,.-••'
Lean Gove
EPA Region 3 and Region 7
Corrective Action Facility Investigation Process
Summary
In 2013, EPA Regions 3 and 7, in partnership with the Association of State and Territorial Solid Waste Management Officials (ASTSWMO),
the States of Missouri and Virginia and industry representatives, held a Lean event on the Resource Conservation and Recovery Act
(RCRA) Facility Investigation Process (RFI). The RFI process is a component of the RCRA Corrective Action Program, which oversees the
investigation and cleanup of hazardous waste facilities across the country. During the facility investigation phase, the nature and extent
of contamination at a facility subject to RCRA Corrective Action is evaluated.
EPA and its state partners set an aspirational goal to construct final remedies at 95 percent of the baseline of RCRA facilities nationwide
believed to need Corrective Action by 2020. Out of those 3,779 RCRA Corrective Action facilities, Regions 3 and 7 alone are home to 783.
The RFI process can potentially comprise 70-80 percent of the overall time it takes to build final remedies for RCRA Corrective action
facilities. The Lean event team sought to identify opportunities for increased efficiencies in the RFI process by determining the root
causes of delay and removing redundancies and barriers to progress. The team developed a Corrective Action Framework (CAF) that
frontloads a discussion of the goals and
expectations of the facility investigation F'§ure 1: The RFI Process Lean Event Team
into a meeting at the beginning of the
process. This approach also provides a
set of tools and templates for project
managers to hold a CAF meeting, and
also provides metrics to track facility
efficiency. The introduction of the CAF
meeting is expected to reduce time
previously associated with non-value
activities, therefore accelerating cleanup
progress to the benefit of affected
communities.
Results
Metric
Total Avg. Lead Time
# Handoffs
# Reviews
# Loopbacks/Revisions
# Documents Generated
Percent Value-Added Steps
Old Process
Up to 19. 4 years
44
33
24
94
10%
Lean Approach
5.1 years
11
7
2
15
51%
Percent Change
4,73%
4,75%
4/79%
4,92%
4/84%
1^80%
*Results are anticipated based on the new process design
In addition to a significant reduction in lead time and cost savings, Lean process improvements can also enhance communication
throughout the process, and ensure all stakeholders have a clear understanding of the steps and decisions needed to complete RCRA
Facility investigations.
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Scope of the Lean Project
Project Scope: The scope encompassed the RFI process starting with the Corrective Action Framework Meeting and ending with the
review and approval of the RFI report.
Regions 3 and 7 improved the Remedy Selection process (RSP), the next phase of RCRA corrective action, through a separate Lean event
held in May 2014. The combined streamlined process for RCRA facility investigation and remedy selection is known as the RCRA FIRST
approach.
Goal: Streamline and reduce lead time in the facility investigation process by 50 percent.
Process Changes and Improvements
Using DMAIC methodology (Define, Measure, Analyze, Improve, Control) and value stream mapping, the team identified twelve pain
points in the RFI process and determined the root causes of these pain points. The new process design incorporated the following
primary takeaways from the Lean project:
1. Upfront planning and information-sharing is essential.
2. Upfront scoping of goals and expectations can save time later in the process
3. Identify delays and elevate problems where visible
4. Use metrics to measure progress and adjust process
Figure 2: The Lean event team's DMAIC methodology
The event team determined that early understanding of goals and expectations in the RFI process could reduce redundancies and
expedite the investigation process. Under the Lean approach, the lead agency, supporting agency, regulated facility, and stakeholders
clarify the objectives and expectations for the facility investigation during one or more CAF meetings to develop a Corrective Action
Framework. The CAF Meeting, under the RFI Lean concept, is an initial meeting between the regulatory authority (EPA and/or State) and
facility representatives to identify and clarify expectations concerning the RFI phase of the Corrective Action process. This meeting
would bring the representatives together early in the process for a robust discussion of the investigation scope, conceptual site model,
potential interim measures, and other elements of the RFI process. The CAF summarizes the goals and expectations for the RFI as
discussed during the CAF meeting. The CAF ensures that all stakeholders have a clear understanding of the data needs, decision points,
and outcomes before moving forward. Figure 3 shows how this new process works with the CAF meeting taking place and the goals and
expectations understood before the facility submits the RFI workplan.
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Figure 3: RCRA Facility Investigation Process showing CAF meeting and RFI Workplan Review
Assemble Team &
Plsn Corrective Action
Fi Emework (CAF)
Meeting
EPA I Facilitation
| EPA State Action
Facilit:Action
:.r,n i:i,,Mhil-i
Dec bio n Point
C ondue I
P/eeting ?nd
Produce CAF
RFI Gosls End
EHpectation
U nderstood?
Commence
.'oint E Is'/Etion
Beginning PhEse Outputi
1 CAF
2. Draft Conceptual Site Model (in CAF)
3. Approved RFI 7,'orh Plan
FEcility Submits RCR^
Facility Irwesiigation
(RFI)Work Plan
EPA has developed tools for
regulators and facilities
wishing to draw upon the
results of the RFI Lean
analysis at their own facilities
-a model Corrective Action
Framework Meeting Agenda
(CAF Meeting Agenda) and a
model Corrective Action
Framework Template (CAF
Template). EPA anticipates
that the increased attention
to detail prompted by the
templates will help identify
potential issues that may
need attention for the RFI to
continue smoothly. To make the tools accessible, the event team created a RCRA Corrective Action Lean Effort public webpage
where project managers working on the RFI process at facilities across the country can download the tools as needed.
In addition to the templates, the Lean event team also created process metrics to measure the efficiency of the newly
established CAF structure, and track where process adjustments might be needed.
Commence
Joint Election
Implementation
During the last half of 2013, EPA Regions 3 and 7 successfully piloted the CAF tools. The pilot realized a 75 percent reduction in
the time required to approve an RFI Work Plan. The regions developed a set of RCRAInfo CAF events to document the progress.
In the spring of 2014, the other eight Regions identified pilot projects to utilize the CAF tools. Since the pilot, Regions 3 and 7
have now fully implemented the process changes into their facility investigations.
Following the RFI event, a separate Lean event addressed root causes of delay in the RCRA Remedy Selection process. The
process improvements identified in the RFI Lean event and the Remedy Selection Lean event were combined into a streamlined
process called the RCRA FIRST approach to Corrective Action. EPA is creating a guide to transfer the tools and lessons from
these process improvement efforts to other regions. Once completed, it will be available on the RCRA Corrective Action Lean
Effort website.
For More
Information:
Lean Event Contacts:
Don Lininger, EPA Region 7, (913) 551-7724, lininger.don@epa.gov
Paul Gotthold, EPA Region 3, (215) 814-3410, gotthold.paul@epa.gov
RCRA Corrective Action Lean Effort Website:
http://www.epa.gov/epawaste/hazard/correctiveaction/lean effort.htm
EPA Lean Government Initiative:
Kimberly Green-Goldsborough, EPA Office of Policy, (202) 566-2355,
green-goldsborough.kimberly@epa.gov
http://www.epa.gov/lean/government/
United States
Environmental Protection Agency
Office of Policy
(1807T)
March 2015
EPA-100F15001
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