impact. (R) Potential source of substantial injury/lost time or human health impact. | 4 |
(O) Eliminates potential source of death or disabling injury. (R) Potential source of death or disabling injury. | 5 |
Natural and Cultural Resources (NCR) | Score |
(R/O) Negligible impact or benefit on natural or cultural resources. | 1 |
(O) Results in minor improvement to natural or cultural resources. (O) Results in minor improvement in sustainable practices. (R) Minor impact on natural or cultural resources. | 2 |
(O) Supports conservation of natural or cultural resources. (O) Results in moderate improvement in sustainable practices. (O) Moderate reduction of impacts on natural or cultural resources. (R) Moderate impact on natural or cultural resources. | 3 |
(O) Prevents substantial impact to onsite, protected, natural, or cultural resources. (O) Results in substantial restoration or conservation of/improvements to onsite protected natural or cultural resources. (O) Results in substantial improvement in sustainable practices. (R) Substantial onsite impact on protected natural or cultural resources. | 4 |
(O) Prevents off-site damage to natural or cultural resources. (O) Results in expanded off-site natural or cultural resources. (O) Results in sustainable off-site improvement in sustainable practices. (R) Off-site damage to natural or cultural resources. | 5 |
Compliance Obligations | Score |
(R/O) Negligible regulatory action. | 1 |
(O) Improve relationship with regulators. (O) Avoids an informal notice. (R) Informal notice. | 2 |
(O) Avoids a potential notice of violation with no fine. (O) Minor incentive, such as eliminates a minor regulatory requirement. (R) Notice of violation with no fine. | 3 |
(O) Major incentive, such as regulatory relief. (R) Significant fine, consent agreement, unilateral order, or noncompliance with legal and other requirements. | 4 |
(O) Significant incentive, such as eliminate regulatory requirement. (R) Work stoppage. (R) Criminal sanctions. | 5 |
Performance | Score |
(R/O) Negligible risk to mission/institutional capability. | 1 |
(O) Temporary enhancement of mission/institutional capability. (R) Temporary loss of mission/institutional capability. | 2 |
(O) Moderate enhancement to mission/institutional capability. (R) Moderate loss of mission/institutional capability. Workaround available. | 3 |
(O) Significant enhancement to mission/institutional capability. (R) Significant loss of mission/institutional capability. Workaround available. | 4 |
(O) Permanent enhancement to mission/institutional capability. (R) Permanent loss of mission/institutional capability. | 5 |
Reputation and Stakeholder Relationship (R&S) | Score |
(R/O) Negligible media interest or effect on NASA reputation or stakeholder relations. | 1 |
(O) Minor increase in positive public inquiries or stakeholder support. (R) Minor adverse effect on NASA reputation or stakeholder relations. | 2 |
(O) Moderate increase in positive public inquiries or stakeholder support. (R) Moderate adverse effect on NASA reputation or stakeholder relations. | 3 |
(O) Substantial increase in positive public inquiries or stakeholder support. (R) Substantial adverse effect on NASA reputation or stakeholder relations. | 4 |
(O) Major increase in positive public inquiries or stakeholder support. (R) Major increase in negative public inquiries/mandatory meeting attendance. (R) Potential mission risk. | 5 |
Cost | Score |
(R/O) Negligible benefit or cost impact. | 1 |
(R/O) Net benefit or cost of less than $50,000. | 2 |
(R/O) Net benefit or cost of $50,000 to less than $100,000. | 3 |
(R/O) Net benefit or cost of $100,000 to $500,000. | 4 |
(R/O) Net benefit or cost of greater than $500,000. | 5 |
Schedule | Score |
(R/O) Negligible schedule change. | 1 |
(O) Accelerates mission/project schedule by 1 day to less than 1 month. (R) Delays mission/project schedule by 1 day to less than 1 month. | 2 |
(O) Accelerates mission/project schedule by 1 month to less than 3 months. (R) Delays mission/project schedule by 1 month to less than 3 months. | 3 |
(O) Accelerates mission/project schedule by 3-6 months. (R) Delays mission/project schedule by 3-6 months. | 4 |
(O) Accelerates mission/project schedule by greater than 6 months (R) Delays mission/project schedule by greater than 6 months. | 5 |
3.2.5 Step 5: Determine the environmental risk/opportunity severity score for each category.
a. For each environmental aspect, Center management shall use the environmental risk/opportunity categories in Table 3-2 to determine the numerical score for the applicable category.
b. Center management shall ensure that determination of severity scores includes the effect of management controls in place to mitigate environmental risks or secure existing opportunities.
