5. ENVIRONMENTAL BRIEFINGS AND TRAINING
The purpose of the MMCRP is to ensure compliance with adopted mitigation measures, and associated requirements and permits, in order to minimize impacts on the environment. Non-compliance with environmental requirements can occur because owner, contractor, and inspector personnel are not completely aware of the environmental requirements for the project or because they do not understand how the environmental requirements are implemented. Aspen's environmental monitors will receive in-depth training to learn all the environmental requirements and how they are to be implemented. To reduce the potential for non-compliance events, training provided by PPSI for PPSI inspectors and contractor supervisory personnel (to the level of foreman) will provide an understanding of the environmental requirements that pertain to the Pacific Pipeline Project; this training will be monitored by Aspen and our staff will participate as necessary or as requested.
5.1 Training of Aspen Monitors
Aspen has developed a training program for environmental monitors based on project specific mitigation requirements as well as Federal, state, and local permit stipulations, landowner agreements, and applicant-proposed measures. Aspen's goal is to educate the environmental monitors to ensure that the specific standards and requirements for protecting the environmental resources are met. This section describes the goals of the training program, and presents a detailed agenda for the course.
Prior to monitoring the project, each Environmental Monitor (EM) will attend Mitigation Monitor Training (MMT), which is tentatively scheduled for the last week of May, 1997. The MMT program will be presented in three full days to mitigation monitors who will be representing the California Public Utilities Commission (CPUC) and the Angeles National Forest (ANF). The training program will ensure that each EM has complete working knowledge of:
- - What the project is; what are the components of the construction phase of the project
- - What impacts were identified and what mitigation measures were adopted
- - How to interpret and apply the measures
- - Where the measures are required
- - Who is responsible for compliance
- - Enforcement responsibility and authority
- - Procedures for non-compliances
- - Levels of non-compliance
- - Reporting requirements
- - How to respond to requests for variances
- - Jurisdictional agencies and their requirements
- - Construction and environmental alignment sheets and typical drawings
- - Chain of command (including levels of authority)
- - Communication protocol and structure.
The MMT program will begin with a brief description of the Pacific Pipeline Project. The contents of the Field Monitoring Manual for Environmental Monitors (see Section 6 of this Implementation Plan) will be reviewed to ensure that all monitors fully understand its contents (the manual will be distributed during the training). Both correct and incorrect applications of the mitigation measures in a variety of situations will be discussed. Understanding the requirements of the mitigation measures and how to apply them will be emphasized during training. Technical Experts may be utilized to describe specific requirements and significant features associated with their issue areas. The function and use of the Data Management System will be included in the MMT program. Attendance by EMs at the MMT program will be recorded.
At the conclusion of the MMT program, and depending on the construction schedules, the monitors will receive portable computers, communication tools, necessary forms and any other informational or field material. The manual will be updated as necessary throughout the pre-construction and construction phases.
Following is the proposed agenda for the MMT program:
DAY 1
- 8:00 Introduction - Dr. Hamid Rastegar
- Introduction of project team members
- Background of project
- Introduction of Participants
- CPUC, ANF, PPSI, L. W. Reed Consultants, etc.
- Responsibility of participants
- 9:00 The California Public Utilities Commission (CPUC) - Martha Sullivan
- Role and expectations
- Philosophy
- Authority
- 9:30 The Angeles National Forest (ANF) - Rich Borden
- Role and expectations
- Philosophy
- Authority
10:00 BREAK
- 10:10 Program Manager - Hamid Rastegar
- Aspen and EM's role and expectations
- Authority
- 10:40 Deputy Program Manager - Susan Lee/Vida Strong
- Role and expectations - Field/office coordination
- Authority
- 11:00 Environmental Monitors - Kris Thorne
- Lead Environmental Monitor (LEM)
- Role and responsibilities
- Authority
- Environmental Monitors (EMs)
- Role and responsibilities
- Authority
- 11:30 Field Communication - Hamid Rastegar
- Within Aspen
- With Participants
12:00 LUNCH
- 1:00 Training Overview - Hamid Rastegar
- Purpose of training - well-informed and well-trained staff
- Other training programs (PPSI's environmental, contractor's safety, etc.)
