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Methodology for Identifying
and Tracking Environmental Regulations for U.S.
Army Environmental Policy Institute (AEPI)
For the Army Environmental Policy Institute (AEPI),
ICF International developed a methodology to identify,
screen, analyze, and follow up on environmental
regulations and policies that may affect Army
operations. The methodology consisted of five
steps:
- identify potential federal regulatory and
policy initiatives (e.g., by reviewing EPA's
Regulatory Plan and Unified Agenda, and conducting
research on EPA policies)
- assess relevancy of the initiatives to the
Army, by identifying priority areas and data
needs and screening initiatives based on selected
criteria
- analyze potential impacts of relevant initiatives
on the Army and clarify the Army's current level
of involvement in the initiative
- design and implement tracking strategy to
continue to monitor and report on the regulatory
and policy initiatives
- provide follow-up support on regulatory and
policy initiatives
In addition to developing a report describing
the methodology in detail, ICF International then
carried out the proposed methodology to identify
any upcoming regulations or policies that might
affect the Army's chemical demilitarization program.
Environmental Activities Management
Handbook for NASA Headquarters
For NASA, ICF International developed the Environmental
Activities Management Handbook, which describes
the necessary steps and processes NASA environmental
managers must employ to manage successful remedial
activities under the Resource Conservation and
Recovery Act (RCRA) and the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA),
as well as other large, compliance-based environmental
activities. The Handbook is intended to assist
NASA managers in planning, budgeting, and managing
environmental activities, particularly remediation
efforts. It provides an overview of the principles
of facility planning and management, and then
outlines specific environmental remediation processes,
including regulatory requirements, and highlights
factors that affect the planning, scheduling,
and budgeting of each type of environmental activity.
It also discusses how each stage of the various
site remediation efforts relates to the annual
NASA budget cycle and identifies points in the
process where it may be appropriate for managers
to revisit the existing schedule and budget estimates
for those activities.
U.S. Army Reserve Facility
Manager's Environmental Handbook
For AEPI, ICF International developed a Handbook
to assist U.S. Army Reserve Facility Managers
in identifying major environmental problems that
can occur during normal operations at a Reserve
Center, and in complying with the appropriate
environmental regulations. The environmental program
areas addressed by the handbook include the National
Environmental Policy Act, management of hazardous
materials and wastes (e.g., under RCRA), keeping
water resources clean (e.g., under the Clean Water
Act), clean air issues, and other special considerations
(e.g., pesticides, waste oil, PCBs, noise, radon,
and lead paint). The handbook was intended for
non-environmental staff, and was designed to make
the managers aware of the laws and regulations
that can affect facility operations; the discussion
of each program area provides a map of a typical
reserve center and highlights the potential compliance
problem areas. The handbook also provides quick
references, frequently asked questions, lists
of contacts, and instructions on how to prepare
for an audit/inspection and what to do if a violation
is found.
Environmental Management Reference
Manual (EMRM) for NASA
ICF International recently prepared a guidance manual
that is written for the non-environmental manager
and executive, and provides key information that
will enable these individuals to contribute meaningfully
to the attainment of NASA's environmental goals
(e.g., through pollution prevention or green procurement).
The manual includes sections describing NASA's
environmental functions and their relationship
to the agency's overall mission, the genesis and
form of existing environmental law, the specific
aspects of environmental control regulations and
executive orders that affect NASA operations,
preparing for audits and inspections, and budgeting
for environmental costs.
U.S. Army Installation Safe
Drinking Water Compliance Analysis
For AEPI, ICF International conducted an analysis
of Army installation compliance with Safe Drinking
Water Act (SDWA) requirements. The purpose of
the analysis was threefold:
- to determine whether there are certain trends
in noncompliance at Army facilities, such as
relationship to type of installation, type of
water system, type of violation, and cause of
violation
- to assess the general reasons for noncompliance
in order to analyze the programmatic needs for
addressing these deficiencies
- to compare the different sources of data on
compliance and determine whether there are any
inconsistencies to be addressed from an environmental
management system perspective
To allow for comparison across the different
data sets, ICF International grouped the findings
under six general categories:
- source-water protection
- water treatment plant
- distribution system
- contaminant monitoring procedures
- monitoring-related administrative requirements
- system-wide administrative requirements
Each finding was categorized according to the
type of violation (e.g., administrative, equipment,
or operation) to allow for analysis of reasons
for noncompliance (e.g., insufficient training,
inadequate supervision, lack of standard operating
procedures, lack of budget for equipment repairs,
etc.). Finally, the findings were given characterization
codes to provide further information on the severity
of the violation (e.g., whether a few records
were missing or whether record keeping was never
conducted at all).
