1. Authorizing Environmental Permitting

Management System: Environment, Safety, and Health

Subject Area: Environmental Authorization

Procedure 1. Authorizing Environmental Permitting

Subject Matter Expert: GERALD GRANZEN
Management System Owner: PATRICK SMITH
Secondary Management System Owner: KARL MORO
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Issue Date:  07/12/2012
SCMS Revision:  1.2

1.0  Applicability

This procedure applies to all Office of Science (SC) Site Office Managers and SC Site Office Staff who authorize work involving environmental permitting and oversee compliance with issued permit conditions associated with Federal and contractor operations and projects.

2.0  Required Procedure

Environmental permitting deals with regulatory authorizations under the Clean Air Act, Clean Water Act, Resource Conservation and Recover Act, etc.

Step 1 The SC Site Office Manager assigns an Environmental Permit Point of Contact (POC) who is responsible for regulatory authorizations and monitoring regulatory changes. The POC may utilize additional Site Office Staff as needed.
Step 2

POC reviews the contractor work planning processes, such as National Environmental Policy Act (NEPA) process (See the Implementing the National Environmental Policy Act [NEPA] within the Office of Science [SC] Subject Area) to evaluate the need for new or modified regulatory permits.

Step 3 In the event of new or revised regulations, the POC evaluates the applicability of the regulation to contractor operations.
Step 4 POC receives draft permit application from contractor or prepares draft application for environmental permit.
Step 5 POC reviews applicability and completeness of draft application submitted by contractor against regulations.
Step 6 POC recommends application for submittal to regulator or returns it to contractor for revision.
Step 7 For all draft applications recommended for submittal, POC obtains signatures with assistance of legal counsel, prepares transmittal correspondence, and sends application to appropriate regulatory agency(ies).  
Step 8 As necessary, POC discusses application with regulatory agency representative(s), coordinates public meetings, and/or prepares and coordinates any required Public Notices.
Step 9 The Regulator reviews the application and issues a final permit.  When SC Site Office Staff receive the Final Permit from the Regulator, the Staff review the permit and any final or special conditions. 
Step 10 POC sends permit and final or special conditions to the contractor for evaluation and determination of acceptability. If permit is not acceptable, the POC will initiate appropriate regulatory processes to contest the permit or unacceptable special condition.
Step 11

POC or Contractor develops implementation plans for the final permit.
Step 12

POC maintains Final Permit

NOTE: See Records Management Management System Description for more information on managing records.
Step 13

POC verifies compliance with permit conditions and associated implementation plans.

NOTE: For action steps that effectively accomplish the verification with the requirements of the specified DOE Order and other applicable standards (i.e. assessments, operational awareness, performance trending and issue management), see the Quality Assurance and Oversight Management System Description.
Step 14

POC conducts compliance assurance activities related to all regulatory compliance agreements and is responsible for understanding the provisions of the regulatory compliance agreements and ensuring compliance.

NOTE: For action steps that effectively accomplish the verification with the requirements of the specified DOE Order and other applicable standards (i.e. assessments, operational awareness, performance trending and issue management), see the Quality Assurance and Oversight Management System Description.

3.0  References

This is the online OFFICIAL SCMS COPY of this file. Before using a printed copy, verify that it is the most current version by checking the Last Major Revision and Last Minor Revision dates (at the bottom of each document) on the SCMS Web site.

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Last Major SCMS Revision: 03/11/2008