kristendickey_bio
 

Quote To Live By: “I’ve learned that people will forget what you said, people will forget what you did, but people will never forget how you made them feel.” – Maya Angelou

EXPERTISE:

  • Due Diligence/Transaction Services
  • Environmental Compliance Auditing
  • Environmental Compliance Support
  • Environmental Audit Program Management
  • Hazardous Materials Compliance

  • Full Profile

    Kristen is a CPEA with over 18 years of experience managing environmental, health and safety (EHS) due diligence and compliance projects.  She has worked with private industry clients across the manufacturing, energy, commercial and financial sectors.  Kristen has an outstanding rapport with clients and regulatory agencies as she has managed skilled compliance teams of technical staff in the US and globally. Her expertise includes preparation and review of technical reports including audits, Phase Is, due diligence reports, and liability cost estimates. A client advocate, Kristen is known for meeting project deadlines and effectively managing project budgets and financial goals.

    EDUCATION

    • BS, Environmental Science, Allegheny College, Meadville, Pennsylvania, 1998

    CERTIFICATIONS & TRAINING

    • ASTM E 1527 -13, Environmental Professional
    • Certified Professional Environmental Professional Auditor (CPEA)
    • U.S. Department of Transportation Hazardous Materials Handling Training, 2005- Current
    • International Air Transport Association Dangerous Goods Training by Air, 2006-Current
    • OSHA 40-Hour HAZWOPER Training with OSHA 8-Hour Supervisory Training, 1998-Current
    • 2-Hour Asbestos Awareness Training, 2006
    • First Aid and CPR Certified, 1998-Current
    • McCoy RCRA 40-Hour Training Seminar, 2000

    KEY EXPERIENCE

    Private Equity Firm
    Project Manager – Due Diligence

    For a private equity firm, project manager for the completion of due diligence for various divestitures and acquisitions of companies including industrial, oil and gas, and food and beverage operations.  The standard scope of work included the completion of desktop environmental due diligence and the complete of ASTM E 1527-13 compliant Phase I environmental site assessments with the preparation of liability cost estimates for land contamination and compliance issues of concern.  Recent project examples included environmental, health and safety due diligence in support of an acquisition of portfolio of natural gas compression stations in the Central US/Rocky Mountain region and the sale of a paper product manufacturing organization in North America.  Often, due diligence findings were used to assist client in the post-divestiture or post-acquisition integration process for EHS related matters.

    Global Financial Organization
    Client Manager – Environmental Services

    Client Manager for a multinational Fortune 500 organization. Provided ongoing environmental, health and safety due diligence services to the organization’s internal environmental risk management team for transactions worldwide.  The due diligence services included intensive desktop studies and Phase I environmental site assessments worldwide.  Each project deliverables included a detailed summary of environmental liabilities with associated costs; the completion of a Company risk assessment questionnaire; and presentation to the deal team comprised of Company financial and environmental advisors through face-to-face meetings and telephone conferences with key findings.  In addition to the traditional ASTME 1527-13 Phase I environmental site assessment scope of work, the client typically required a review of environmental resource impacts, social impacts, client change impacts, and other aspects.  Portfolios included oil and gas, renewable energy, industrial properties, Brownfields sites, and commercial properties.  Additional services included remediation under state regulatory programs for soil and groundwater impacted with chlorinated solvents and PCBs at client-owned sites in California and New Jersey as well as indoor air quality monitoring at commercial sites in the organization’s portfolio.

    Steel Mill
    Compliance Support

    Provided environmental, health, safety and U.S. Department of Transportation Hazardous Materials training for approximately 1,000 employees over three work shifts in various plants for an active steel mill in Colorado.  The training incorporated site-specific policies and procedures as well as state and federal EHS and hazardous materials regulations.  The training was conducted semi-annually.

