Finally! – A Process that Looks at Environmental Risk Early

J. S. IrvingEnvironmental ComplianceIdaho National Laboratory

1.1 Assign proposal project manager (PLM)

1.2 File Scope (PPM/PPI)

1.4 Notify Division Director and identify required reviewers

(PPM & PLM)*

1.5 Submit RA (proposal stage)

(PPM/PPI)

1.3 Conduct Preliminary Risk Assessment

(PPM/PPI)

1. Conducting Preliminary Risk

Assessment

1.6 Approve Scope & RA?

(proposal stage) (PLM)

Cond. Yes

Yes

Acceptable mitigation Plan?

(PLM)

Yes

Develop risk mitigation plan

(PPM/PPI & PLM)

No

2.1 Develop Proposal SOW

(PPM/PPI)

2. Proposal Development & Program Review

2.2 Initial review of SOW (PR,

CR, PLM)

2.4 Develop cost estimate

(PPM/PPI)**

2.3 Develop the schedule

(PPM/PPI)

Disapprove RMP (PLM)

3.1 Submit proposal for review

(PPM/PPI)

3.2a Optional IP & PR Reviews

3.5 Submit proposal to client

(BSS, CR)

3.4 Approve proposal and sign

PREPS (PLM)

3. Submittal and Approval of the Proposal

3.2b BSS, CR, BMI, PLM WFO

Reviews*

3.2c Reviewers concur with proposal?

No

Withdraw Proposal from PREPS (PPM)

3.3 Revise Proposal?

No

Yes

4.1 Negotiate contract (BSS, CR, PPM/PPI,

PLM)

4.4b Accept work authorization/

Receive Funding (BSS)

4.3 Review contract

authorization (BSS, PPM/PPI)

4. Contract Negotiation with Customer

4.2 Client awards work?

No

Yes

4.4a Acceptable contract?

No

Yes

5.1 Issue work authorization (CR,

Budget Office)

Review and approve RA (PLM)

Update PREPS to reflect negotiations &

final RA (PM/PI)

5. Project Work authorization

Prepare project management

planning (PM/PI)

5.2 PM/PI/PLM Accepts the Work

Authorization

Initiate work

Covered in Project Management System

BMI – Battelle CorporateBSS - Business Support ServicesCR - Contracts RepresentativeIM - Immediate ManagerPREPS - Proposal Risk Evaluation & Preparation SystemPLM - Program Line Manager (Division Directorate)PI – Principal InvestigatorPM - Project ManagerPPI – Proposal Principal InvestigatorPPM—Proposal Project ManagerRA - Risk / Mitigation AssessmentPMS - Project Management SystemPPS - Proposal Pricing SheetsPR - Peer ReviewerSOW—Statement of WorkWFO – Work for Others

Project Management System Area

PREPS Function

Proposals Subject Area

* BSS, PMS, PR, CR, PLM-specific, using graded approach** PPS, Client rqmts., etc.

Revise/update a PREPS

Yes

All Proposed INL Work

Responding to New Opportunity

Continue/Repeat Current Project

Pre-Proposal Data Entry

Request Approved?

Yes

No

2.5 Update RA as Necessary

(PPM/PPI)**

4.1a Consult w/Stakeholders on

negotiated changes/risks

(PPI/PPM/PLM)

Submit w/o PDF

2.6 Upload Proposal

Attachments/mitigation plan to

PREPS (PPM/PPI)

Requesting PDF

Funding?

No

Yes

No

LEGEND

To Proposal Tracking Database

To Proposal Tracking Database

Output

1.1 Assign proposal project manager (PLM)

1.2 File Scope (PPM/PPI)

1.4 Notify Division Director and identify required reviewers

(PPM & PLM)*

1.5 Submit RA (proposal stage)

(PPM/PPI)

1.3 Conduct Preliminary Risk Assessment

(PPM/PPI)

1. Conducting Preliminary Risk

Assessment

1.6 Approve Scope & RA?

(proposal stage) (PLM)

Cond. Yes

Yes

Acceptable mitigation Plan?