3.2.6 Step 6: Determine the probability score for each category.
a. Center management shall assign a numerical, probability-based score to each environmental aspect, using the applicable risk/opportunity categories and the probability rating of the risk/opportunity.
b. Center management shall ensure that probability scores include the potential effect of management controls in place to mitigate environmental risks or secure existing opportunities.
c. Taking into account the historical record of such an incident occurring, Center management shall use Table 3-3 to determine the probability score for each scenario.
d. Center management shall assign the score that corresponds with the probability rating.
Table 3-3, NASA EMS Probability Scoring
Probability Rating | Ordinal Value | Description of Risk Probability (Examples) |
---|---|---|
Very Low | 1 | Qualitative: Very unlikely to occur, management not required in all cases. Either strong controls are in place or controls are not required.
OR Frequency: Minimum of once every 10+ years. |
Low | 2 | Qualitative: Not likely to occur, management not required in most cases. Current controls have minor limitations/uncertainties and may need to be strengthened. OR Frequency: Once every 5 years to once every 10 years. |
Moderate | 3 | Qualitative: May occur, management required in some cases. Current controls exist with some uncertainties, need for review is evident. OR Frequency: Once a year to once every 5 years. |
High | 4 | Qualitative: Highly likely to occur, most cases require management attention. Current controls have significant uncertainties, corrective actions likely. OR Frequency: Once a month to once a year. |
Very High | 5 | Qualitative: Nearly certain to occur, requires immediate management attention. Current controls have little or no effect. Implementation of corrective action is mandatory. OR Frequency: Continuous to once a month. |
3.2.7 Step 7: Determine overall priority level.
a. Center management shall determine the priority level of the associated environmental aspect based on the environmental risk/opportunity severity versus probability using the 5x5 Risk Matrix illustrated in Figure 3-2.
Figure 3-2, 5x5 Risk Matrix With Priority-Level Categories
b. The overall priority level for each environmental aspect is determined by the risk/opportunity associated with the most severe scores.
c. Center management shall ensure that the Center's aspect inventory is reviewed and updated annually. This review will be based on anticipated changes in Center operations, known abnormal/emergency situations, and changes to compliance obligations.
d. If interested party (Component Facility, contractor, partner, commercial tenant) personnel are required to conduct Steps 1 through 6, the Center EMS Representative and appropriate environmental subject matter experts shall review and approve, modify, or reject the data or request further analysis, in addition to making the overall risk-ranking determination.
3.2.8 Step 8: Set objectives, targets, and programs.
Center management shall determine which environmental aspects, associated with specific activities, products, and services, require objectives and targets as defined in Section 3.4.
3.3.1 Center management shall establish and maintain procedures to identify and document:
a. Compliance obligations applicable to the environmental aspects of NASA's activities, products, and services.
b. The environmental risks and applicable compliance obligations associated with NASA-wide and Center-specific contracts, partnerships, agreements, and commitments. See Section 1.3.4.
3.3.2 Center management shall develop, implement, and maintain procedures for the annual evaluation of the applicability of compliance obligations, as well as any proposed changes to existing compliance obligations, to Center activities and operations.
3.3.3 Center management shall consider compliance obligations in establishing, implementing, and maintaining the Center's EMS and ensure:
a. All applicable compliance obligations are available to appropriate individuals at the Center and to Mission Directorates and Mission Support Offices, on request.
b. Center Offices of Chief Counsel are consulted, as necessary, in fulfilling responsibilities under Section 3.3.
3.4.1 Center management shall ensure appropriate organization levels establish and document objectives and targets, as needed for implementing and maintaining the EMS. The determination of the need for objectives and targets will be made by the appropriate NASA authority; objectives and targets may be suggested by other interested parties.
3.4.2 Center management shall ensure objectives and targets are:
a. Consistent with the environmental policy.
b. Measurable (if practicable).
c. Monitored.
d. Communicated.
e. Maintained.
3.4.3 When establishing objectives and targets, management at each Center shall consider:
a. Compliance obligations.
b. Priority environmental aspects.
c. Risks and opportunities.
3.4.4 Center management shall establish specific objectives and targets, that are technically feasible and economically reasonable, to address high-priority environmental aspects. If the determination is made that a high-priority environmental aspect cannot be addressed with one or more objectives and targets, because it is not technically feasible or is economically unreasonable, the rationale behind this determination will be documented. Objectives and targets may be established by Center management for medium- or low-priority aspects, as necessary, to address other Federal, Agency, or Center goals and commitments.
3.4.5 Center management shall establish, document, implement, and maintain EMPs for achieving the established objectives and targets. Each EMP will address:
a. What will be done.
b. What resources will be required.
c. The personnel responsible for initiation, oversight, and completion.
d. A timeframe for completion, including milestones, as appropriate.
e. Progress toward completion.
f. How the results will be evaluated.
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