Development and application of a regulatory compliance improvement (RCI) approach to environmental remediation operations and maintenance (ERO&M)

Environmental management is a complex and costly part of all organizations that are required to comply with state or federal environmental requirements. This dissertation describes the development and application of an approach for improving the way that regulatory compliance is achieved in environmental remediation operations and maintenance (ERO&M). The regulatory compliance improvement (RCI) approach—and its implementation at the Dow Chemical Company—is presented as evidence of the importance of regulatory compliance as a primary driver of ERO&M costs. The approach is evaluated using' objective evaluation criteria to measure the improvements from the application of a five-stage improvement approach. The approach is novel in its focus on regulatory compliance, but was derived with traditional systematic improvement approaches in mind.; The RCI approach treats regulatory compliance as an opportunity, where it has historically been viewed as a constraint. A pilot test utilized the approach on 21 of the Dow Chemical Corporation's ERO&M projects. The approach resulted in improvements in compliance criteria for more than 75% of the projects. Total short-term cost reductions of {dollar}4.7 million, or 12%, were credited to the approach. Life-cycle cost savings were achieved, and project and public risks were reduced as a result of the approach. These results demonstrate that public and private organizations can reduce their ERO&M liabilities by improving the manner in which they achieve compliance with regulatory requirements.