Emission Reduction Credits
Policy and Guidance Manual for AEPI
ICF International developed a policy manual on emissions-trading
programs for AEPI. This manual explained several
emissions-trading programs, including the emission-reduction
credit market, the open market trading program,
and allowance or permit programs. Provisions for
these programs are included under the Clean Air
regulations, especially the New Source Review
permitting program. Based on ICF International's
experience in the market, ICF International described
the emissions trading process, including the creation
and acquisition of credits, the certification
of credits, and the use and disposal of the credits.
To develop the manual, ICF International reviewed
the Army's policies as they relate to these issues
and explored other federal requirements and policies.
For example, ICF International investigated the General
Service Administration's and the military's policy
on acquiring and selling property rights. ICF International also considered Base Realignment and
Closure policies and procedures as well as policies
developed by other military branches. The policy
manual outlined major emissions trading issues
and recommended an emissions-trading policy for
the Army. After completion of the policy manual,
ICF International drafted a guidance manual explaining
the step-by-step procedures for participating
in emissions-trading markets.
Conformity Analyses for Virginia
Department of Transportation (VDOT)
Since 1994, ICF International has led a team of consultants
providing assistance to VDOT in all phases of
transportation conformity demonstrations for three
Metropolitan Planning Organizations (MPOs), as
required by the Clean Air Act Amendment and the
Intermodal Surface Transportation Efficiency Act
(ISTEA). For these assignments, ICF International
facilitated and participated in interagency consultation
to discuss numerous conformity issues such as
model inputs, allowable credits, transportation
plan schedules, and definition of transportation
projects. ICF International has been involved in
several rounds of travel-demand modeling, and
is responsible for developing the on-road emissions
inventory for the conformity analyses. ICF International
staff have analyzed the emissions benefits and
costs of several transportation control strategies
that would enable the MPOs to demonstrate conformity.
ICF International staff have provided training seminars
to state DOT and MPO staff on all steps involved
in the transportation conformity process.
Pollution Prevention Benefits
Manual for U.S. EPA
ICF International developed the Pollution Prevention
Benefits Manual (PPBM), which lays out a widely
accepted financial analysis approach and methodology
for the evaluation of environmental costs and
cost savings in capital budgeting. The PPBM encourages
its users to recognize and value the often hidden
and intangible environmental costs and benefits
that may be overlooked in conventional analyses.
The PPBM describes cost and financial worksheet-based
protocols for estimating the annualized cost savings,
net present value, and internal rate of return
of pollution prevention (P2) projects in comparison
to a company's current practices. The manual describes
the types of costs a firm may incur, identifying
four levels, or tiers, for the cost protocol:
usual costs, hidden regulatory costs, liability
costs, and less tangible costs. The PPBM stresses
the multimedia nature of P2, and includes tables
for estimating hidden costs associated with compliance
with hazardous waste, emergency planning and community
right-to-know, occupational health and safety,
and clean air and water regulations.
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U.S. Army Reserve Environmental
Regulatory Compliance Analysis
For AEPI, ICF International conducted an analysis
of trends in compliance with environmental regulations
at U.S. Army Reserve facilities. The purpose of
the analysis was to:
- determine under which regulatory protocols
the most incidents of non-compliance occurred
- identify the most common violations under
each regulatory program
- identify violations that could have immediate
and serious consequences to human health and
the environment
The data sources for this analysis were Environmental
Compliance Assessment System (ECAS) audits performed
from 1991 to 1997 under 17 regulatory protocols
covering all environmental statutes, including
the Clean Air Act, Clean Water Act (CWA), RCRA,
Toxic Substances Control Act, and Safe Drinking
Water Act. The audit data covered more than 500
Army Reserve installations in 46 states and included
more than 2,000 violations. Results of the analysis
indicated the environmental regulatory areas where
additional management attention would be appropriate
to ensure that Reserve facility operations do
not endanger human health and the environment.
Training Course on P2 for
Government Institutes
ICF International developed and presented a pollution
prevention (P2) training class for Government
Institutes, a private-sector organization. The
class included six modules:
- What is P2?
- P2 - Why it is Important
- Developing a Successful P2 Program
- Identifying and Implementing P2 Opportunities
- Keeping the Program Going: Preserving Momentum
- Evaluating Program Success and Progress
The course was presented to 45 managers and staff
from private-sector manufacturing companies and
government agencies (DoD and Department of Energy).
ICF International designed this class to be presented
to individuals with little or no previous exposure
to P2, and tailored the depth of the technical
content during the presentation to meet the expectations
of students already possessing an understanding
of basic P2 principles. ICF International received
high marks for presentation and course content.
Public Involvement Training
for Transportation Decision-making for National
Transit Institute
For the National Transit Institute, ICF International
managed the development and delivery of a training
course that teaches transportation project planners,
particularly at the MPO level, how to design and
implement effective public involvement programs
and how to integrate them into transportation
planning, programming, and project development.
ICF International staff have taught the course over
a dozen times in the past 15 months – from
Boston to Honolulu. The course has been among
the most highly rated of National Transit Institute
courses offered nationally.
