SAINT JOHN ENERGY ISO Environmental Management System (EMS) Manual All Operations

Transcription

1 SAINT JOHN ENERGY ISO Environmental Management System (EMS) Manual All Operations Saint John Energy Revision 25

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3 i Table of Contents 1.0 Introduction EMS Manual CEA Sustainable Electricity Program Context Organization and Its Context Needs and Expectations of Interested Parties Scope of the Environmental Management System Environmental Management System Leadership Leadership and Commitment Environmental Policy Organizational Roles, Responsibilities and Authorities Planning Actions to Address Risks and Opportunities General Environmental Aspects Compliance Obligations Planning Action Environmental Objectives and Planning to Achieve Them Environmental Objectives Planning Actions to Achieve Environmental Objectives Support Resources Competence Awareness Communication General Internal Communication External Communication Saint John Energy Revision 25

4 ii 7.5 Documented Information General Creating and Updating Control of Documented Information Operation Operational and Planning Control Emergency Preparedness and Response Performance Evaluations Monitoring, Measurement, Analysis and Evaluation General Evaluation of Compliance Internal Audit General Management Review Improvement General Nonconformity and Corrective Action Continual Improvement Figures Figure 1 ISO Environmental Management System Framework... 2 Figure 2 Saint John Energy Corporate EMS Reporting Organization Chart... 9 Saint John Energy Revision 25

5 1 1.0 Introduction An increasing number of businesses are reflecting a current trend in Canada and elsewhere to integrate the management of environmental issues pertaining to their company with all other aspects of the business. Such organizations are working to ensure that each of the components of their activities take into account what is in the best interest of the customer, Saint John Energy (SJE) and the environment, both for the present and for the future. A common tool for organizations wishing to adopt this approach is implementation of an Environmental Management System (EMS) which adheres to the principles of ISO SJE has committed to such a sustainable approach to operations through their membership in the Canadian Electricity Association (CEA). The Association has stipulated that member distribution utilities must have an ISO compatible or registered EMS. Maintaining SJE's EMS ensures that it continues to conduct its business in a proactive, environmentally accountable, and socially acceptable manner. SJE's EMS is a comprehensive system for managing its environmental risks and opportunities and integrating environmental matters into the utility's overall management system. The EMS serves as a planning tool to allow SJE to continually improve and refine its operations. Saint John Energy Revision 25

6 2 2.0 EMS Manual This EMS Manual provides details of the policies and processes for SJE to have sound environmental management practices in all areas of its operation. Effective use of the EMS allows SJE to maintain and improve environmental performance by controlling the impact of their activities on the environment. The EMS is an integral part of the overall management system that includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy. SJE has utilized the standard described in the International Organization for Standardization (ISO) as issued by the Standards Council of Canada as CAN/CSA-ISO "Environmental Management Systems - Requirements with Guidance for Use". The approach to implementation is defined as a model, which is shown on Figure 1, and shows the sequence from the policy to planning, implementation and operation, checking and corrective action and management review. The principle of continual improvement is provided by the "performance evaluation" item in the model from which corrective/improvement items are regularly fed into the system resulting in updating of the procedures as appropriate. Figure 1 ISO Environmental Management System Framework Source: CAN/CSA-ISO The commitments defined above and the approach presented in Figure 1 has been reflected in this EMS Manual. The document is structured to reflect the headings defined in the ISO Standard. Saint John Energy Revision 25

7 3 3.0 CEA Sustainable Electricity Program Sustainable Electricity is a mandatory sustainability program developed and implemented by CEA and its Corporate Utility Members. The program promotes the integration of sustainability in business decision-making and continual performance improvement of CEA members. Together, CEA and its Corporate Utility Members are committed to sustainable development, which is defined as: Pursuing progressive business strategies and activities that meet the needs of the present, while enhancing the environmental, social, and economic resources that will be needed in the future. Foundational elements While the Sustainable Electricity Program is responsive to the diversity of its Corporate Utility Members, the program is founded on the following elements: All Corporate Utility Members agree and adhere to the Sustainable Development Corporate Responsibility Policy; All Corporate Utility Members report on their Sustainable Electricity key performance indicators, which are synthesized in an annual report; Individual company sustainability performance is verified; and A Public Advisory Panel provides feedback on the members sustainability performance. Saint John Energy Revision 25

8 4 4.0 Context 4.1 Organization and Its Context SJE is owned by the City of Saint John, and accountable to our 36,400 residential, commercial and industrial customers for reliable service at rates that are among the lowest in the region. The important risks and opportunities that are currently affecting the way the organization manages its environment responsibilities are as follows. Size (large area for the number of customers); Financial-increased costs and pressure not to increase rates; Monopoly; CEA membership; ISO EMS; Climate change (more storms); Aging infrastructure (replacement); Grid modernization; and Reduced customer energy consumption 4.2 Needs and Expectations of Interested Parties SJE has determined the relevance of the different subject matter items through various interactions with interested parties including but not limited to: Annual Community General Meetings open to all interested parties, larger ones are directly invited. Attendees are given feedback cards and there is a question and answer period at each meeting. Attendees historically have included rate payers, government officials, the press and other interested parties. Customer Focus Groups covering a broad range of topics across the range of our business operations. Customers provide feedback on how we are performing and where they feel we should concentrate our efforts as we move forward. Customer surveys questions include rating SJE s safety performance, environmental stewardship, reliability and many other areas. Customers provide feedback on the areas of most importance and strategic plans are put in place to address their concerns. Open City Council Meetings presentations are made at least annually to the Mayor and Council at open sessions of City Council. Past performance and strategic vision for the future are presented in this transparent manner. Saint John Energy Revision 25

9 5 Quarterly Staff Meetings staff present project updates to all employees on a regular basis thus increasing the transparency of operations to them. Website SJE s public website is a wealth of information for interested parties and provides a conduit for asking questions to various departments. The input from all of these methods is used to ensure SJE is addressing the concerns of our interested parties in a timely manner. Those considered to have an interest in SJE s environmental performance as well as their needs and expectations are summarized in the table below. Interested Parties Needs and Expectations Compliance Requirement?* SJE Board of Commissioners Internal EMS Conformance Yes City of Saint John Internal Cost sustainability and competitiveness No SJE employees Internal EMS program elements and Internal performance reporting Yes Regulatory and other agencies External Compliance and reporting Yes Customers External Cost competitiveness and environmentally responsible No Suppliers External None No Neighbors and others External Communication No *For specific compliance obligations refer to the Compliance Register in Appendix A. 4.3 Scope of the Environmental Management System The EMS as it applies to the distribution of electricity, including building maintenance, administration activities, purchasing, fleet management and field activities (substation, street and city lighting, pole and wire maintenance). 4.4 Environmental Management System The requirements of the ISO14001:2015 Standard and other SJE requirements are described in this EMS Manual and referenced documents within, related to the following main elements: 4.0 Context of the Organization 5.0 Leadership 6.0 Planning 7.0 Support 8.0 Operation 9.0 Performance Evaluation 10.0 Improvement Saint John Energy Revision 25

