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.

1. Environmental Program
Strategy Summary
BY JOEL HEBDON, PRINCIPAL
VANILLA STRATEGIES

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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