ENVIRONMENTAL PROFESSIONAL
Compliance; Risk Management; Cost Reduction, Strategic Direction
Email: abjyso@r.postjobfree.com 248-***-**** cell
Web Site: http://www.linkedin.com/in/frederickkoehler
Results driven environmental compliance and program manager with experience
in all facets of environmental water, waste, air and PCB compliance (RCRA,
CAA, TSCA, CWA) and program management for manufacturing operations. Well
versed in protocol and procedure development, cost reduction methods, and
liability reduction/risk management approaches. Proactive and perseverant
professional with an extensive background as a liaison/consultant to
government, public, and investor relations and legal staffs as well as
operating personnel. Areas of expertise include:
. Project management and oversight
. Regulatory interpretation for cost reduction strategies and efficient
compliance program implementation
. Technical advisor to WE CARE (Waste Elimination and Cost Awareness
Rewards Everyone - pollution prevention) regional committees
. Agency negotiations
. Environmental compliance auditing, property transfer assessments and due
diligence
. Conversion of government regulations into actionable,
understandable plant-level procedures (EMS), corporate strategic
direction and requirements (see addendum)
. Global compliance strategy implementation
. Vendor contract and pricing negotiations
. Environmental risk mitigation
. Investor Surveys Submittals
CAREER HIGHLIGHTS
. Negotiated water (NPDES and waste (TSDF, Closure and Post Closure,
Corrective Action) permits and permit conditions.
. Supervised all the environmental aspects at a large automotive
assembly plant.
. Initiated and lead the successful effort to remove several
parameters from Michigan's TCLP hazardous waste regulations.
. Established global waste handling and disposal criteria used at over
global 200 manufacturing locations and a methodology to analyze
(environmental) audit data (regionally, subject, risk) to identify,
develop and implement solutions for systemic problem areas.
. Authored over 15 bulletins, guidance and advisory documents that
provided the manufacturing operations with compliance direction.
. Supervised an environmental audit review team in conducting
compliance audits at operating facilities and due diligence -
property transfer reviews at discontinued facilities
. Administered and managed the 12 waste contracts ($16,000,000 per
year) involving disposal within the 100 United States and the
maquiladora facilities.
. Coordinated and managed the RCRA financial assurance program.
. Reduced the number of RCRA Part B permitted facilities from 14 to 4.
PROFESSIONAL EXPERIENCE
DELPHI CORPORATION (1999 - 2008)
Senior Staff Environmental Engineer (and Contract Administrator) Troy MI
(2005 - 2008) In addition to duties described in the 1999 to 2005
timeframe (below) I administered the hazardous and nonhazardous waste
contracts for 50 domestic and Mexican sites. Composed and issued
contract modifications, scopes of work, and waste reduction and disposal
proposals.
. Implemented waste cost (handling, transportation, and disposal)
and generation rate data tools which tracked the cost, volume and
type of each waste shipment. Analysis of this dataset allowed
for internal and external reports and cost savings initiatives.
. Audited waste invoices totally approximately 1500 invoices or
$16,000,000 per year.
Senior Staff Environmental Engineer Troy MI (1999 - 2005)
Responsible for activities related to waste management including
regulatory, legislative, and (EU) directive liaison for domestic and
international initiatives. Instrumental in policy creation, regulatory
interpretations and program initiation for issues related to RCRA
(Resource Recovery and Reclamation Act - waste, underground storage
tanks, etc.), DOT (Department of Transportation), and portions of TSCA
(Toxic Substances and Control Act) related to PCB transformers and
capacitors.
. Composed and supervised the compliance implementation for the
required DOT Security Plans necessary for most of Delphi's
domestic hazardous (waste) materials shipping locations.
. Initiated and managed the financial assurance mechanisms for
Delphi's TSDF, corrective action sites and Underground Storage
Tanks. Spearheaded and drove the reduction of this obligation
by reducing the number of existing TSDF Part B permits from 14
to 4.
. Established and managed Delphi's Global Waste Facility
Evaluation Program and domestic SREA (Superfund Recycling
Equity Act) evaluation program.
. Compiled data (GHG emissions, water discharges, waste metrics,
etc.) for submittal to investor surveys (DJSI, GRI, CERES).
Starting in 2003, Delphi was recognized and added to the Dow
Jones Sustainability Indexes.
GENERAL MOTORS CORPORATION (1984 - 1999)
Senior Staff Environmental Engineer Environmental and Energy Staff
Detroit MI (1994 - 1999)
Regulatory and legislative liaison for federal and state initiatives
related to hazardous waste. Instrumental in policy development,
regulatory interpretations and program initiation for issues related
to RCRA (waste, underground storage tanks), and PCBs.
. Received Presidential recognition for contributions to the Land
Disposal Program Flexibility Act of 1996 (P.L. 104-119). This
change to RCRA, amongst other things, removed the theory of "de-
characterized" hazardous waste which allowed GM to avoid
spending $100 million over 10 years.
. Established various RCRA compliance policies for over 100 GM
facilities, such as LDR (Land Disposal Restrictions Phases ll
and lll, and Subparts AA, BB, CC compliance.
. Initiated and lead the successful effort to remove several
parameters (Cu, Zn, and CN) from Michigan's Hazardous Waste
regulations.
Environmental Engineer Orion Assembly Plant - Facilities Engineering
Lake Orion MI (1993)
Accountable for compliance programs for all environmental aspects -
CAA (Clean Air Act) - NSPS (New Source Performance Standards) and LAER
(Lowest Achievable Emission Rate) monitoring and reporting, CWA
(Clean Water Act) - NPDES (National Pollution Discharge Elimination
System). MORs (Monthly Operation Reports), RCRA - handling and
shipments of hazardous and industrial waste at this automotive
assembly plant.
