EFCOG Best Practice #11

Regulatory Agency Action and Inspection Tracking Systems

Facility: Hanford Site, Richland Washington

Point of contact:

• Richard Gurske, Director, Fluor Hanford, Inc.

Brief description of the Best Practice

Fluor Hanford has implemented two web-based systems for use by DOE and Hanford Site contractors. The first system is used to track and status environmental compliance actions and related requests received from external regulatory agencies, and commitments made by DOE and its contractors in response to these items. This system, known as the Environmental Actions Tracking System (EATS), helps DOE and its contractors ensure that actions and commitments due to regulatory agencies are not overlooked. This system also satisfies the Resource Conservation and Recovery Act (RCRA) requirement to maintain a 10-year compliance history in accordance with provisions contained under Washington Administrative Code (WAC) 173-303-281. Summary reports are available for all DOE/contractor personnel connected to the LAN.

 Fluor Hanford has also implemented a recently developed second system that is used to manage information associated with regulatory agency inspections. The Regulatory Agency Inspection Database (RAID) identifies (1) facilities/buildings inspected, (2) inspection attendees, (3)provides a summary of the inspection, (4) hours spent on the inspection, and (5) cross references associated compliance actions maintained in the EATS database that are associated with a given inspection. All inspections are documented, whether a close-out meeting is held or a written inspection report is received. Summary reports are currently only available to select FH personnel on a Share drive.

In addition to ensuring that environmental compliance actions and commitments are not missed, this system allows for retrieval of historical inspection information that can be used for annual performance reviews.

Why the best practice was used:

EATS was developed to track formal regulatory agency issues (arising from inspections and formally transmitted to DOE) and consolidate multicontractor responses. DOE-RL staff recognized a significant increase in actions being identified by regulatory agencies that were requiring timely or expedited responses. These actions were occasionally not identified in time to respond or required additional time to respond.

In a second effort, Fluor Hanford environmental staff recognized a significant increase in regulatory agency inspections, data requests, and associated inefficiencies related to inspection data retrieval and records management. At the same time, FH environmental staff available to support inspections had decreased in the last three years. RAID was developed to document all regulatory inspections.

What are the benefits of the best practice

Use of EATS

• Ensures DOE-RL and contractor commitments to regulators are identified and addressed
• Improves efficiency and completeness of responses to regulator requests
• Optimizes time and labor resource
• Assists in improving interagency communications

Use of the RAID

• Provides inspection description and results
• Documents Regulator requested data
• Records past inspections
• Retrieves data in a complete and timely manner

What problems/issues were associated with the Best Practice

The problems associated with the deployment of EATS were political not technical. There was resistance to placing the information into a database and resistance to development of a new system rather than trying to force fit it into an existing system.

The problems associated with the deployment of the RAID system were (1) populating the database with archive inspection data, and (2) the associated significant man-power effort required.

How the success of the Best Practice was measured

Since the implementation of EATS, there has been no regulatory action taken against DOE or it’s contractors for missing any actions or commitments associated with a regulatory agency’s request or compliance action. No action or commitment due date has been unknowingly missed.

Numerous compliance performance reports have been generated in hours that, prior to the existence of EATS, would have taken days to generate.

The inspection database is fully supported by Fluor Hanford’s customer, DOE-RL. It is a new system that was deployed June 30, 2003 and in the future, success can be measured by the percentage of inspection data requests completed versus requests not completed.

Positive feedback from EPA, Ecology, and DOH project managers – over the last three years we have received "better than average" feedback from the regulators regarding responsiveness and communication as part of our FH Environmental Stewardship Award criteria.

In the last three years as actions and inspections have increased and time and staffing have decreased, FH has reduced turn around time from 5 days to a week to 3 days for inspection data requests, from days to hours for report requests, and from 2 exempt person to one exempt person for support staff.

Description of process experience using the Best Practice:

EATS and RAID have been established and used as a best management practice at FH. Results include:

• Improved environmental compliance performance to reduce legal fines and penalties associated with missed actions
• Resource and cost savings by needing fewer people (1 instead of 2 exempt staff) and fewer days to respond to report and information requests from days to hours.
• Improved interagency relations at the project/working level by recognizing Fluor Hanford efforts to improve environmental performance. This is confirmed by positive regulator feedback on facilities during our annual award review process and criteria.
• Environmental integration and continuous improvement through EATS and RAID review process.