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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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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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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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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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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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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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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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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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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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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