10 6 5.0 Leadership 5.1 Leadership and Commitment The Chairman and Board of Commissioners (Board) are the ultimate reporting body for SJE. The Management Team, defined below, is committed to proactive leadership and accountability in implementing and maintaining SJE s EMS. The Management Team will be well versed in the EMS and incorporate appropriate environmental management practices into general business activities as they are determined to be relevant. 5.2 Environmental Policy The President and CEO endorses in writing the facility s Environmental Policy and ensures that it is communicated to all persons working for or on behalf of SJE as summarized in the table below. Environmental Policy Communication Existing Employees New Employees Contractors The public Posted in the lobby of the head office During employee awareness training During new employee orientation prior to commencing work During contractor orientation prior to commencing work Posted in the lobby of head office Posted on the external website Environmental Policy Review Process The activities, products and services provided by SJE are reviewed by the President and CEO annually to ensure that they are consistent with the goals of the environmental policy. The Board of Commissioners conducts an annual review of the Environmental Policy statement to ensure its suitability with respect to SJE operations and the expectations of its interested parties. Saint John Energy Revision 25

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12 8 5.3 Organizational Roles, Responsibilities and Authorities The corporate organizational structure for the implementation, review and maintenance of SJE's EMS is shown in Figure 2. The EMS is designed to be integrated with SJE's overall management system. The roles and responsibilities for key individuals with respect to the EMS are outlined below. President and Chief Executive Officer (CEO) has the overall responsibility for implementing the environmental policy and subsequent EMS. The President and CEO reports to the Board of Commissioners and is responsible for implementing their directions on all matters including matters related to the EMS as they relate to management and operations. The President and CEO have appointed the HSE Coordinator responsible for the day-to-day management of the EMS, including audits, performance reviews, etc. Vice President of Finance and Administration and Vice President of Engineering and Operations (Executive Managers) are responsible to the President and CEO for the environmental performance of their divisions and must integrate the requirements of the EMS with SJE's other management requirements. Health, Safety and Environment Coordinator (HSE Coordinator) reports to the Manager of Shared Services and is responsible for all issues and aspects relating to the EMS across the organization. The HSE Coordinator provides support to the Managers with respect to maintenance of the EMS and monitoring of environmental performance in each department to ensure its requirements are met. Duties of the HSE Coordinator include: amalgamation of monthly reports from the Managers on environmental performance into quarterly and annual summary reports for submission to the President and CEO; coordination of environmental budgets for training and other environmental performance related activities as necessary and amalgamation for submission to the President and CEO; scheduling and implementation of training programs; review and prioritization of expenditures to address environmental matters; and possession of current knowledge with respect to legislation and industry requirements as they pertain to activities of SJE. Saint John Energy Revision 25

13 9 Figure 2 Saint John Energy Corporate EMS Reporting Organization Chart Saint John Energy Revision 25

14 Planning The following sections outline the environmental risks and opportunities associated with the daily activities of SJE and compliance requirements to which the utility must adhere. Following identification of the environmental requirements, a series of objectives are defined to ensure that SJE meets the corporate environmental policy goals as well as regulatory requirements. 6.1 Actions to Address Risks and Opportunities General The majority of risks and opportunities within the EMS scope are managed via engineering controls and operational procedures as they relate to environmental aspects, compliance obligations and other requirements further detailed in Section Environmental Aspects Under ISO 14001, environmental aspects are defined as "...an element of an organization's activities, products or services that can interact with the environment." SJE s EMS addresses the aspects of SJE's operations that could potentially impact air, water, land and/ or social systems. There are several components that make up SJE's operations and daily activities, not all of which have environmental concerns associated with them. Activities include, but are not limited to, the following: building maintenance (including grounds keeping), administration activities (paper use, toner cartridge replacement, etc.), purchasing, fleet management, and various field activities. Following discussions with representatives of the administration, engineering and operations departments and the HSE Coordinator, environmental aspects of concern were identified as those which may adversely impact air, water or terrestrial resources. These are identified in the Aspects Identification Process below and summarized in the Environmental Aspects Table in Appendix A. Criteria used to evaluate the significance of potential impacts associated with each of the aspects includes consideration of the following: scale of potential impact; severity of potential impact; probability of occurrence; duration of potential impact; potential regulatory and legal exposure; difficulty to change impact; cost to change impact; Saint John Energy Revision 25

15 11 effect of change on other activities and processes; concerns of interested parties; and effects on public image. For each aspect, the above criteria were scored 0 to 3 (0 = low, 3 = high) for a maximum total score of 30 for each aspect. The totals were then used to categorize the overall impact as low (total less than 16) or high (total greater than or equal to 16). See Appendix A for a tabulation of the significance of the environmental aspects. Aspects Identification Process 1. SJE has developed and evaluates its aspects based on a review of its operation that could potentially impact air, water, land and/or social systems as outlined above. 2. SJE commits to a yearly review of its aspects. New or modified activities, operations, products and/or services require an aspect review prior to implementation. 3. New aspects are developed or existing ones modified with the consultation of the affected departments. 4. All environmental aspects are grouped into categories for ease of handling and review. Categorized aspects are listed in the Environmental Aspects Table in Appendix A. 5. Grouped aspects are evaluated to determine the significance of the potential environmental impacts using the SJE Environmental Aspects Evaluation Form in Appendix B. 6. The identified evaluation results are summarized in the Environmental Aspects Table. 7. Significant Aspects are addressed utilizing the Objectives Process outlined in Section The review is done annually or sooner if new or modified activities occur. Activities conducted at SJE that were determined to have potentially adverse environmental impacts associated with them include activities associated with: 1. Waste Management; 2. Building Management; 3. Hazardous Materials Management; 4. Materials/Product Management; and 5. Pesticide Usage. The key environmental aspects associated with these activities and for which procedures have been developed include: solid waste generation (any product that cannot be recycled or used as feedstock for another process); Saint John Energy

