Environmental Management System Support to Comply with a Consent Decree
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Alpha Natural Resources (ANR) was one of America's leading producers of coal. ANR and certain of its subsidiaries (ANR) entered into a Consent Decree with the U.S. Environmental Protection Agency (EPA), U.S. Department of Justice, and three states regarding claims under the Clean Water Act.

The Consent Decree resolves a complaint by the US EPA and state agencies alleging that the company's mining affiliates in Kentucky, Pennsylvania, Tennessee, Virginia, and West Virginia exceeded certain water discharge permit limits. As part of the Consent Decree, ANR agreed to implement a compliance-focused Environmental Management System (EMS), and retained Geosyntec to serve as the Consent Decree-mandated EMS Consultant and to support ANR with development and implementation of its new EMS.

Geosyntec's Scope of Services

Geosyntec provided ANR with an initial review and evaluation of its existing environmental management practices and documents. This process identified where existing systems or subsystems had not been adequately developed or implemented or needed to be enhanced. It also identified new management systems or subsystems that needed to be developed to adequately address all requirements under the Consent Decree.

We then provided a presentation to ANR's top management and its EMS advisory group on how EMSs are designed and how ANR can benefit from an EMS, and provided support to ANR in developing and publishing its EMS Manual that was submitted to EPA for review and approval. Concurrently, Geosyntec worked with ANR to develop the management system procedures and formulate an implementation plan including an environmental aspects and impacts assessment. We also worked with ANR on developing operating procedures, templates, and training materials.

In August 2015, ANR and certain of its wholly-owned subsidiaries filed voluntary petitions with the U.S. Bankruptcy Court to reorganize under Chapter 11 of the U.S. Bankruptcy Code. Since that time, Geosyntec's work has been limited to one conversation with ANR about its EMS roll out plan.

Notable Accomplishments

Geosyntec helped ANR avoid stipulated penalties by meeting its Consent Decree deadlines for Initial Review and Evaluation Report completion and EMS Manual submission. In addition, "Environmental Compliance" has now been added as a new section to ANR's employee manual under the heading "What the Company Expects from You," right along side "Safety Rules."

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Project Summary

  • Location: Bristol, Virginia
  • Client: Alpha Natural Resources
  • Project Practice Areas: Environmental Management
  • Type of Facility: Coal mining
  • Services Provided: Initial review and evalution of existing environmental management practices and documents, Integrated environmental management system development and implementation, Operating procedure, template, and training material development, Education and training on environmental management systems and management system procedures
  • Type of Work: Environmental management system support
  • Governing Regulation: Federal regulations