EIR Process/Corrective Action Plan

EIR Process

The OECM EIR process places a great deal of importance on having documents well in advance of the on-site review. There are several reasons:

i) It ensures that sites are ready for the review and minimizes expenditure of EIR resources for on-site visits with limited value.
ii) Review of advance documentation allows OECM and the EIR team to develop specific Review Questions that are generated from the document review and that are the focus of the on-site portion of the EIR. Effectively, we can inform the project team, in advance of the on-site review, of the specific data and information needed to address EIR concerns related to the various review elements discussed earlier.
iii) Having key documentation well in advance of the review allows OECM to perform reasonably comprehensive assessments without tying up site resources with lengthy on-site visits.

The specific duration of the Performance Baseline and the Construction or Execution Readiness Review depends on the size and complexity of the individual project being reviewed. The typical process for conducting a review takes 8 weeks from the time OECM receives the required review documents. This process is described below followed by a timeline for a typical EIR. (Limited EIRs can be done more quickly, and have been completed in less than 2 weeks.) During the EIR, final design and other on-going project activities may continue.

• Week 1. Following receipt of the review documents, OECM, in conjunction with the EIR contractor, develops a draft EIR Review Plan. OECM provides the Project Team, the PMSO and/or Program support staff a draft of the EIR review plan for review and comment. The PMSO/Program is responsible for coordinating any comments.

• Week 2. At the end of Week 2, the PMSO and/or Program provides comments on the draft Review Plan, as well as provides suggestions, if any, for additional review elements

• Week 3. OECM finalizes the EIR Review Plan and provides it to the PMSO, Program, and Site Project Team. In general, the Final Review Plan will also include specific Review Questions that will need to be addressed at the on-site review. The purpose of the Review Questions is to obtain data and information needed to address Scope of Review lines of inquiry, but not provided in the site project documents.

• Week 4. The Site Project Team reviews the EIR Final Review Plan, including specific EIR team Review Questions to be addressed during the on-site review, and makes final preparations for the EIR.

• Week 5. The EIR Team conducts the on-site review, and concludes with an outbrief to the Site Project Team. Note: The PMSO/ Program are encouraged to arrange for a teleconference/ televideo connection to the site outbrief.

• Week 6. OECM issues the draft report to the PMSO and/or Program, and Site Project Team for a factual accuracy review.

• Week 7. The Program and Project Team reviews the draft EIR report and provides factual accuracy comments to OECM. The Program/Project Team should strictly limit comments to the factual content of the EIR report. Any disagreements with the specific Findings or Observations should be noted in the Corrective Action Plan.

• Week 8. OECM incorporates comments, as appropriate, and issues the Final Report with recommended corrective actions to the PMSO and/or the Program, and the Site Project Team.

Corrective Action Plan

The Findings and recommended corrective actions from the EIR Team are provided by OECM to the Program/Project team in the final EIR report in the form of a "corrective action" template. The template will include fields to be completed by the Program/Site Project Team. The Corrective Action Plan template will include the following fields:

• Review Team Findings, including report page.
• Review Team recommendation
• Program/Project Team response (including whether the Review Team Finding is accepted or rejected)
• Response status for accepted Findings. The status should identify whether corrective actions are completed or pending, as well as the appropriate date.

Note: Programs/ Project teams may not always agree with EIR Findings. If the Program/Project disagrees with a Finding, the response should contain the supporting technical rationale.

For Performance Baseline reviews, the Corrective Action Plan should be approved by the Program and provided to OECM at least two weeks prior to a (pre)ESAAB- equivalent or prior to OECM scheduling of an ESAAB. For CD-3 reviews, the approved Corrective Action Plan should be submitted to OECM prior to scheduling the ESAAB.

EIR Tailoring

Tailoring is an essential component of EIRs. Tailoring can apply to any project, but has increased applicability to projects that are considered to be routine in nature, such as traditional construction projects, and have relatively low risk. Tailoring will also be used by OECM when validating Performance Baselines as part of a Baseline Change Proposal following a deviation. A key consideration when tailoring the Performance Baseline EIR is to ensure the EIR supports OECM validation of the Performance Baseline. Tailoring may include:

• Use of summary level Resource Loaded Schedules
• Use of summary cost and schedule supporting documents 
• Conducting limited interviews with selected members of the Integrated Project Team over the telephone or in a videoconference
• Reviewing key documents with minimal site visit, if any
• Reducing the scope of review requirements

Note: The nature of environmental restoration and closure activities performed by the Office of Environmental Management requires a tailored approach to EIRs. For these type of projects, EIRs may include additional review elements or deletion of some of the standard elements. The overall process described in Section 6 will be followed.

EIR Report

The format and content of the EIR report will, in general, be consistent with the EIR Review Plan. For each element of the review scope identified in the Review Plan, the EIR Team will discuss what was done by the Project to address this element followed by any EIR team findings or observations. There will not be a separate Independent Cost Review report --- findings or observations in this area will be incorporated into the overall EIR report. The EIR Report will also contain an Executive Summary that discusses significant Findings.

Formal transmittal of the EIR Report will be from the Director of OECM to the Deputy Administrator or Program Secretarial Officer.

OECM Performance Baseline Validation Process

Consistent with DOE Order 413.3, all projects must have the Performance Baseline validated by OECM. Baseline validation occurs prior to CD-2 or prior to Baseline Change Proposal approval.

OECM will use the EIR Final Report, in combination with any corrective actions identified in the approved Corrective Action Plan, to assess whether the Performance Baseline can be validated. OECM may also use information from Independent Project Reviews, IG reports, or other such information in assessing whether a Performance Baseline can be validated.

OECM is required to validate the Performance Baseline prior to a program requesting construction funds from Congress. On an exception basis, and to conform to the budget cycle, projects may need to be in the budget prior to OECM validation. All OECM Performance Baseline validations will be documented in a memorandum from the OECM Director to the Deputy Administrator or Program Secretarial Officer.

EIR Evaluation and Feedback

Program offices, project teams and PMSOs are encouraged to provide OECM with feedback on the conduct of the EIR including any comments related to:

• Quality of the review and findings
• Knowledge and professionalism of the review team members
• Preparation of the review team
• Scope of the review
• Timeliness and responsiveness of OECM and the EIR team

Evaluation comments and feedback will be used to improve the quality of the overall EIR process.