16 12 hazardous waste generation/handling/accidental discharge; use of unsustainable /non-green products; generation of exhaust, fugitive dust, noxious fumes; and resource consumption. Life cycle considerations have been incorporated into the procedures as appropriate Compliance Obligations SJE operates within the boundaries of the City of Saint John, within the Province of New Brunswick. The EMS therefore addresses the applicable municipal, provincial and federal environmental legislation. Legislative update sources for SJE are the monthly Royal Gazette and the monthly Workplace Environment, Health & Safety Reporter from Templegate and relevant government websites. The HSE Coordinator communicates regulatory changes to affected employees by Planning Action SJE utilizes the following business processes to address its compliance obligations based on its risk and opportunities and significant environmental aspects: Compliance Obligation Process 1. Compliance obligations outlined in Section are reviewed to identify sections applicable to SJE activities. 2. Employees whose duties are impacted by compliance obligations are trained as per procedure every 3 years or when major changes to legislation occur. 3. Unforeseen incidents that result in a non-compliance must be mitigated immediately to bring the situation into compliance. Regulatory agencies must be advised of the non-compliance as per the applicable legislation. 6.2 Environmental Objectives and Planning to Achieve Them Environmental Objectives The environmental objectives are derived from the requirements of the Policy statement, the risks and opportunities (includes, significant environmental aspects (environmental aspects ranked as "high"), and CEA s Sustainable Electricity Program goals. The objectives tables in Appendix A are designed to provide specific action items which, when implemented, will result in each of the action items being reflected in the SJE s means of operation. Targets (action) show, where feasible, a measurable means of determining performance and thus the achievement of improvement. The Strategic Environmental Planning Package in Appendix A provides a summary of CEA s current program goals, strategic pillars and top priorities. Saint John Energy

17 Planning Actions to Achieve Environmental Objectives The environmental management program component of the EMS provides the framework for SJE and its employees to follow to achieve the objectives outlined in Section The environmental management programs or processes are subject to change as objectives are achieved and new ones are set. In addition to providing a road map for achievement of the objectives, the processes also identify line responsibility and assign accountability within SJE for the success of the EMS. To achieve some of the objectives, SJE considers the use of the best available technology or best available product/material (life cycle) approach where practical. The environmental objectives are reviewed periodically and revised to reflect changes in circumstances or recommendations from periodic audits of the EMS. This, in effect, provides the means by which continual improvement is achieved. SJE utilizes the following process to establish its environmental objectives: Establishing Objectives Process 1. SJE develops its objectives based on a review of its environmental policy, compliance obligations, significant environmental aspects financial and other constraints. 2. SJE commits to quarterly review of its objectives to determine performance of the EMS. 3. New or modified activities, operations, products and/or services to be utilized by SJE are reviewed prior to implementation to identify risks and opportunities and to ensure they are consistent with the current environmental policy, compliance obligations, existing objectives and environmental management programs. 4. New objectives and environmental management processes are developed, or existing ones modified, as required. Saint John Energy

18 Support 7.1 Resources The following types of resources are used by SJE to maintain and continually improve environmental performance: Financial resources o o An annual expense budget which allocates monetary funds to operate the organization. An annual capital budget which allocates monetary funds for larger financial investment. This includes expenditures planned through a capital review process for upgrades to pollution control devices, critical maintenance assets, or new equipment. Technological resources o o Pollution control devices installed, operated, and maintained to support regulatory compliance. Operational equipment and supplies to manage its environmental aspects. Human resources (e.g. specialized skills and knowledge); o Employees are assigned various roles and responsibilities to facilitate daily operational activities. These daily operational activities support the EMS efforts to be in compliance, prevent pollution, and continually improve upon identified opportunities. 7.2 Competence Successful implementation of the EMS requires that employees at all levels are made aware of the existence and purpose of the EMS and their role in the achievement of improved environmental performance. Employee training (as applicable to employee responsibilities at SJE) and competency as a result of this training will ensure that the goals of the environmental policy and objectives are achieved. Various types of training that are required to implement, review and improve the EMS include: training of senior management to increase awareness of the strategic importance of environmental management and environmental legislation within the industry and SJE; training of all employees to increase general environmental awareness regarding daily operations; specialty training to enhance the skills of all employees, particularly those whose responsibilities could impact the environment; and compliance training for those employees whose responsibilities could affect compliance. Saint John Energy

19 15 SJE utilizes the following process to train and ensure the competence of its employees: Employee Training and Competence Process 1. Training needs can be identified by Employees, Supervisors, Managers, the HSE Coordinator, Tools and Materials Committee, the JHSC and communicated to the Managers. 2. Training is provided using seminars, videos, awareness programs and/or workshops. 3. Training includes the consequences of not following environmental requirements. 4. The HSE Coordinator reviews the training needs with respect to requirements and produces an Annual Training Plan to be approved by the President and CEO. The HSE Coordinator monitors implementation. 5. Individuals receiving training provide confirmation of successful completion of the training to the HSE Coordinator. 6. Competency is determined through testing of individuals on their respective training subjects and takes one or more of the following forms: written, oral, practical or on-the-job observation. 7. Results of the testing are in written form and presented on an individual basis as pass/fail, percent correct or acceptable/unacceptable. 8. Results of testing are filed in the EMS-related filing system as per Section Awareness SJE utilizes the following process to promote awareness of the EMS and its function to all employees: 1. An information session to raise the awareness and general importance of environmental issues associated with activities and operations carried out at SJE particularly with respect to the importance of achieving and maintaining its registration under ISO Using newsletters, notice boards, s, etc. on a regular basis to report on the progress of the environmental objectives and performance with respect to continual improvement. 7.4 Communication General Communication across SJE at all levels of management and operations is essential to the success of the implementation of the EMS. SJE has both internal and external communication processes which address the results of the EMS monitoring. Senior Management has chosen to communicate environmental performance to the public through its Website, by opening its facility to the public and through its marketing and communications (e.g. Annual Report). Saint John Energy

20 Internal Communication SJE utilizes the following process for internal environmental communication: Internal Environmental Communication Process 1. Internal environmental issues and concerns must be written on the Proactive Risk & Opportunity Form and submitted to the Department Supervisor. 2. The supervisor submits the Proactive Forms to the HSE Coordinator for review and action. 3. Results of the review are relayed to the originator if the form has been signed. 4. The completed form, with date of action and action taken is filed as per the Document Control Process in Section The issue or concern raised on the form is added to the Proactive Risk & Opportunity Summary Log External Communication SJE utilizes the following process for external environmental communication: External Environmental Communication Process 1. External regulatory communications relating to environmental issues are managed by the HSE Coordinator with direction from the President and CEO. 2. All incoming and outgoing environmental communications must be signed-off by the Manager receiving the communication and the HSE Coordinator. 3. Environmental communications must be filed as per the Document Control Process in Section Environmental communications specific to a department or addressed to someone other than the HSE Coordinator must be handled per the addressee and then follow Steps 2 and 3 above. 5. The Proactive Forms are submitted to the HSE Coordinator for review and action. 6. Results of the review are relayed to the originator if the form has been signed. 7. The completed form, with date of action and action taken is filed as per the Document Control Process in Section The issue or concern raised on the form is added to the Proactive Risk & Opportunity Summary Log. 9. Media/public communications must be handled by the President and CEO or his alternate following consultation with the HSE Coordinator. 10. The results of the EMS audit are made available to the public annually by the HSE Coordinator. Saint John Energy

21 Documented Information General SJE has established and implemented an EMS Manual in paper and/or electronic format to: i) Describe the core elements of the management system and their interaction; and ii) Provide direction to related documentation (included in Appendix B) Creating and Updating SJE utilizes the following process to review the EMS Manual: EMS Manual Review Process 1. The EMS Manual is reviewed twice a year by the HSE Coordinator. 2. The EMS Manual is periodically reviewed by all SJE employees and used for information purposes as well as practical applications. 3. Employees initial the "sign-off" sheet at the front of their manual and return it to the HSE Coordinator for filing as per the Document Control Process in Section to confirm receipt. SJE utilizes the following process to create and revise environmental documentation: Environmental Documentation Creation and Revision Process 1. Requests for new EMS documentation or changes to existing documentation are submitted to the HSE Coordinator on the Proactive Form for review; 2. The HSE Coordinator reviews the requests and discusses with the appropriate manager(s) to determine if they will be adopted; 3. Revisions to existing documents are shown in red text; 4. Document revisions are indicated by a sequential revision number as well as the revision date. 5. The HSE Coordinator informs employees of new documents and revisions within one week of being prepared with directions for insertion into hard copies of the EMS Manuals; 6. Employees incorporate revisions to their manuals in a timely fashion following receipt of such from the HSE Coordinator to ensure it remains current; 7. Electronic documentation is deleted when a new revision is introduced. 8. Paper and electronic documentation no longer required is deleted or destroyed. Saint John Energy

22 Control of Documented Information Maintenance of the EMS and related environmental documentation as they pertain to the performance of the EMS provides tangible evidence of the success of the implementation of the system. SJE utilizes the following process to manage documented information in support of the EMS: Document Control and Maintenance Process 1. Each EMS Manual is numbered and the allocation recorded; 2. Page numbers and revision dates must be present on all pages of documentation; 3. Paper copies of documentation are legible, easily retrieved and protected against damage, deterioration or loss; 4. Electronic copies of documentation are available to employees in a read only format with editing control and authority only with the HSE Coordinator or their designate; 5. A central EMS Master Filing System for all environmental documentation is maintained by the HSE Coordinator. Examples of documentation in the filing system include, but are not limited to, the following: environmental test results; waste transportation manifests; certificates of destruction for hazardous waste; quarterly reports relating to environmental performance; annual summary reports on performance of the EMS; internal and external audit results; training documents, schedules and budgets; incident and accident reports (including field book summaries, hazard reports); internal/external correspondence pertaining to the EMS or environmental matters; department-specific documents (i.e. SDS information, daily building inspection reports); relevant legislation and industry standards/protocols and other applicable requirements; proactive environmental hazard reports; regulatory and other filings (SF6, epcb and CEA Sustainable Electricity Program SEP); comments/improvement suggestions received with respect to the EMS; instructions from the President and Board of Commissioners; and any other matters related to the performance of the EMS. Saint John Energy

23 19 3. Documentation in the EMS Master Filing System is catalogued and dated. 4. Documentation in the EMS Master Filing System must be kept for a minimum of two years then removed and placed in the designated storage cabinet for a minimum of six additional years as per the Compliance Document Retention Matrix; 5. Environmental test results must be kept eight years past the asset disposal date; and 6. Documents of external origin are controlled via either electronic format on the server network or in hard copy versions. Saint John Energy

24 Operation 8.1 Operational and Planning Control SJE develops the operational capabilities and systems to achieve the goals of the EMS through the implementation of the procedures derived from the environmental objectives. The Board of Commissioners reviews and adopts new and modified processes for subsequent implementation at SJE. Operational Control Process Examples Building, Substation Yard, Substation Maintenance, and Transformer Inspection Programs SJE has a process by which it monitors potential site impacts. These impacts could be a result of activities on neighboring properties impacting the SJE site or activities conducted by SJE impacting neighboring sites. This monitoring is done as part of the Building, Substation Yard, Substation Maintenance, and Transformer Inspection Programs (see inspection forms in Appendix B). Building inspections are conducted monthly by building maintenance employees. Substation yard inspections and transformer inspections are conducted yearly by substation maintenance employees and linemen respectively. Examples of processes in place at SJE are described below and other supporting operational procedures are provided in Appendix C. Global Harmonization System (GHS) Program The GHS program (formerly WHMIS) is a process used to identify and control hazardous materials in the workplace. The GHS Manual contains a master list of hazardous materials, material safety data sheets (SDS) on all identified hazardous materials and a temporary product trial section. The four manuals are placed in Engineering, Operations, Purchasing and Stores Departments and are reviewed yearly. Training is on a three year basis or as training evaluations dictate. Compliance audits are conducted yearly. Vehicle Inspection and Maintenance Program The Vehicle Inspection and Maintenance Program is a comprehensive process used to ensure vehicles are working in a safe and efficient manner. The program is through the Supply and Services Department and all maintenance is contracted out. Contracting-out/Tendering Process The Contracting-out/Tendering process is used by the Purchasing Department to ensure subcontractors are made aware of SJE's Environmental Policy and EMS Program requirements. Applicable contracts specify that the contractors work must comply with SJE policy and specified requirements including proof of training. The Purchasing Department currently uses a Contractor Responsibility for Safety and Environment Form and a Contractor Checklist-Evaluation Information Form in Appendix B as part of the contracting process which is renewed every year. Jobs are planned and tracked using the Job Folder Saint John Energy

25 21 Checklist in Appendix B. The checklist is used to open the job file, track and monitor progress and finally close the job. Herbicide/Pesticide Application Program This program is used by the Purchasing Department to control plant growth and pests within SJE s substations. It ensures applications are performed by a licensed contractor or licensed maintenance staff. Only over-the-counter herbicide and pesticide consumer products are used and all applications are logged. The Environmental Emergency Response Guide is used to address spills. Bird/Species at Risk Standard Operating Procedure (SOP) This SOP developed by SJE is used to ensure bird safety before filling in bird holes in poles and it is maintained in the SOP Manual. SJE will review operating practices on an on-going basis (e.g., emergency situations, hazardous material handling and storage) and develop additional procedures to address planned and unplanned operating conditions. 8.2 Emergency Preparedness and Response SJE has developed an Environmental Emergency Response Guide to control some of the key activities and operations that are associated with its environmental risks (i.e., PCB handling and spill response). The Environmental Emergency Response Guide distributed to all Operations employees and is the responsibility of the HSE Coordinator. SJE maintains emergency response capabilities to respond within the same reporting shift to any known emergency problem. SJE provides a full spectrum of emergency response services from immediate response and containment to subsequent investigations and final restoration. As part of these capabilities, SJE maintains an on-going relationship with a number of key service providers, including a number of: excavation contractors; oil pumping contractors; analytical laboratories; soil disposal facilities; and hazardous waste disposal facilities. SJE coordinates the activities of the service providers to ensure emergencies are properly addressed. SJE also maintains a relationship with the provincial regulators in New Brunswick. In many instances, where time is of the essence, SJE will work with the regulators to minimize the impact of a spill occurrence. Depending on the location, there are a number of agencies which may be contacted. These include the Saint John Energy

