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HomeMy WebLinkAbout1.05 Environmental complianceEnvironmental Compliance 1. Pipeline Environmental Management Process 2. Organizational Overflow 2.1 Project Managers 2.2 Environmental Managers 2.3 Environmental Inspectors 2.4 Threatened 2.5 Biological, Cultural Resources & Paleontological Monitors 2.6 Construction Managers 2.7 Construction Inspectors 3. Orientation and Training l. PIPELINE ENVIRONMENTAL MANAGEMENT PROCESS ETC Canyon Pipeline, LLC is committed to designing, constructing, and operating the project in compliance with all federal, state, and local pennits and requirements. To ensure that this is accomplished, ETC wiIl implement the following strategies as the framework of the project's environmental management program. • Environmental Training: Environmental training and awareness programs will be conducted prior to construction on all environmental requirements. All project personnel working on the right-of-way will be required to attend environmental training. • Environmental Inspection: ETC's Environmental Inspectors will have a visible presence on the project. During construction, they will observe and document environmental compliance, as well as actively identify and anticipate potential environmental compliance concerns ahead of construction. • Open Communication: Environmental and construction representatives will interact daily and will ensure that all verbal discussions and written documentation are responsive at all times. All project personnel will interact as frequently as necessary to ensure that environmental information, concerns, and issues requiring resolution are communicated in a timely manner. 2. ORGANIZATIONAL OVERVIEW ETC Canyon Pipeline, LLC. has filed and will comply with the Bureau of Land Management (BLM) ROW Grant application procedures and associated stipulations and conditions. ETC acknowledges these stipulations as a condition and responsibility for the use of these public lands. The ETC Canyon Pipeline, LLC Environmental Compliance Management Program roles and responsibilities are summarized below. 2.1 PROJECT MANAGER Responsibilities include: • Successful completion ofthe ETC Canyon Pipeline, LLC ETC project. • Coordinating among the Construction Manager and Environmental Manager. • Consulting with the appropriate agencies on changes of project work that affect the mitigation program or sensitive resources. • Acting as the arbitrator between construction and environmental considerations if an intemal conflict arises. • The Project Manager wiIl be an ETC employee. The Chief Construction Inspector will report to the Project Manager. 2.2 ENVIRONMENTAL MANAGER The Environmental Manager is the ultimate authority for project environmental compliance and successful implementation of the environmental compliance management program. The Environmental Manager is responsible for directing the development and implementation of the pre-construction environmental planning, permitting and conformance activities, the environmental inspection program, and environmental training. Other responsibilities include policy and management level communications with ETC Canyon Pipeline, LLC management, federal, state, and local regulatory agencies. Additional responsibilities include: • communicating frequently with the Environmental Inspector and Contractor regarding environmental inspection and compliance activities; • maintaining communication with regulatory agencies; • coordinating with management level jurisdictional agency representatives (BLM, and Garfield County) in issues relating to environmental compliance; • advising on the interpretation of environmental compliance requirements; • ensuring that sufficient staff resources are available to successfully implement the environmental compliance management program; • interfacing with and advising project management regarding environmental compliance, • preparing environmental status reports; • reporting hazardous material spills in accordance with the Hazardous Materials Management and SpiIl Prevention and Countermeasures Plan; and • Coordinating with various project representatives, as necessary, to resolve issues when performing project troubleshooting on environmental compliance issues. 2.3 ENVIRONMENTAL INSPECTOR The Environmental Inspector will be assigned to the entire environmental compliance inspection process. In addition to performing inspection duties the Environmental Inspector wiIl be responsible for the following: • coordinating with the Project Manager and the Chief Inspector on a daily basis; • providing key liaison role in coordinating attendees and facilitating agreements in the field, as appropriate, with agency representatives; • Overseeing environmental training activities. The Environmental Inspector will be at work areas during clearing, construction, and reclamation operations, including seeding. The Environmental Inspector will oversee: the construction process as defined in the Plan of Development, environmental pennits, and BLM and Garfield County ROW Grant. The Environmental Inspectors is the key field staff responsible for ensuring pipeline construction activities comply with