Corporate Environmental Program Strategy Briefing

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Information about Corporate Environmental Program Strategy Briefing
Business & Mgmt

Published on February 6, 2014

Author: joelhebdon

Source: slideshare.net

Description

Corporate-level environmental strategy developed as a model for large facilities/large corporations with complex regulatory requirements. This tool has been used for briefing Top Management on four major DOE and Army projects whose contract values exceeded $$1.5B per year.

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   2 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 Vanilla Strategies, 2014

Work Breakdown Structure Environmental Division 1.2 RCRA TSCA 1.2.8 CERCLA CAA CWA NEPA 1.2.2 Consent Agreements 1.2.1 1.2.3 1.2.4 1.2.5 1.2.6 PROGRAM MANAGEMENT 1.2.9 EPCRA EQARD 1.2.10 1.2.11 Regulatory Compliance Assurance 1.2.12 CULTURAL AND HISTORIC RESOURCES 1.2.7

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 4

ENVIRONMENTAL SERVICES DIVISION (ESD) FUNCTIONAL TASK ASSIGNMENT CHART 5 ESD 1.2 Division Director QA • Regulatory Compliance Assurance (1.2.12) Cultural Resources • Cultural and Historical Resources Program (1.2.7) Enterprise Mgt • Enviro. Mgmt. System (EMS) • Program Management (1.2.9) 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 Rqmts Management Projects Itegration • Tri-Party Agreement (1.2.1) • CERCLA (1.2.3) • River Corridor Projects (N/A) • Central Plateau Project • NEPA Succession Planning (1.2.6) TBD TBD • CERCLA (1.2.3) • 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) Vanilla Strategies, 2014

Strategy Summary 6 RCRA  Role       Status:   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 All RCRA Part B “Units” permitted Issues:  Disagreement Over XXX Vanilla Strategies, 2014

Strategy Summary 7 CERCLA  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 Vanilla Strategies, 2014

Strategy Summary 8 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 Vanilla Strategies, 2014

Strategy Summary 9 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) Vanilla Strategies, 2014

Strategy Summary 10 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 Vanilla Strategies, 2014

Strategy Summary 11 Clean Water Act Permits  Role  Program Manager  Coordinate  Status:  Individual  Site-Wide Issues Permits Delegated to Contractor Issues:  Quality Assurance  Contractor Compliance Vanilla Strategies, 2014

Strategy Summary 12 Environmental Management System  Role  Required  Status:  Contract  Program  Implementation Reqmts Doc. in Review w Contractors Plan in Place, Procedures in Development Issues:  Project  Sr. Ownership of Implementation Management Support  Internal Reporting/Sr Management Briefings Vanilla Strategies, 2014

Strategy Summary 13 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 Vanilla Strategies, 2014

Strategy Summary 14 Regulatory Strategy and Planning  Role   Status    Integrate Regulatory Processes with Strategies, Business Planning, and Contracts Regulatory Strategy Complete (Requires Annual Revision) Regulatory Program Plans Complete Issues  No End Point for Cleanups  Integration of Strategic Policy w Strategic Implementation Plans   Optimization Strategy   Groundwater Strategy Brownfields Strategy Role of Workgroups in Formulating Strategy Vanilla Strategies, 2014

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