- 1:15 Distribute and Introduce Training Tools - Kris Thorne
- Alignment sheets
- Typical and supplemental drawings
- Field Monitoring Manual
- look through and explain sections
2:15 BREAK
- 2:30 Media Contact - Hamid Rastegar
- Guidelines when approached by the media
- 2:45 Project Location - Craig Hattori
- Spread descriptions and locations
- 3:15 Jurisdictional Agencies - Negar Vahidi
- The agencies
- Their authority
- Our responsibility to them
- Their permits (distribute copies of permits if not previously included in the manual due to timing & availability)
- Conditions and requirements of the permits
5:00 ADJOURN
DAY 2
8:00 General Guidelines for EM actions: mobilization, logistics, appearance, and work habits
- 9:00 Compliance and Non-compliance - Kris Thorne
- Definition
- Levels of non-compliance
- Procedures to follow
- Reporting requirements
10:30 Mitigation Measures, Applicant-Proposed Measures, and PPSI's Plans
How to interpret and apply:
- - Air Quality
- - Biological Resources
- - Cultural Resources
- - Cultural Resources Plan
- - Management Plan for Old Ridge Route
- - Environmental Contamination
- - Health and Safety Plan
- - Geology and Soils
- - Erosion Control, Revegetation and Landscaping Plan
- - Geologic Hazards
- - Hydrology
- - Stream Crossings
- - Land Use and Public Recreation
- - Notification of Residents/Property Owners Plan
- - Mitigation Disclosure Form
- - Noise
- - Paleontology
- - Paleontological Resources Monitoring Plan
- - Public Utilities and Energy
- - Utility Restoration Plan
- - Socioeconomics and Public Services
- - Local Employment Plan
- - Business Impact Mitigation Plan
- - System Safety and Risk of Upset
- - Fire Protection Plan
- - Transportation and Traffic
- - Transportation Management Plan
- - Visual Resources
- - Environmental Justice (Impacts on Minority and Low-income Populations)
- - Community Outreach and Communication Plan
- - Community Partnership Plan
- - Oil Spill Contingency Plan
12:00 LUNCH
1:00 Mitigation Measures and Applicant-Proposed Measures (continued)
4:30 Requests for Variances - Kris Thorne
Protocol
5:00 ADJOURN
DAY 3
8:00 Role-Playing Exercises - Hamid Rastegar and Kris Thorne
Non-compliance events and actions to be taken
Difficult situations anticipated in dealing with contractor personnel
11:00 Documentation and Reporting - Craig Hattori and Kris Thorne
Record-keeping procedures
12:00 LUNCH
1:00 Documenting and Reporting (continued)
Familiarization with the portable computers
Data Management System
System application and use
Exercises in report preparation and modem submittal
5:00 ADJOURN
5.2 Training/Briefings for Construction Personnel
Preconstruction training sessions will also be developed and conducted by PPSI and their construction contractors to inform construction personnel about mitigation measures, the reason for the establishment of the Mitigation Monitoring Program (MMP), and the requirements of the MMP. The training will describe in simple, nontechnical language why training and monitoring are occurring and how a win-win relationship can be established among the agencies, the owner, and the contractors and subcontractors.
Topics to be presented, at a minimum, are:
Construction personnel (including PPSI, contractors, subcontractors, and service personnel) must attend a brief (not less than 30 minute) project orientation and environmental training program prior to going to the project area (including right-of-way, staging areas, extra work space, and equipment yards). A record shall be kept of personnel attending all training and briefings. The purpose of the project orientation program is to introduce personnel to the general requirements that everyone on the job site must follow. This program will be developed by PPSI and conducted by PPSI or its designee. Aspen's LEM, or her designee, will participate in the project orientation and environmental training programs to present information regarding the monitoring program of the agencies and to clarify discussion of mitigation monitoring activities, if PPSI so requests. Agency personnel are encouraged to monitor the adequacy of training and briefing programs.
During construction, PPSI may also provide periodic training or briefings to provide more in-depth or specialized information about project requirements. Aspen shall be notified of such training at least 24-hours prior in order to make arrangements to attend, although Aspen is not required to attend.
5.3 Briefings with Permitting Agencies
Aspen has identified jurisdictional requirements and developed coordination procedures for the affected agencies (see Section 7). Clear roles and responsibilities for the numerous jurisdictional entities and the line of authority and reporting for each entity will be established by meeting with field personnel from CPUC/ANF and responsible/cooperating agencies.
If specific briefing or training is required for agency personnel regarding the status of the project, it will be provided by the Program Manager or his designee. If agencies need to provide information or training to the EMs, the LEM will coordinate with agency personnel to make necessary arrangements.
5.4 Training Manual
The Field Monitoring Manual prepared by Aspen is contained in this Implementation Plan as Section 6. The Manual defines all relevant information and requirements for conducting consistent and complete field monitoring. The manual contains the following sections: