Environment & Safety
1. In order to maintain uniformity throughout Germane Synergy Ltd, energy compliance offices and to comply with applicable laws and regulations, Germane Synergy Ltd Energy compliance staff (ECS) in Head Office will maintain a master project database which will include all energy compliance project required by Germane Synergy Ltd facilities.
2. The Germane Synergy Ltd master project database will include synoptic information and priority rankings for all Germane Synergy Ltd energy compliance projects. It will support the development of the energy compliance portion of Germane Synergy Ltd budgets, spending plans, and annual financial statements.
3. Electronic methods will be used to maximum extent possible in maintaining, sharing, and transferring the master project database.
1. Energy cost estimates within Germane Synergy Ltd will be determined using direct methods whenever possible, and through indirect methods when necessary.
1. Direct methods will be used according to the following order of preference:
1. Solicited estimates from reputable vendors or contractors for specific or grouped activities
2. Approved Germane Synergy Ltd cost- estimating software
3. Detailed "bottom-up" estimates of the amount of labor, equipment, and materials and their associated unit costs.
4. Standardized published references (such as "means")
1. Indirect methods rely on the expertise of estimator and extrapolation from analogous data
2. A simple statement will accompany the cost estimates stating why the particular technique used was considered preferable.
2. Discovery as used in this document shall be defined as the date the government accepts the results of an observation, survey, audit, or inspection. Acceptance can be agreement with preliminary results as being indisputable. The receipt of a final survey, audit, or inspection report will always constitute discovery if the government has not previously agreed to preliminary results.
3. Germane Synergy Ltd considers a project complete from a financial energy liability perspective when the work has been completed and the receipt of contracted goods or services has been certified for payment.
3.1 Discovery: Germane Synergy Ltd energy compliance projects are discovered by various means, including environmental site audits, environmental surveys, self-inspections, external inspections, and informal observations. Regardless of how a project is identified, it is important that it be considered for inclusion in the Germane Synergy Ltd master project database
3.2 Prompt Corrective Action: some energy compliance projects either have no associated cost or can be corrected with available funding. Such projects should be completed promptly and do not require further action. However, many projects either cannot be funded immediately or must be funded from a source other than the facility at which the project exists. The project must be documented and entered into the master project database, regardless of the funding source or the fiscal year of anticipated funding.
4.1 Line Office Role:
4.1.1 The process begins with the completion of a "Project Prospectus Sheet the line office representative (as designated). This form should be completed within 30 days of "discovery" of an unfunded energy project.
4.1.2 The line Office representative should estimate the cost of the project, indicate the rationale supporting the estimate, and include it on the project Prospectus Sheet
1. The Project Prospectus Sheet is submitted to the facility's Regional Energy Compliance Officer (RECO).
2. RECO Role:
1. Within 30 days of receiving a Project Prospectus Sheet, a RECO will validate the project described as a legitimate energy compliance project and insure that an appropriate cost estimate is attached to the project
2. The RECO will determine if the project imposes a financial energy liability on Germane Synergy Ltd.
3. Project Prospectus Sheet, cost estimates, and other data pertinent to particular facility's energy compliance projects will be maintained by RECO in project files. A form similar to the project validation checklist is recommended for attachment to the front cover of the file to track quarterly reviews
4. All project determined to be financial energy liabilities shall be subject to the criteria specified on the Energy Project Liability Checklist. The checklist shall be completed by the RECO for each project and maintained with the data specific to that project. All financial energy liability project files shall be distinctively marked to facilitate ease of identification.
5. All environmental project data will then be summarized and submitted by the RECO to ECS headquarters (HQ) for inclusion in the master project list database.
Guidance, "dated January 15, 2011.
4.3.1 HO will maintain Germane Synergy Ltd.'s master project database
4.3.2 HO will validate project submissions by reviewing the submitted data for complete entry. The submitted project will be compared to other projects submitted for the same facility to ensure that it represents work not previously described.
4.3.3 HO will assign project numbers to all validated submissions and update the master project database accordingly.
4.3.4 HO will be responsible for coordinating complete reconciliation of the master project database and any lists, or other information held in the field, and for using the project data in supporting the annual budget submission
4.4.1 Health or Safety Threats: If a "discovered" energy project presents an immediate threat to the health or safety of individuals or to the environment, the process of Project Prospectus Sheet preparation, cost estimate preparation, project validation, and entry onto Germane Synergy Ltd master project list database shall be expedited such that the entire process is completed in less than 15 days.
4.4.2 End-of-Year Discoveries:
126.96.36.199 During the last 60 days of the fiscal year, any "discovery" of an unfunded environmental project shall be considered for its possible inclusion as a financial environmental liability.
