U.S. DEPARTMENT OF THE INTERIORBUREAU OF LAND MANAGEMENT
UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
September 25, 2007
In Reply Refer To:
1703, 3720(360) P
EMS TRANSMISSION 10/05/2007
Instruction Memorandum No. 2007-204
To: All Field Office Officials
Attn: Hazard Management and Resource Restoration Program Leads, Lands and Realty Program Leads
From: Assistant Director, Minerals, Realty, and Resource Protection
Subject: Identification of Bureau of Land Management Environmental Professionals and Available Training
Program Areas: Lands and Realty, Hazard Management and Resource Restoration
Purpose: The purpose of this Instruction Memorandum (IM) is to provide managers with the list of Bureau of Land Management (BLM) personnel who are qualified to conduct Environmental Site Assessments (ESAs) for property acquisitions and to request assistance in maintaining the list.
Policy/Action: The personnel listed in Attachment 1 are Environmental Professionals (EPs) and are the only persons, currently identified, who meet the requirements of 40 CFR Part 312 for conducting environmental screening for BLM land purchases, leases, grants, or any other type of land acquisition in which the BLM gains a real property interest. The application process for adding personnel to the list is provided as Attachment 2.
Managers should fully support training to ensure that these personnel meet the continuing education requirements of the new regulation. Attachment 3 provides additional information on EP training.
Managers that do not have personnel who meet these EP qualifications will need to request assistance from their Hazard Management and Resource Restoration (HMRR) State Office Program Lead or contract a qualified EP to conduct ESAs.
The BLM Washington Office will coordinate with an EP Panel, the National Training Center and the HMRR State Office Program Leads to:
Timeframe: 40 CFR Part 312 was effective November 1, 2006, and applies to all ESAs conducted by the BLM after that date. This IM is effective immediately.
Budget Impact: Funding associated with training and travel will impact the budget.
Background: This IM complies with a recent Environmental Protection Agency regulation, effective November 1, 2006, modifying the way the BLM conducts ESAs for new land acquisitions. The new regulation has specific requirements concerning the qualifications of personnel engaged in the environmental screening process (See attachment 4, Definition of an Environmental Professional and Relevant Experience). The regulation provides that only an EP may certify an ESA. An EP is defined as “someone who possesses sufficient specific education, training, and experience necessary to exercise professional judgment to develop opinions and conclusions regarding conditions indicative of releases or threatened releases of hazardous substance on, at, or to a property, sufficient to meet the objectives and performance factors of the rule.” All new acquisitions are required by 602 Department Manual 2 to have an ESA.
The Washington Office issued IB No: 2006-117, to prepare the BLM personnel for changes resulting from 40 CFR Part 312.
A survey (IM No: 2007-027) was conducted to identify BLM personnel meeting the requirements of 40 CFR Part 312. A Review Team consisting of Washington and State Office HMRR Leads and Lands and Realty Program personnel assessed responses and determined that those individuals identified in Attachment 1 meet the requirements.
Manual/Handbook Sections Affected: The BLM Manual Section 1703 and BLM Handbook H-2101-4 will be updated to include these policies.
Coordination: This policy has been coordinated with the Lands, Realty and Cadastral Survey Division (WO-350) and the National Training Center.
Contact: Miyoshi Stith, HMRR Program Lead, (202) 557-3578, Division of Engineering and Environmental Services (WO-360).