all applicable mitigation requirements contained in the Plan of Development, environmental permits, and project stipulations contained in the Row Grant. The Environmental Inspector will directly represent ETC Canyon Pipeline, LLC and have authority to enforce the environmental requirements of the POD. He will act as a liaison between the construction personnel and agency field representatives. In this capacity, he will coordinate regularly with the various Construction Inspectors to ensure that the Construction Inspectors are apprised of the status of environmental issues in their respective areas. Additionally, the Environmental Inspector will work in conjunction with the construction contractor representatives and agency field representatives. The Environmental Inspector will have in his vehicle at all times, a copy of the Plan of Development, environmental permits, and project stipulations contained in the ROW Grant, Environmental Inspectors will document construction contractor conformance with project mitigation requirements, permit conditions, and environmental specifications on a daily basis. The Environmental Inspector will be on a peer status with other project construction inspection staff. The Environmental Inspector will be responsible for determining non-compliance activities and anticipating activities and situations that could result in non-compliance to Plan of Development, environmental permits, and project stipulations contained in the ROW Grant. Environmentallnspectors will have a significant role to play in suggesting methods to bring construction activity into compliance and/or to temporarily halt certain activities that may cause damage to sensitive environmental resources. In this capacity, the Environmental Inspector will work in conjunction with the Construction Inspector as applicable. Under ordinary circumstances, or unless otherwise necessary, the Environmental Inspectors will exercise such "stop work" authority only after consulting with ETCs Chief Inspector. The Environmental Inspectors will use sound professional judgment in exercising these authorities and will not stop work unless there is a situation that could: I) cause serious injury or harm to persons or property, 2) harm threatened or endangered species or protected cultural resources, or 3) violate certain federal or state codes. The Environmental Inspector will be equipped with a cellular phone, measuring equipment, and record keeping equipment to perform compliance activities. 2.4 THREATENED AND ENDANGERED SPECIES MONITORS At this time, there are no requirements for separate Threatened and Endangered Species Monitors on the project. Sensitive plant populations have been avoided and will be flagged in accordance with project requirements. 2.5 BIOLOGICAL, CUL TERAL RESOURCE AND PALEONTOLOGICAL MONITORS At this time, there are no requirements for Cultural Resource Monitors on the project. Paleontological Monitors will also be present in areas requiring paleontological monitors. Responsibilities for these monitors include: • monitoring resource protection within specific areas of expertise (i.e. -paleontological); • being available at the request ofthe Lead Environmental Inspector; and • observing construction activities, documenting work, and submitting reports to the Environmental Inspector, according to their respective disciplines. 2.6 CONSTRUCTION MANAGER Responsibilities include: • completion of the construction project, including the pipeline and meter stations; • notifying the Environmental Manager of changes in the project work so that appropriate environmental reviews can take place; and • working with the Environmental Inspector to evaluate and Improve the implementation of the environmental compliance management program, as construction progresses. • coordinating with ETC Canyon Pipeline, LLC ETC Canyon Pipeline, LLC construction contractors, Construction Inspector and Environmental Inspector for all construction-related issues; and • supervising compliance with construction, safety, and environmental mitigation measures identified in the Plan of Development. 2.7 CONSTRUCTION INSPECTORS Responsibilities include; • conducting quality control construction inspections within area of expertise; and • providing support in monitoring and reporting compliance with the environmental compliance management program. 3. ORIENTATION AND TRAINING Training is an integral tool for achieving environmental compliance. The environmental training program will be developed to target every level of the organization (management and workforce). The training program will distribute various products to communicate and reinforce the compliance message, including a quick-reference handbook. Topics to be addressed during training will include biological resources, cultural resources, erosion control, fire prevention, hazardous materials spill prevention and control measures and other project requirements. In addition to the environmental training program, the Contractor is responsible for providing safety training that includes topics such as construction practices around overhead electrical transmission lines, buried utilities, and other safety related issues.