188.8.131.52 If the project is determined to be a financial energy liability, a cost estimate will be prepared to determine if it exceeds the Germane Synergy Ltd threshold for accrual.
184.108.40.206 If the financial energy liability exceeds the Germane Synergy Ltd threshold for accrual, the process of Project Prospectus Sheet Preparation, cost estimate preparation, project validation, and entry onto Germane Synergy Ltd master project list database shall be expedited such that any project qualifying for accrual on the annual Germane Synergy Ltd Financial Statement prior to the last 15 days of the fiscal year shall be recognized and properly reported.
4.5 Quarterly Reviews:
4.5.1 Once a project has been included Germane Synergy Ltd master project database of environmental projects, Line Office representatives should review those projects applicable to their facility on a quarterly bases. This review will validate that those projects are still required and that their scope remains accurately presented.
4.5.2 The appropriate RECO will coordinate and assist in this review and validation.
4.5.3 Each will review and update the project list and forms for all projects designated for his or her region of responsibility and forward the result of that review to HO.
4.6 Semiannual Reviews:
4.6.1 On a semiannual basis, the RECO will similarly review and validate the cost estimate and forward the result to HO. For those estimates where there is no change, the RECO shall initial and date the verified cost estimates.
4.6.2 The project list validations of paragraphs 4.4.3 and 4.5.1 will become part of the HO-coordinated master project database reconciliation discussed in paragraph 4.3.3.
4.7 Project Removal or Reduction:
4.7.1 A project is recommended for removal for the master project database when the work has been completed and the receipt of the contracted goods or services has been certified for payment
220.127.116.11 For financial energy liabilities:
18.104.22.168.1 The RECO shall make this recommendation to headquarters immediately upon meeting the criteria of paragraph 4.7.1.
22.214.171.124.2 Recommendations for removal will be validated and completed within 7 days of receipt at HO
126.96.36.199 For other than financial energy liabilities(completion, duplicate entry, overtaken by events, etc.), recommendations for removal will be made by the RECO, validated at HO, and entered on the master project database no less than quarterly.
4.7.2 Large projects may be subject to payment for work progress and may extend over many months or even years. Although such projects are subjects to the requirements to paragraph 4.7.1, the liability imposed by these projects must be reduced periodically to reflect the progress payments made.
188.8.131.52 For all energy liabilities, progress payment shall be reported by the RECO semiannually (in conjunction with cost estimate verification, paragraph 4.6.1), validated at HO, and entered on the master project database.
184.108.40.206 The reduction of an energy project's liability to reflect progress payments shall be carefully coordinated with the servicing finance office to insure that liabilities are not double counted.
220.127.116.11.1 The original liability estimate for a given project number will be reduced by the sum of all accrual and disbursements related to that project number during the reporting period.
18.104.22.168.2 Only the difference between the original liability estimate and the total of the accruals or disbursements made shall be posted on Germane Synergy Ltd.'s annual financial statements.
22.214.171.124 Although reduction of the liability associated with an environmental project prior the certification of successful completion by a regulating agency runs a risk that such certification will not be forthcoming, this risk is considered remote and not necessary for estimating.
4.8 Annual Processes:
4.8.1 At the end of each fiscal year, HO will save and store the validated and updated master database as a separate file for historic reference.
4.8.2 Also at the end of each fiscal year, HO will transfer those projects completed during the year to a separate database comprised only of completed environmental compliance projects.
4.8.3 The validated and updated master database, having had the completed projects removed will form the initial master project database for the new fiscal year.
4.8.4 At the end of each fiscal year, HO will provide summary Germane Synergy Ltd.'s financial environmental liabilities to Germane Synergy Ltd.'s Chief Financial Officer/Chief Administrative Officer. Any disclosures necessary to clarify the financial energy liabilities will be coordinated by HO.
4.8.5 The master database, as supplemented with information provided by the RECOs, will be used to generate Germane Synergy Ltd.'s annual submission.
4.9 Database Protocol:
4.9.1 The master project database maintained by HO is the only authorized listing of Germane Synergy Ltd energy compliance projects.
4.9.2 Other specially tailored databases are permissible at the RECO or line office designee level, but they MUST match exactly the energy projects contained on the master project database for the region or facility.
4.9.3 Any differences in project listings must be either reconciled for inclusions on or removal from the master project database, or removed from or added to the tailored database.
4.10 Control: The point of contact for the Germane Synergy Ltd energy project management shall be the Deputy Chief, Energy Compliance Staff.