(PLM)

Yes

Develop risk mitigation plan

(PPM/PPI & PLM)

No

2.1 Develop Proposal SOW

(PPM/PPI)

2. Proposal Development & Program Review

2.2 Initial review of SOW (PR,

CR, PLM)

2.4 Develop cost estimate

(PPM/PPI)**

2.3 Develop the schedule

(PPM/PPI)

Disapprove RMP (PLM)

3.1 Submit proposal for review

(PPM/PPI)

3.2a Optional IP & PR Reviews

3.5 Submit proposal to client

(BSS, CR)

3.4 Approve proposal and sign

PREPS (PLM)

3. Submittal and Approval of the Proposal

3.2b BSS, CR, BMI, PLM WFO

Reviews*

3.2c Reviewers concur with proposal?

No

Withdraw Proposal from PREPS (PPM)

3.3 Revise Proposal?

No

Yes

4.1 Negotiate contract (BSS, CR, PPM/PPI,

PLM)

4.4b Accept work authorization/

Receive Funding (BSS)

4.3 Review contract

authorization (BSS, PPM/PPI)

4. Contract Negotiation with Customer

4.2 Client awards work?

No

Yes

4.4a Acceptable contract?

No

Yes

5.1 Issue work authorization (CR,

Budget Office)

Review and approve RA (PLM)

Update PREPS to reflect negotiations &

final RA (PM/PI)

5. Project Work authorization

Prepare project management

planning (PM/PI)

5.2 PM/PI/PLM Accepts the Work

Authorization

Initiate work

Covered in Project Management System

BMI – Battelle CorporateBSS - Business Support ServicesCR - Contracts RepresentativeIM - Immediate ManagerPREPS - Proposal Risk Evaluation & Preparation SystemPLM - Program Line Manager (Division Directorate)PI – Principal InvestigatorPM - Project ManagerPPI – Proposal Principal InvestigatorPPM—Proposal Project ManagerRA - Risk / Mitigation AssessmentPMS - Project Management SystemPPS - Proposal Pricing SheetsPR - Peer ReviewerSOW—Statement of WorkWFO – Work for Others

Project Management System Area

PREPS Function

Proposals Subject Area

* BSS, PMS, PR, CR, PLM-specific, using graded approach** PPS, Client rqmts., etc.

Revise/update a PREPS

Yes

All Proposed INL Work

Responding to New Opportunity

Continue/Repeat Current Project

Pre-Proposal Data Entry

Request Approved?

Yes

No

2.5 Update RA as Necessary

(PPM/PPI)**

4.1a Consult w/Stakeholders on

negotiated changes/risks

(PPI/PPM/PLM)

Submit w/o PDF

2.6 Upload Proposal

Attachments/mitigation plan to

PREPS (PPM/PPI)

Requesting PDF

Funding?

No

Yes

No

LEGEND

To Proposal Tracking Database

To Proposal Tracking Database

Output

Life Cycle of a Project

Idea

Proposal

RFP

BusinessRisk

ProjectMgmt.

Work Control

Closure

Env. Risk

Env. Risk

Env. Risk

Env. Risk

Env. Risk

INL’s New Approach

Proposal RiskEvaluation &

Preparation SystemPREPs

Work ManagementSystem

Project ManagementSystem

• Conduct Preliminary Risk Assessment (evaluates ESH, Legal, Business, Security, etc. Risk)

• Submit / Approve Project (Company & Program)

• Contract Negotiations (Business Office, Authorizes Funds)

• Project Work Authorization

• Determine Level of Project Management …

• Determine if activities is Maintenance, Sub Contract, Construction, R&D or Operation

• Prepare Project Execution Plans (PEP)

• Develop Cost / Schedule Office, Authorizes Funds)

• Develop Work Plan

• Determine Work & Environmental Hazards

• Identify Applicable Mitigation & Controls

• SME Review as Appropriate

• Authorize to Perform Work

• Environmental Questions …

– Will proposed work be performed in a location other than an office setting, where environmental hazards could be present or work control is required (e.g., experimental facility, nuclear facility, in the field)?