26 22 New Brunswick Department of Environment and Local Government, Federal Emergency Response, RMCP and local police, Fire Department, Provincial - Emergency Response Contacts, and Occupational Health and Safety Commission. SJE reviews its emergency response procedures on an annual basis or following an accident or emergency situation, to determine the continuing suitability of the plans. Revisions are made and documented as applicable. Procedures outlined for emergency response are tested periodically (mockdisasters) where practical to ensure success. SJE uses the following general process to outline activities involved in the event of an emergency response involving a spill. Emergency Spill Response Process 1. Immediately upon notification of a spill incident, SJE will mobilize the necessary resources to make an initial assessment of the situation. Based on information provided and the Environmental Emergency Response Guide, a response plan will be formulated accordingly. 2. Upon arrival at the site, SJE employees and contractors will stay upwind of the spill and assess the situation from a personal and public safety perspective. If in doubt, SJE employees and contractors will not go near the spill but will cordon off the scene and safely attempt to obtain emergency telephone numbers and identify the material spilled. 3. Once the work area has been determined safe to work, SJE employees and contractors will take all reasonable action to stop the spread of spilled materials by blocking drainage ditches and catch basins, digging trenches, creating dykes, and/or spreading an absorbent. Depending on the nature of the accident or spill, different regulatory agencies will be contacted as required. 4. SJE will coordinate the cleanup of spilled material in consultation with the regulatory agencies. This will include: assessment of the site conditions and environmental impacts; assessment of the potential for containment and collection; deployment of on-site personnel to contain and clean up spilled material if within their capability; call in spills response contractor if required; arrangement of disposal of contaminated material and cleaning materials; arrangement of confirmation of cleanup; preparation and distribution of a written report on the incident; and take necessary precautions to ensure that the incident does not occur again. Saint John Energy

27 Performance Evaluations 9.1 Monitoring, Measurement, Analysis and Evaluation General The intent of performance evaluation activity, described in the ISO model (see Figure 1), is to ensure that environmental performance is regularly monitored so that items requiring attention are identified and the appropriate corrective action is put in place. It is by this means that "continual improvement" is achieved in accordance with the ISO premise. Monitoring, measuring and analyzing SJE s environmental performance helps ensure that the environmental objectives and other performance indicators are being met. This enables SJE to: gauge environmental performance; identify areas where corrective action is needed; analyze causes of problems; and improve performance and increase efficiency. Calibration of environmental equipment ensures measurement accuracy and precision. Currently the calibration of equipment is contracted out. Chlor-N-Oil PCB oil field test kits come with instructions for use, are a one-time use kit and require no on site calibration. The SEP Program requires SJE to monitor and report yearly on eleven environmental indicators following the SEP Reporting Guidelines. The reported information is be audited by the CEA currently on a four year cycle. Managers are to ensure that targets (actions) set by the SEP Program through objectives (see Appendix A) are being met by their departments. The following is a description of the monitoring and measurement process for assessing environmental performance: Monitoring and Measurement Process 1. SJE monitors its activities in the following areas: energy distribution, field work, fleet vehicles, building maintenance, purchasing and administration. 2. SJE monitors and measures the following environmental indicators as required under the SEP Program as a member of CEA: internal energy efficiency, reuse of electrical insulating oil, spills, PCB management, public reporting of environmental performance, response to external input concerning environmental performance and evidence of an effective employee awareness and training program. Saint John Energy

28 24 3. SJE gauges its environmental performance by benchmarking its environmental indicator performance to CEA's most current Utility SEP Summary Report. 4. SJE measures the above-mentioned items as detailed in the CEA Guidelines for the SEP Utility Progress Reports. 5. SJE monitors its compliance obligations as listed in the Compliance Register in Appendix A. SJE prepares and issues required annual government and agency compliance monitoring and measurement reports as follows: a. CEA SEP Report due by April 23; b. Federal HWIN Hazardous Waste Generation/Disposal Registration Report due between Jan 1 and Feb 15; c. Provincial Watercourse and Wetland Permit renewal every 5 years (expires January 31, 2022); d. Provincial PCB storage report due by June 10; and e. Federal online PCB e-registration due by March 31. Compliance and other EMS related activities are summarized in the Recurrent Task List in Appendix D Evaluation of Compliance SJE utilizes the following process for evaluating compliance with applicable environmental requirements: Compliance Evaluation Process 1. Internal EMS audits are conducted quarterly. 2. Environmental compliance audits are conducted every three years or when changes occur. 3. Internal compliance audits are recorded using the Audit Checklist, Summary Report Form, Crane Mountain Compliance Checklist and PCB Compliance Checklist in Appendix B. A number of other legislation specific checklists are also used internally. 9.2 Internal Audit General Internal EMS audits are conducted on random activities by the JHSC on a quarterly basis. External audits are conducted every two years by a certified external environmental auditor appointed by the Board of Commissioners. Activities audited for either internal or external audits will be based on the environmental significance of the particular activity and previous audit performance. The audit process determines the conformity of the EMS to the systems described in the manual (proper implementation and maintenance) and to the ISO standard. This provides management with Saint John Energy

