Keyport's facility covers 243 acres, employs 1,500 staff, and hosts 600 contractors. The major activities at Keyport include a variety of engineering and industrial processes such as electro-mechanical teardown, cleaning, machining, plating, painting, reassembling, and testing services. Keyport provides systems support and fleet material support for deployed systems. Also supporting Keyport's mission are the underwater range sites and detachments; located in Washington, California, Hawaii, Nevada, and Canada.

Environmental Policy of the Naval Undersea Warfare Center Division, Keyport Conducting business in an environmentally responsible manner by integrating pollution prevention and resource conservation into our vision, mission, and core values. Ensuring our processes are in compliance with DoD, Navy, Federal, State, and local laws/regulations. Continually improving our workplace to reduce environmental risk and committing the resources necessary to achieve environmental compliance. Developing environmental procedures and goals based upon significant environmental aspects and objectives. These aspects, objectives, and goals shall be communicated throughout the organization to enable their use as guidance for planning and operations. Supporting environmental stewardship and improvement as an integral part of our mission through teamwork, commitment, and awareness.

Keyport made a strategic decision to implement its EMS program and this decision is reinforced by Executive Order 13148 (Greening the Government Through Leadership in Environmental Management). Keyport's goal of improving environmental performance and the focus on merging environmental efforts into the "business" of Keyport's operations also served as a driver to EMS implementation. The ISO 14000 EMS complements the ISO 9000 QMS and finally, implementing an EMS program serves to underscore Keyport's commitment to enhancing and improving its relationships with members of the surrounding community, the regulatory community, and the various stakeholder groups at Keyport.

Keyport is implementing its ISO14000 registered EMS in three phases. Phase 1 involves Keyport's processes within the fenceline. Phase 2 extends to their Bangor annex and Dabob in-water test range. Phase 3 expands to the detachments. For Phase 1, the property fenceline is the physical fenceline including all Keyport processes therein. Keyport chose the fenceline for phase 1 because it is a recognizable, long-standing, physical line, and serves to define an area where most of the environmental functions reside and are within Keyport's direct control. At the other locations (Phase 2 & 3), environmental functions reside mostly with the host and will vary from activity to activity. For additional information, review Keyport's ISO14000/EMS slide presentation.

Keyport management supported the EMS activities from the beginning of the process. The Board of Directors serves as the upper management review team and they receive briefings at least twice a year. These briefings serve to maintain the connection to the EMS program. During the EMS reviews, the Board receives updates and information on the following elements:

1. Results from audits,
2. Progress on objectives and targets,
3. Concerns from interested parties (usually regulators or public), and
4. Suitability of the EMS.

As a result of Keyport's entire Board of Directors, serving as the upper management review team, any minor change of staff should not have a severe negative affect on the EMS process.

Keyport implemented Phase 1 in approximately 18 months and are adding phase 2 and 3 at one-year intervals so total implementation time should be 3 ½ to 4 years. Phase 1 was the most intensive as it involved considerable training and facility staff education. Phase 1 required approximately four in-house workyears plus the contractor dollars spent on EMS registration. Phase 2, 3, and the outyears will scale back to approximately 2 workyears in-house plus any necessary contractor registration/surveillance costs. Keyport's EQA effort has been rolled into its EMS program.

In developing the EMS, one of Keyport's initial steps was to develop the environmental aspects. All Keyport processes within the fenceline were considered in the development of a unique and meticulous rating/ranking matrix. The matrix is used to determine the environmental aspects of all processes within scope. The top 20% of which become Keyport's significant aspects. Station processes were examined for aspects based upon influencing factors (releases, energy usage, hazardous material usage, hazardous waste generation, compliance status, human health, and frequency of occurrence) and are assigned a weighted numerical ranking. These aspects are used in setting environmental targets as well as influencing audit schedules.

Keyport's currently is targeting four areas (Strategic, Compliance, Pollution Prevention, and Outside Concerns). Examples include:

1. Strategic - Environmental documentation supporting MILCON projects.
2. Compliance - Environmental projects to fix larger compliance problems identified by internal/external audits, media managers, or changing regulations.
3. Pollution Prevention - P2 projects identified by the P2 program, process owner suggestions, or ideas transferred from other activities.
4. Outside Concerns - Areas identified by outside parties (such as the regulators or the public) which should have attention.

Keyport obtained initial formal training for the implementation team and the lead auditors. Keyport developed presentations to introduce the EMS process to upper management and All-Hands and also used department environmental contacts to train staff. Informational awareness pamphlets, reference guides, emails, and news articles were developed for all-hands. Shop/Site visits were used extensively to reinforce training and to raise awareness.

Keyport also developed EMS information and guidance for its contractors. The Environmental Guide for Contractors provides environmental information for contractors working at the facility. The guide provides information, in detail, necessary to comply with key environmental regulations. The guide helps contractors develop and maintain an efficient and effective environmental plan. Keyport also specifies that contractors remain in compliance with all applicable Federal, state, local, and Keyport environmental requirements and that compliance is mandatory.

The metrics used by Keyport are unique and related to the facility's aspect measurement system.

Keyport reports that intangible savings have been recognized and while costs have increased slightly overall, the environmental risk posture is now measurable (and risks are reducing) and awareness has risen significantly.

Finally, Keyport notes that the most significant challenge was the initial standing up of the system in such a tight timeframe. However, Keyport experienced many successes in developing and implementing the EMS program.

For example, one of Keyport's successes was the development of a series of directives outlining environmental responsibilities. Environmental management systems documentation was developed for elements of the EMS process. The following presents the scope and purpose of key system documents. The summaries provide a link to the full document.

Environmental Management System Documentation

Scope: This document identifies the requirements and responsibilities for the environmental management process within the fenceline of NUWC Division Keyport. Excluded from coverage are regional and independent contractor assets.
Purpose: The purpose of this document is to establish guidance and responsibilities for an environmental management system meeting the requirements of ISO 14001:1996.

Environmental Aspect Definition

Scope: This document identifies the process and responsibilities for documenting and ranking environmental aspects.
Purpose: The purpose of this document is to establish guidance for the development and ranking of environmental aspects to determine the most significant aspects.

Environmental Objective and Target Definition

Scope:  This document identifies the process and responsibilities for documenting environmental objectives and targets.
Purpose:  The purpose of this document is to establish guidance for the development of environmental objectives and targets in support of Keyport's mission.

Environmental Operational Control Procedure

Scope: This document determines environmental considerations for Operational Control Procedures, provides environmental roles/responsibilities for all individuals within the scope of the Environmental Management System, and recommends training resources.
Purpose: The purpose of this document is to establish the environmental Operational Control Procedures.

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