Environmental Engineering Reference
In-Depth Information
may not be covered in existing, preapproved packages of Guidelines. This
approach would proceed as follows:
1. The developer assembles the package of Guidelines (see above) that it
proposes to use for a particular project, and it prepares documentation
and analysis demonstrating that all requirements of the goal-based stan-
dards are satisfied.
2. A third-party CVA reviews the developer's package of Guidelines and
the underlying documentation and analysis and provides a statement
indicating that the package is in full compliance with the goal-based
standards. If the CVA identifies deficiencies or has concerns that are not
fully reconciled by the developer, they should be explained in the CVA's
report.
3. The developer submits its package of Guidelines, including the CVA's
report, to BOEMRE, seeking approval for the package of Guidelines to
be applied to the project. BOEMRE either approves the package or
sends it back to the developer requesting revisions or further documen-
tation and analysis, or both.
The approval of the package of Guidelines (standards, rules, industry
guidelines, and recommended practices) that will be followed to ensure
compliance with the goal-based standards does not imply that site-specific
assessment and analysis are not required. Project certification (see Chap-
ter 3) with on-site assessment is expected to be a standard part of the design
and review process.
OVERVIEW OF PROJECTED BOEMRE ROLE
It is important that a single government agency, presumably BOEMRE,
have overall responsibility for regulatory development, monitoring and
maintenance of the regulations, and implementation of the verification
and oversight regime.
Below is a summary of the role that BOEMRE would play under the
approach recommended by the committee. The role is a large one, and
BOEMRE may wish to consider creating an expert panel to assist with the
initial development of the goal-based standards and then with continuous
monitoring and evaluation of the standards and regulations.
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