29 25 information on the success of the implementation of the EMS. SJE utilizes the following process for conducting internal EMS Audits: Internal Environmental Audit Process 1. Portions of the EMS are audited quarterly internal auditors (JHSC members). If non-conformances are found, then the particular area is audited at an increased frequency, determined by the HSE Coordinator in consultation with the JHSC, until performance improves. 2. Internal auditors receive formal training in the ISO standards and auditing procedures from a qualified person or organization. 3. The schedule of items to be audited is presented by the HSE Coordinator to the President and CEO a minimum of once per year for approval. 4. Monthly JHSC meetings are held to address which areas are to be audited, when the audit will occur, who will audit each area and what the auditors will be looking for. This information is documented in the meeting minutes. 5. The JHSC has developed Audit Checklists for auditing each different area of the EMS. A sample of the forms is included in Appendix C. The audits cover policies, procedures, legislation, instructions and evidence of implementation of the EMS. 6. The JHSC notifies the Department Supervisors of the audit date and areas being audited. Department Supervisors indicate the contact person(s), as applicable, representing each area to be audited. 7. During the audit, the Audit Checklist is used to ask questions and record compliance/noncompliance and objective evidence supporting this conclusion. 8. If a non-conformance is found, other similar examples should be investigated to determine if the non-conformance is evidence of a single occurrence or of a systemic problem. 9. After completing the audit, the JHSC member documents non-conformances as Corrective Action Requests or as Observation Notes, as outlined in the Non-conformance and Corrective Action Process in Section A post audit meeting is held with the Department Supervisor to review results and answer any questions. 11. The JHSC member prepares an Internal Audit Summary Report for the HSE Coordinator. The Summary Report identifies the components of the EMS audited and the results. 12. The HSE Coordinator summarizes and reviews the results of internal audits at the next Executive Meeting. 13. Copies of the Internal Audit Summary report and associated documents are filed in the EMS Master Filing System. 14. The HSE Coordinator ensures the Corrective Action Requests are followed up in accordance with Non-conformance and Corrective Action Process in Section Saint John Energy

30 Management Review The Board of Commissioners will review the performance of the EMS on a regular basis (at least once every six months) to ensure its continued suitability, adequacy and effectiveness. On the basis of these reviews, improvements and refinements of the EMS will be authorized, thus providing for the continual improvement of the system as specified in ISO Management Review Process 1. The results of the internal audits and ongoing environmental summary reports will be consolidated by the HSE Coordinator for submission to the Management Team and to the Board of Commissioners at least once every six months. The review process will include the following inputs: a) The status of actions from previous management reviews; b) Changes in: 1) external and internal issues that are relevant to the EMS; 2) the needs and expectations of interested parties, including compliance obligations; 3) the significant environmental aspects; 4) risks and opportunities. c) The extent to which environmental objectives have been achieved; d) Information on the facility s environmental performance, including trends in: 1) nonconformities and corrective actions; 2) monitoring and measurement results; 3) fulfillment of it compliance obligations; 4) audit results. e) Adequacy of resources; f) Relevant communications from interested parties, including complaints; g) Opportunities for continual improvement. 2. The results of the Board of Commissioners review will be documented in the meeting minutes and circulated to members of the Board and the HSE Coordinator. The Board's review will include the following two outputs: decisions and actions related to changes in environmental policy, objectives, other EMS elements and comment consistency with ongoing commitment to continual improvement. 3. All employees will be made aware of the Board's findings by the HSE Coordinator through methods outlined in the Internal Environmental Communication Process in Section Saint John Energy

31 Improvement 10.1 General Environmental performance across the organization is improved through analysis of monitoring and other data, evaluation of compliance, audit results and inspections to achieve its sustainability goals Nonconformity and Corrective Action SJE utilizes the following process to identify and investigate non-conformances, mitigate associated impacts and determine corrective and preventative actions. Non-conformance and Corrective Action Process 1. All health, safety and environmental concerns or other reported problems are to be recorded on a Proactive Risk & Opportunity Form available throughout the building and returned to a Supervisor. 2. The Supervisor forwards the form to a JHSC Member to verify the corrective action is completed then to the HSE Coordinator so the non-conformance and corrective action is logged and tracked. 3. The original Proactive Risk & Opportunity Form and completed reports are filed in the EMS Master Filing System. 4. Incidents of non-conformance are investigated to: identify the cause of the incident; identify and implement the necessary corrective action; identify controls necessary to avoid repetition; and record required changes to procedures. 5. Corrective actions are to be commensurate with the magnitude of the problem Continual Improvement SJE utilizes the following process to continually improve environmental performance associated with their operations: Continual Improvement Process 1. SJE audits the performance of the EMS utilizing the internal and external audit process. 2. Non-compliance issues are addressed utilizing the Non-conformance and Corrective Action Process described in Section Aspects are developed, evaluated and reviewed using the process as identified in the Aspects Identification Process described in Section Saint John Energy

32 Saint John Energy 28

33 A - 1 Appendix A Aspects, Objectives, and Compliance Tables Saint John Energy

34 Saint John Energy A - 2

35 Waste Management office/administration solid waste generation consumption of landfill Other # High biowaste/needles Hazardous waste landfill Other # Low Saint John Energy ISO EMS Manual Saint John Energy Environmental Aspects Analysis Table Activity / Product/ Service Environmental Aspects Potential Environmental Impacts Environmental Aspects associated with activity, products services, prevention of pollution, compliance, interested party concern Compliance Requirement (Ref to Section 6.1.3) Scale of Impact Severity of Impact Risk Evaluation of Impacts Significance of Impact Probability Duration of Impact Regulatory or Legal Difficulty to Change Cost to Change Impact Effect of Change on Other Concern of Interest Effect on Public Image product replacement product purchase hazardous waste generation use of non-sustainable products reduction of raw materials, consumption of landfill, contamination of soil, water reduction of raw materials, consumption of landfill, contamination of soil, water Legal #2b, #4d Other # High Legal #2b, #4d Other # High Air Emissions vehicles exhaust, fugitive dust ozone depletion, nuisance Legal #2b, #10e High painting and cleaning fumes nuisance (air quality, Legal #10e Low odour) HVAC malfunctioning system poor air quality Legal #10e Low Release to Water storm & surface potential discharge of Legal #2a, #2d, #4b water hazardous materials water contamination potential discharge of Legal #11a pesticide use hazardous materials water contamination potential discharge of Legal #2a, #2d, #4b chemical or fuel spills hazardous materials water contamination Resource Management operation of vehicles consumption of energy reduction of raw materials, Legal #2b & heavy equipment ozone depletion Office Building consumption of reduction of raw materials, Other # High High High Low June Revision 15

36 Saint John Energy ISO EMS Manual Saint John Energy Environmental Aspects Analysis Table Activity / Product/ Service Environmental Aspects Potential Environmental Impacts Environmental Aspects associated with activity, products services, prevention of pollution, compliance, interested party concern Compliance Requirement (Ref to Section 6.1.3) Scale of Impact Severity of Impact Risk Evaluation of Impacts Significance of Impact Probability Duration of Impact Regulatory or Legal Difficulty to Change Cost to Change Impact Effect of Change on Other Concern of Interest Effect on Public Image electricity consumption of natural resource SCADA/load consumption of consumption of natural management electricity resource Customer Electricity consumption of consumption of natural Consumption Energy electricity resource Efficiency Hazardous Materials use of PCB containing potential discharge of water, soil, human, animal materials hazardous materials contamination use of mercury, potential discharge of water, soil, human, animal containing materials hazardous materials contamination Land Management contaminated/ potential discharge of potentially hazardous materials, contaminated sites decommissioning sites water, soil contamination substations noise and visibility noise pollution and (aesthetics) aesthetics High Other # Low Other # High Legal #2a, #2c, #2d, #5, #14a Other #15, # High Legal #2a. #2d, High Legal ##2a, #2c, #2d, #3a, #4a Other #19 Legal #10e Low flora & fauna sensitive area damage Legal #7a, #12a, #13a, Low pole placement Sensitive area Water contamination Legal #5a-b Low Note: Each issue in the "Risk Evaluation of Impact" is scored from 0 to 3 points, for a total possible score of 30. Aspects are then ranked low (0-15) and high (16-30) significance, based on the total risk. 27-High June Revision 15