Compliance Guidance and Inspection
Checklist for Clandestine Drug Laboratory Waste
Storage
For the Drug Enforcement Administration (DEA),
ICF International developed guidance for performing
inspections of facilities that store and dispose
of certain DEA-generated hazardous waste. In its
seizure of clandestine drug laboratories, DEA
may encounter subject to EPA's hazardous waste
regulations under the RCRA. Because DEA is responsible
for the hazardous waste it generates at the clandestine
drug laboratories, DEA recognized that it needed
to carry out periodic inspections of its contractor's
storage facilities to ensure that the DEA-generated
waste is being properly managed. ICF International
developed a detailed inspection checklist and
accompanying guidance document to be used by DEA
in conducting unannounced inspections of its contractors'
facilities to ensure that they are complying with
the appropriate environmental laws and regulations
(e.g., RCRA) as well as DEA regulations under
the Controlled Substances Act; OSHA regulations
on workplace safety; and DOT regulations under
the Hazardous Materials Transportation Act.
Guidance Materials for Worker
Protection at Hazardous Waste Sites
For EPA, ICF International developed guidance materials
to ensure compliance with worker protection standards
for hazardous waste operations and emergency response
(HAZWOPER). These materials were intended for
use by EPA Regional managers to ensure the safety
of their employees at sites where hazardous wastes
and materials are present. Specifically, ICF International
developed the "Standard Operating Safety Guides"
manual which provides guidance on development
of the health and safety program and the site-specific
health and safety plan (HASP), training for workers
and managers, site control, use of personal protective
equipment (PPE), air monitoring methods and equipment,
development of the medical surveillance program,
handling heat stress and cold exposure, carrying
out decontamination activities, handling drums,
and other safety considerations. ICF International
also developed standard operating guides (SOGs)
for use by field personnel to ensure compliance
with HAZWOPER standards for workers engaged in
cleanup of hazardous waste sites. Three specific
SOGs were developed to address procedures for:
- carrying out decontamination of personnel,
PPE, and equipment
- conducting initial site entry, including
air monitoring
- establishing work zones as part of site control
Toxics Release Inventory
(TRI) Reporting Calculations and Guidance for
Private Sector
ICF International assisted several plastic manufacturing
facilities in performing activities required to
comply with Emergency Planning and Community Right-to-Know
Act (EPCRA) Sections 312 and 313. ICF International
developed a release calculation method appropriate
for each site, and also calculated waste transfers,
waste water releases, and air emissions. ICF International
continually kept the client aware of changing
policies and interpretations of the requirements.
Also, when any new chemicals were added to the
list of pollutants, ICF International would develop
policy papers on how to determine the releases
and thresholds. In addition, ICF International prepared
numerous guidance documents and fact sheets for
the client. These documents include a brochure
designed to help the facilities understand the
data reported in the TRI and how to communicate
the data and chemical risks to the public; a data
quality checklist designed to help ensure the
facilities include all relevant information in
determining their section 313 reporting responsibility
and have documentation to validate their data;
fact sheets on various EPCRA reporting issues
specific to the facilities including PCBs, article
exemption, reporting on metals and metal compounds,
and continuous release reporting; and questions
and answers on EPCRA issues to use in obtaining
policy clarifications to ensure full compliance
with the reporting requirements and regulations.
These documents incorporated the extensive first-hand
knowledge that ICF International has gained through
working with the facilities. Where possible, knowledge
of systems and releases was transferred from site
to site.
Environment, Health, and
Safety Compliance Support for DOE
ICF International assisted several DOE facilities
in planning and conducting comprehensive self-assessments
of compliance with DOE orders and regulatory requirements.
In addition, ICF International provides on-going
training to personnel at Lawrence Livermore National
Laboratory on hazardous and low radioactive waste
management. ICF International also developed and
delivers a course across the DOE Complex on radioactive
waste management to support DOE's implementation
of its new Order 435.1, Radioactive Waste Management.
Hazardous Waste Compliance
Assistance for PADEP
ICF International is developing fact sheets, compliance
guides, and training courses to aid the PADEP
in achieving their program goals of reducing waste
toxicity and volume and assuring compliance with
hazardous waste regulations (that underwent major
revisions in 1999). To develop training courses
that would best meet the department's needs, ICF International interviewed headquarters and regional
department staff to identify the regulatory changes
that were proving most challenging and, thus,
warranted the most focus in the training. Through
this process ICF International determined that it
was appropriate to develop separate courses for
inspectors and for permitting staff. ICF International
also developed fact sheets and more complete guides
on selected topics (e.g., hazardous waste identification,
generator requirements). To promote waste minimization
and toxicity reduction, ICF International also developed
targeted outreach materials aimed at selected
industries. These materials make the business
case for cost and risk reduction through waste
minimization.
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