. Computed, compiled and submitted the NSPS reports detailing the
facility's hourly VOC emission rates.
. Coordinated and managed all industrial and hazardous waste
shipments.
. Compiled and submitted environmental reports such as SARA 313
report, RCRA annual report, NPDES monthly operating reports,
etc.
. Conducted worker training as necessary for their job functions
related to the environmental program.
. Co-Chair of the plant's Hazardous Material Control Committee.
Environmental Audit Supervisor - Environmental and Energy Staff
Detroit MI (1992 - 1993)
Supervisor for several teams of engineering personnel in conducting
environmental and health and safety compliance audits and phase 0 due
diligence/property transfer reviews at a number of various
manufacturing facilities.
. Conducted about twenty Phase 0, and 1 due diligence/property
transfer reviews.
. Created and implemented an environmental management systems
audit and internal protocols for property transfer review.
Staff Engineer - EAS - Industrial Waste Activity Detroit MI (1991 -
1992)
Provided project oversight for remediation projects and acted as the
environmental engineering interface between Legal Staff and various
environmental agencies for issues occurring in five GM divisions.
Lead legislative and regulatory negotiator and program initiator for
USTs (Underground Storage Tanks), pollution prevention, and packaging
waste proposals potentially impacting GM.
Divisional Environmental Engineer Buick-Oldsmobile-Cadillac (BOC)
Group - Warren MI (1988 - 1991)
Divisional expert responsible for CWA compliance programs and permits,
included project oversight, interface to GM Research.
. Project oversight on the upgrading of two wastewater treatment
plants.
. Lead engineer on the negotiations of several NPDES and sanitary
sewer permits at this division's assembly and metal fabrication
plants.
. Lead engineer for the Phase 1 (concept design and data and cost
model development) portion of the EMIS (Environmental
Management Information System) for the BOC group.
Associate/Project Engineer - Environmental Activities Staff (EAS) -
Audit Team Warren MI (1984 - 1988)
Conducted internal Air, Water and Waste compliance audits at over 100
GM manufacturing operations and hazardous waste disposal and recycling
operations.
. Created and implemented a corporate on-line disposal facility
database for domestic concerns.
. Conducted over ninety environmental audits in water, waste and
air areas of various domestic and international GM
manufacturing facilities.
. Promoted in-place during this tenure from associate engineer to
project engineer.
EDUCATION
B.S. Chemical Engineering - Purdue University, West Lafayette, IN, 5/1980
SIGNIFICANT TRAINING and CERTIFICATIONS
Professional Engineer Candidate
Certified Hazardous Materials Manager - Master Level - October 1995 No.
6488
Six Sigma Green Belt 52 hours Training
Delphi Problem Solving Process 8 hours
Delphi Environmental Training 32 hours
Risk and Vulnerability Assessment 16 hours
DOT Hazardous Material Transportation 16 hours
Financial Fundamentals in GM 24 hours
Finance and Strategy 16 hours
Root Cause and Decision Analysis 24 hours
RCRA Subpart CC 8 hours
Wayne County Air Emission Evaluation Training 16 hours
Property Transfer Environmental Auditing 16 hours
Hazardous Material Chemistry 8 hours
GM Environmental Certification Course 40 hours
A. D. Little Audit Team Leader Training 16 hours
EHS Leadership and Management 8 hours
Michigan Part 201 Implementation 8 hours
General Motors - Worldwide Facilities Group = Certificate of Recognition -
GM's First Successful RCRA Delisting Petition. Effort resulted in an
annual cost savings of $250,000.
Web Site: http://www.linkedin.com/in/frederickkoehler
ADDENDUM
Regulatory Expertise
. RCRA Haz Waste 40 CFR Parts 260 - 265
. UST 40 CFR Part 280
. Used Oil Part 279
. PCB 40 CFR Part 761
. DOT 49 CFR Parts 171, 172, 173
. Hazwoper 29 CFR 1910.120
Other Competencies
. CAA Title 1
. CWA Sections 402 and 307
. ATF 27 CFR Parts 20, 21, 22
. OSHA 40 CFR 1910
Trade Association Experience
MVMA Motor Vehicle Manufacturers Association - Now known as Alliance of
Automobile Manufacturers
MMA Michigan Manufacturers Association
NAM National Association of Manufacturers
API American Petroleum Institute
CMA Chemical Manufacturers Association Now know as American Chemical
Council
Aluminum Association
STI Steel Tank Institute
RCAP RCRA Corrective Action Project
CIBO Council of Industrial Boiler Owners
Authorships - Bulletins and Notices
. Regulatory Classification of Igniter (Explosive) Waste, 8/17/2005
. SREA Site Evaluations, 6/29/04
. Construction and Demolition Debris, 9/11/03
. Transportation Security Awareness Plan Guidance, 7/25/03
. Global Common Procedure Environmental Standards for Waste
Management, 7/1/02
. Mercury Control and Spill Response, 4/5/02
. Mexico PCB Regulations, 4/9/2002
. Fluorescent Light Ballasts Containing PCBs (polychlorinated
biphenyls), 3/8/2002
. Air Emission Regs for Waste Activities Subpart AA, BB, and CC
(Privileged and Confidential),12/16/1996
. Michigan Hazardous Waste Regulation, 11/20/1996
. Hazardous Waste Land Disposal Restrictions Phase lll, 5/21/1996
. RCRA Used Oil Regulations Part 279 Technical Amendments, 4/26/1994
. RCRA Used Oil Requirements, 2/14/1994
. PCB Update - Removal, Replacement, Retrofill or Decontamination.
(Privileged and Confidential), 7/16/1993
. Hazardous Waste/Toxicity Characteristic Determination, 7/15/1993
. Polychlorinated Biphenyls (PCBs) Update (Privileged and
Confidential), 2/12/1993