37 Environmental Vision Strategic 2018 Environmental Planning Package Including CEA s Sustainable Electricity Program Framework November 11, 2016 Revision 1 The Power Commission of the City of Saint John considers that the environmental performance of its system is as important to its customers as the quality of the service which they receive. Program goals Integrate Sustainability Integrate and embed sustainability within SJE s operations and business model Continuous Improvement Continuously improve environmental, social, and economic performance to meet our collective vision through innovative solutions, management approaches, and best practices Public Acceptance and Support for Utility Operations Advance the public acceptance and support for utility operations through meaningful engagement, collaboration, transparency, and accountability Program Strategic Pillars and Focus Areas Low-Carbon Future Focus: Climate change management Infrastructure Renewal and Modernization Focus: Infrastructure renewal, modernization and reliability Building Relationships Focus: Community and stakeholder engagement Risk Management Systems Focus: Environmental stewardship, health and safety, and security management systems Business Innovation Focus: Innovation, changing business models, human resources Top Priority Issues by Pillar Climate change mitigation Investments in new and refurbished infrastructure Early engagement and consultation of local communities and stakeholders Environmental risk avoidance and mitigation, including climate adaptation Investments in innovation culture and technology advancement Internal energy efficiency and customer conservation programs (retail) Integration of renewable energy, including energy storage Early engagement and consultation of all stakeholders Protection of employee, contractor, and public health and safety Engagement of regulators, supply chain partners and other stakeholders Electrification of transportation and contributing to the overall Canadian GHG reductions System reliability and resiliency against severe weather impacts Enhancing customer experience, lowincome customer programs, and meeting customer expectations Use of standards to reduce enterprise risks, including cyber security threats Employee recruitment, training, and retention

38 2018 Objectives and Targets from the Policy Statement Area of Responsibility Objective Target (Action) KPIs Policy Commitments Achieve policy goals. President & CEO will review all planned activities identified in the Board-approved 2018 budget/plan to ensure they are consistent with goals of the environmental policy. By February 15, 2018 Regulatory Compliance Endeavour to meet or exceed all regulatory requirements for activities associated with SJE. Manager Compliance, Regulatory and Commercial Affairs will conduct a compliance review of municipal, provincial, and federal environmental legal and other requirements. By September 1, 2018 ISO Compatibility Maintain an EMS compatible with ISO standard. HSE Coordinator will review the EMS Manual and make any required updates. By September 15, 2018 Canadian Electricity Association (CEA) Meet requirements of CEA's Sustainable Electricity Program (SEP). VP Engineering & Operations will verify that SJE is in compliance through environmental benchmarks. By March 15, 2018 Pollution Prevention Continue to develop pollution prevention / environmental improvement plans. Manager of Engineering will update the Environmental Damage Response Guide including the Oil Spill Procedure. By June 15, 2018 Continual Improvement Determine ongoing performance of EMS. JHSC will conduct four quarterly internal environmental audits prior to the last day of each quarter. By December 31, 2018

39 Environmental Aspects Climate Change - Mitigation and Adaptation 2018 Objectives and Targets from the Environmental Aspects Objectives Targets (Action) KPI Pillar: Low Carbon Future Mitigate greenhouse gas emissions from facilities and operations, and adapt to the adverse effects of climate change on electricity infrastructure. VP Finance and Administration to ensure the continued reduction of the utility s carbon footprint through the continued implementation of the Heat Pump Rental Program Units in 2018 Energy Management Pillar: business Innovation Investment in advanced technology and addressing changing business models. VP Engineering and Operations to initiate a Solar Pilot R & D Project. June 15, 2018 Environmental Stewardship (Hazardous waste generation / handling / accidental discharge.) Pillar: Risk Management Manage facilities and operations through a riskbased approach that avoids or minimizes impacts on the environment and supports ecosystem protection and conservation of biological diversity. Manager Shared Services to implement and track an ewaste Program for electronic devices in order to divert the hazardous components from landfill. March 15, 2018 Sustainable Business Model Pillar: Business Innovation Investment in advanced technology and addressing changing business models. President & CEO to pursue a new business model to better meet forecasted industry technology changes. May 15, 2018 Page 5

40 2018 Objectives and Targets from the Environmental Aspects Environmental Aspects Environmental Management System and Standard Objectives Targets (Action) KPI Pillar: Risk Management Manage facilities and operations through a riskbased approach that avoids or minimizes impacts on the environment HSE Coordinator will ensure all employees are educated on the newly revised ISO 14001:2015 EMS. By February 15, 2018 Stakeholders Pillar: Building Relationships Provide environmental benefits to shareholders, communities, and regions in which the company operates. VP Engineering and Operations to investigate the feasibility of integrating utility owned renewables into the distribution system. By May 15, 2018 Aging Infrastructure Pillar: Infrastructure Renewal and Modernization Invest in the renewal and modernization of generation, transmission, and distribution systems to meet the current and future energy needs of customers in a safe, reliable, and costeffective manner. Manager Grid Modernization to develop a long term grid modernization plan. By March 31, 2018 (Including office building resource management) Manage an energy efficient modern office building. Manager Shared Services to Investigate updating lighting to LED. June 15, 2018 Page 6

41 Saint John Energy ISO EMS Manual Compliance Requirements Canada-Federal Canada Wildlife Act, RSC 1985, c W-9 (no regulations) Canadian Environmental Protection Act, 1999, SC 1999, c 33 Environmental Emergency Regulation SOR/ Ozone - Depleting Substances Regulation, 1998, SOR/99-7 PCB Regulation SOR/ Release and Environmental Emergency Notification Regulation SOR/ Transportation of Dangerous Goods Act, 1992, SC 1992, c 34 TDG Reg, SOR/ TDG Reg, SOR/ National Fire Code of Canada (2015) New Brunswick-Provincial Clean Environment Act, RSNB, 1973, c C-6 Environmental Impact Assessment Regulation, NB Reg Petroleum Product Storage and Handling Regulations, NB Reg Used Oil Regulation, NB Reg Water Quality Regulation, NB Reg Clean Water Act, SNB 1989, c C-6.1 Watercourse and Wetland Alteration Regulation, NB Reg Watershed Protected Area Designation Order, NB Reg Electricity Act, SNB 2013, c 7 Electricity from Renewable Resources, NB Reg Endangered Species Act, SNB 1996, c E Endangered Species Regulation, NB Reg Municipalities Act, RSNB 1973, c M-22 New Brunswick Building Code Act, SNB 2009, c N-3.5 Occupational Health and Safety Act, SNB 1983, c O-0.2 Administration Regulation, NB Reg Code of Practice for Working Alone Regulation, NB Reg Code of Practice for Working with Material Containing Asbestos Regulation, NB Reg October Revision 10

