Corporate Environmental Program Strategy Briefing
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Transcript of Corporate Environmental Program Strategy Briefing
Environmental Program Strategy Summary
BY JOEL HEBDON, PRINCIPAL
VANILLA STRATEGIES
What Does the Mission Look Like?
The organization is aligned to the primary mission R2A2s Lean, Flexible
Regulations and Permits define the requirements Basis of Policy Formulation, Oversight
Staff Understands and Works Within “Requirements” Framework
Roles and Responsibilities Understood Formal Authorities (NCO, Tech Representative)
Positional Interactions (Subject Matter Experts, Regulatory Program Managers)
Focus on Mission Accomplishment Aggressive Pursuit of Performance Goals
Consistent Application of Risk
Continuous Improvement Through Assessment and Planning Changes
Collaboration with Mission Elements (Projects) and Contractors Ensure Mutual Understanding of Procedural and Technical Requirements and
Goals
Focus on Getting Work Done Effectively, Efficiently
Institute Regulatory Assurance
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Vanilla Strategies, 2014
Environmental DivisionEnvironmental Division
1.21.2
Consent Agreements
1.2.1
RCRA
1.2.2
CERCLA
1.2.3
CAA
1.2.4
CWA
1.2.5
NEPA
1.2.6
CULTURALAND HISTORICRESOURCES
1.2.7
TSCA
1.2.8
PROGRAMMANAGEMENT
1.2.9
EPCRA
1.2.10
EQARD
1.2.11
RegulatoryComplianceAssurance
1.2.12
Work Breakdown Structure
Environmental Division
WBS and Schedule Additions Complete
Program Plan Complete
Responsibility for Environmental Management System Programs Defined
Pollution Prevention
Natural Resource Trustee Program
Radioactive Waste Management
Environmental Monitoring
RCRA/CERCLA/TSCA
CAA
CWA
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ENVIRONMENTAL SERVICES DIVISION (ESD)FUNCTIONAL TASK ASSIGNMENT CHART
ESD 1.2
Division Director
QA
• Regulatory Compliance Assurance (1.2.12)
Clean Air
• Clean Air Act (1.2.4)• Clean Water Act (1.2.5)• EPCRA (1.2.10)• Tier 2• NESHAPS (1.2.4)• Underground Storage Tanks• LDR
NEPA
• NEPA Compliance Officer (1.2.6)
RCRA
• RCRA (1.2.2)• TSCA (1.2.8)• Central Plateau Projects (N/A)• River Corridor Project• Office of River Protection
Cultural Resources
• Cultural and Historical Resources Program (1.2.7)
Rqmts Management
• Tri-Party Agreement (1.2.1)
Projects
• CERCLA (1.2.3)• River Corridor Projects (N/A)• Central Plateau Project
Itegration
• NEPA Succession Planning (1.2.6)
Enterprise Mgt
• Enviro. Mgmt. System (EMS)• Program Management (1.2.9)
TBD
• CERCLA (1.2.3)
TBD
• RCRA (1.2.2)
Strategy
• EQARD (1.2.11)• RIMS (1.2.9)• Strategic Planning (1.2.9)• Requirements Management (1.2.9/1.2.11)
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Vanilla Strategies, 2014
Strategy SummaryRCRA
Role Establish Site-Wide Compliance Positions Single POC for Regulators Ensure High-Quality, Consistent Documentation Ensure Procedural Compliance/Recommend
Certifications Lead for Negotiations and Enforcement Actions
Status: All RCRA Part B “Units” permitted
Issues: Disagreement Over XXX
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Vanilla Strategies, 2014
Strategy SummaryCERCLA
Role Set Site-Wide Policy in Consultation with Sr.
Managers Lead for Negotiation and Enforcement Actions Ensure Administrative Compliance
Status: Site-Wide Policy Integrated
Issues: EPA Staff Overly Prescriptive and Contentious State Attempts to Enforce CERCLA Applicability of Local Regulations Interim Actions vs “Protectiveness” vs Construction
Completions
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Vanilla Strategies, 2014
Strategy Summary Radioactive NESHAPS
Role Single Point-of-Contact Lead for Compliance Negotiations
Status: Exit Federal Facility Compliance Agreement in 18
Months Subpart H Compliance Agreement Letter in Place Nearly 300 NOCs Processed in FY 13
Issues: Permit-Based Billings Over-Regulation (< 0.1 mrem) Permits Issued for CERCLA Activities
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Vanilla Strategies, 2014
Strategy Summary Clean Air Act--Air Operating Permit
Role Single Point-of-Contact Lead Compliance Negotiations Integrate and Maintain Permit
Status: Origin of requirements still a question Permit issued (first of its kind)
Issues: State Coordination Over-Regulation (100% Oversight)
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Vanilla Strategies, 2014
Strategy Summary NEPA
Role NEPA Compliance Officer (NCO) Lead Reviews, Set Policy Recommend Approvals to Manager and HQ
Status: Expect Litigation on ??? Expect Litigation on ???
Issues: Succession Planning Coordination Dual Reporting for NCO
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Vanilla Strategies, 2014
Strategy Summary Clean Water Act Permits
Role Program Manager Coordinate Site-Wide Issues
Status: Individual Permits Delegated to Contractor
Issues: Quality Assurance Contractor Compliance
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Vanilla Strategies, 2014
Strategy Summary Environmental Management System
Role Required Implementation
Status: Contract Reqmts Doc. in Review w Contractors Program Plan in Place, Procedures in
Development
Issues: Project Ownership of Implementation Sr. Management Support Internal Reporting/Sr Management Briefings
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Vanilla Strategies, 2014
Strategy Summary Regulatory Compliance Assurance
Role Company Oversight RCRA/CERCLA/CAA/CR/CWA Arrange/Accompany/Report Regulatory Inspections Continuous Improvement Systems Oversight not Transactional Oversight Defined key processes and activities
Status: Program Plan in Place Procedures in Development
Issues: Environmental Quality Assurance (EPA QA/R5) Coordination With XXX
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Vanilla Strategies, 2014
Strategy Summary Regulatory Strategy and Planning
Role Integrate Regulatory Processes with Strategies, Business
Planning, and Contracts
Status Regulatory Strategy Complete (Requires Annual Revision) Regulatory Program Plans Complete
Issues No End Point for Cleanups
Integration of Strategic Policy w Strategic Implementation Plans
Groundwater Strategy Optimization Strategy Brownfields Strategy
Role of Workgroups in Formulating Strategy
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Vanilla Strategies, 2014