• Environmental Questions …

– Will proposed work be performed in a location other than an office setting, where environmental hazards could be present or work control is required (e.g., experimental facility, nuclear facility, in the field)?

PREPS

• Environmental Questions …

– Will proposed work be performed in a location other than an office setting, where environmental hazards could be present or work control is required (e.g., experimental facility, nuclear facility, in the field)?

• Does the work involve siting, constructing, modifying, or other changes to a building, support structure, or well?)

• Environmental Questions …

– Will proposed work be performed in a location other than an office setting, where environmental hazards could be present or work control is required (e.g., experimental facility, nuclear facility, in the field)?

• Does the work involve siting, constructing, modifying, or other changes to a building, support structure, or well?)

PREPS

• Environmental Questions …

– Will proposed work be performed in a location other than an office setting, where environmental hazards could be present or work control is required (e.g., experimental facility, nuclear facility, in the field)?

• Does the work involve siting, constructing, modifying, or other changes to a building, support structure, or well?)

– Will work involve siting, constructing, demolishing, closing, or abandoning a facility or structure?

• Environmental Questions …

– Will proposed work be performed in a location other than an office setting, where environmental hazards could be present or work control is required (e.g., experimental facility, nuclear facility, in the field)?

• Does the work involve siting, constructing, modifying, or other changes to a building, support structure, or well?)

– Will work involve siting, constructing, demolishing, closing, or abandoning a facility or structure?

PREPS -- Rational

Project personnel need to identify what level of environmental review an activity will require such as an environmental assessment (EA) or environmental impact study (EIS). Most of our activities will fall within categorical exclusions (CX) and not require the cost, time, and effort that an EA or EIS would take.

In addition, project personnel need to identify if an activity will require a notification or permit that may require resources and time to prepare and submit.

Activities involving emissions, effluents, and waste (industrial, hazardous, mixed, and radioactive) may require permits, notifications, or plans approved by federal and state. Those permits may involve a long-lead time to prepare, submit, and approve. Contact John Irving, Environmental Compliance, for assistance in determining the correct level of environmental review.

Project Management

• Prepare Project Execution Plans to identify …

– environmental deliverables, reports, and activities

– resources necessary to prepare environmental approvals, permits, reports, and documents

– controls necessary to executing work in compliance with environmental requirements

– performance measures to evaluate compliance with environmental requirements

– close out activities to help verify environmental requirements met

Work Control

• Hazard and Risk Planning System

– At the core of the Work Management system is a hazard ID and mitigation tool called HaRPS which is used by all entities at the INL for hazard and risk planning and mitigation at the work activity level.

HaRPSP

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Does the work involve …• Structures, building facilities, or processes?• Generating industrial, radioactive,

hazardous, or mixed waste or managing surplus property?

• Airborne environmental concerns?• Chemicals, fertilizers, or regulated

hazardous material?• Samples or sampling?• Potable water, waste water or storm

water systems?

Example of Primary Questions

HaRPSP

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Does the work involve …• Drinking water or potable water systems?• Septic tanks or systems or other

wastewater or sewage systems?• Storm water?• Wells?

Example of Secondary QuestionsPotable water, waste water or storm water systems?

HaRPSP

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Does the work involve …• Discharging, or changing existing or adding

new discharges of, wastewater to the City of Idaho Falls sewer system?

• Constructing or modifying sewage or other wastewater systems?

• Maintaining and repairing septic tanks or septic systems?

• Abandoning or closing septic tanks.

Example of Work ActivitiesSeptic tanks or systems or other wastewater

or sewage systems?

HaRPSP

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Instruction …• Before abandoning or closing the septic

tank, contact Environmental Support Personnel to determine if the septic tank is a CERCLA operable unit and if so, coordinate the activity with them.

Example of Control or MitigationAbandoning or closing septic tanks.

Life Cycle of a Project

Idea

Proposal

RFP

BusinessRisk

ProjectMgmt.

Work Control

Closure

Env. Risk

Env. Risk

Env. Risk

Env. Risk

Env. Risk

Env. Risk