42 Saint John Energy ISO EMS Manual First Aid Regulation, NB Reg General Regulation, NB Reg Training and Designated Trades Regulation, NB Reg Workplace Hazardous Materials Information System Regulation NB Reg Pesticide Control Act, RSNB 2011, c 203 General Regulation (Pesticide), NB Reg Protected Natural Areas Act, SNB 2003, c P Establishment of Protected Natural Areas Regulation, NB Reg Species at Risk, SNB 2012, c 6 List of Species at Risk Regulation, NB Reg Transportation of Dangerous Goods Act, RSNB 2011, c 232 General Regulation (TDG), NB Reg Saint John - Municipal Zoning By-Law Building By-Law Emergency Measures By-Law Evacuation of Streets By-Law Fire Protection By-Law Noise By-Law Other Requirements Other requirements include the following: CEA Sustainable Electricity Program (SEP) -refer to Procedure Fire Code-inspections by Saint John Fire Department Insurance Requirements-inspection by BI&I for Frank Cowan Insurance Crane Mountain Landfill Requirements-refer to Procedure Certificate of Authorization for PCB Storage and Handling-inspection by NBDELG Temporary Environmental Permits for Term Projects-inspections by NBDELG October Revision 10

43

44 B - 1 Appendix B Supporting Documentation Saint John Energy

45 Saint John Energy B - 2

46 Saint John Energy ISO EMS Manual The following is a list of supporting documentation located in the EMS Master Filing System in the Engineering Department of Saint John Energy. 1 Regulatory Requirements -summary document and legal documents 2 ECR Program and Reports -guideline and reporting documentation 3 3R-Monitored and Measured -supporting documentation 4 PCB Removal and Disposal Programs -supporting documentation 5 Emergency Response Guide -document and supporting documentation of review 6 Hazardous Waste Forms -document 7 Completed Hazardous Waste Forms -supporting documentation 8 PCB Storage and Reporting Requirements -document and documentation of approval 9 PCB Storage Log (office copy) -document 10 Correspondence -supporting documentation of internal and external communications 11 Oil Decontamination -documents 12 PCB Working Guides -documents 13 PCB Field Tests -Chlor-n-oil and L2000 test results 14 PCB Lab Tests -laboratory test results 15 Commission Monthly Environment Summary Reports -supporting documentation 16 Landfill Requirements -document and supporting documentation 17 Environmental Damage / Spill Reports -supporting documentation 18 ISO Gap Analysis -documents 19 ISO Standards -documents 20 ISO Registration -documents and supporting documentation 21 Environmental Budget and Management Plan -documents and supporting documentation 22 PCB/Oil Field Maintenance Process -documents 23 Internal and External Audits -supporting documentation 24 Environmental Policies -documents 25 Training -supporting documentation 26 ISO EMS Manual and Progress Reports -document and supporting documentation 27 Environmental Contractors/Consultants/Resources -supporting documentation 28 Proactive Risk & Opportunity Form (previously called Proactive Hazard Form) -document and supporting documentation March Revision 3

47 Saint John Energy ISO EMS Manual The following is a partial list of forms that will be used as part of the EMS: Daily Work Report..May 2002 Revision 2 Daily Maintenance Work Report December 2000 Revision 1 Daily Interior & Exterior Checklist.April 2006 Revision 2 Workplace Inspection Recording Form..December 2000 Revision 1 Material Evaluation Form..June 2007 Revision 2 Material Evaluation Checklist.December 2000 Revision 1 Safety and Environment Hazard Report.July 2000 Revision 1 Observation Report (Auditing)...April 2000 Revision 1 Proactive Hazard Report (Non Conformance Auditing)...January 2015 Revision 4 Audit Checklist (Auditing)..April 2000 Revision 1 Summary Report Short Form (Auditing).March 2004 Revision 1 Summary Report Form (Auditing)..January 2017 Revision 2 Crane Mountain Compliance Checklist (Auditing).December 2000 Revision 1 PCB Storage Compliance Checklist (Auditing)..December 2000 Revision 1 Job Folder Checklist February 2003 Revision 1 Contractor Evaluation Checklist.April 2007 Revision 3 March Revision 11

48 Saint John Energy ISO EMS Manual DAILY WORK REPORT NAME: DATE: PRINCIPLE TRUCK # DEPARTMENT APPROVALS OPERATIONS. ENGINEERING. JOB COSTING. JOB NO. AND WORK DESCRIPTION MAN TRK QUAN. CODE ACCOUNT DESCRIPTION HRS. HRS. NO. May Revision 2

49 ISO EMS Manual DAILY MAINTENANCE WORK REPORT NAME: DATE: JOB NO. OR WORK DESCRIPTION MAN HOURS MATERIALS REQUIRED APPROVED BY: December Revision 1

50 Saint John Energy ISO Implementation Manual DATE: DAILY INTERIOR & EXTERIOR CHECK LIST (GUIDELINE) INSPECTED BY: OK REQUIRES ACTION 1. Check parking lots and driveways for Weeds, debris, leaves, snow, glass, paper etc. and that fences are in good repair - Lot off Queen Street - Back lot off Charlotte Street (Employee s entrance) - Stores area lot 2. Check entrances, exits and front sidewalk. Must be free of dirt, debris, snow and ice. - Front customer entrance - Side exit - Employee s entrance - All overhead doors and man doors - Refuse containers and butt cans 3. Check outdoor lights. 4. Interior-work area, floors and walls. - Protrusion of any kind - Cracks or holes - Spills-oil, water and grease - Tires - Hydraulic fluid pan and drum 5. Check interior lights. 6. Check recycle bottle container in 2 nd floor lunchroom. 7. Check penthouse. - Equipment (condenser, cooling tower, etc.) - Structure, pipes, trays, etc. 8. Other: April 2006 Revision 2

51 ISO EMS Manual WORKPLACE INSPECTION RECORDING FORM ITEM, LOCATION AND DESCRIPTION REPEAT ITEM YES NO RECOMMENDED ACTION ACTION TAKEN DATE DATE: December Revision 1