    Global Manufacturer of Commercial and Residential Building Materials
    Hazardous Materials Compliance Support

    Served as client manager for this Denver-based, third-party Department of Transportation Hazardous Materials compliance audit program.  Kristen’s involvement included the completion of a baseline hazardous materials compliance gap analysis at the corporate headquarters, a corporate research and development center, and various manufacturing locations in the U.S.  The gap analysis was reviewed with corporate legal counsel and corporate EHS managers to determine appropriate corrective actions.  The scope of work included training, program development, assistance with the preparation of hazardous materials shipping papers, and annual third-party audits.  As a follow on scope of work, the company requested annual third-party audits included evaluations of multi-modal compliance (i.e., ground, rail, water, and air) at its manufacturing sites in the U.S.

    Aircraft Parts Manufacturer
    Compliance and Management Systems Support

    The scope of the project included the development of a comprehensive environmental compliance management system starting from the ground level for an active aircraft parts manufacturing facility with operations in Michigan.  Kristen developed compliance manuals, training materials, and prepared environmental plans and reports including a Resource Conservation and Recovery Act Contingency (RCRA) and Emergency Preparedness and Prevention Plan and supporting documents; a combined Spill Prevention Control and Countermeasure (SPCC) and Michigan Department of Environmental Protection (MDEQ) Pollution Incident Prevention Plan (PIPP); and others.  She was responsible for the preparation of the reports and supporting calculations under the Superfund Amendments and Reauthorization Act (SARA) including Tier Twos and Form Rs.  Various training modules were developed for each regulatory media including RCRA, SARA, Spill Prevention, and Clean Air Act.  Kristen worked closely with the facility’s environmental team to train them in the relevant topics and management systems such that the environmental manager eventually self-sustained the program, saving the organization consulting fees in the long-term.

    Confidential Environmental Engineering Firm
    Hazardous Waste and Hazardous Materials Compliance Support – Superfund Site

    For a Superfund site in Colorado, on behalf of a confidential environmental engineering firm, the scope of work included the completion of an annual site inspection and document review to ensure hazardous waste management practices met the requirements of the site-specific RCRA Waste Management Plan.  Additionally, Kristen conducted the annual hazardous waste and U.S. Department of Transportation Hazardous Materials training for site employees who were responsible for the onsite remediation activities.

    Large Cheese Manufacturing plant– New Mexico
    Due Diligence

    Retained through a buyer’s legal counsel, the scope of work included a Phase I environmental site assessment and environmental compliance review for a potential buyer of a large cheese manufacturing facility in New Mexico.  The compliance review included an in depth assessment of onsite wastewater treatment facility operations and compliance with National Pollutant Discharge Elimination System requirements for its wastewater discharges and other aspects of the Clean Water Act.  Additionally, the scope of work included a review of solid and hazardous waste management practices under the Resource Conservation and Recovery Act, chemical report under the Superfund Amendments and Reauthorization Act, and compliance with the Clean Air Act, Toxic Substances Control Act, Federal Insecticide, Fungicide, and Rodenticide Act, and CFATS.  The Phase I environmental site assessment and summary of compliance matters were used by the client to understand the environmental risks in the purchase process.

    West Virginia Underground Storage Tank Fund
    Claims Management

    Provided insurance claims management for the West Virginia Division of Environmental Protection Petroleum Underground Storage Tank Insurance Fund.  The purpose of the project was to ensure that approximately 250 tank owners located throughout the state, achieved compliance with state and federal UST regulations, and in the event of a release, that the tank owners received funds to properly remediate any contaminated soil or groundwater.  During the course of the project, responsibilities included the completion of site inspections, processing insurance claims, tracking insurance accounts, reviewing insurance policies, as well as the preparation of a monthly deliverable to the WVDEP, which included insurance coverage recommendations, an insurance account balance sheet, and a summary of the month’s claims activities.

    Confidential Global Electronics Manufacturer
    Third-Party Environmental Compliance Audits

    Working with the firm’s legal counsel, Kristen conducted third-party environmental compliance and management systems audits covering RCRA, SARA, Clean Air Act, Clean Water Act, Toxic Substances Control Act, CFATS, and U.S. Department of Transportation Hazardous Materials requirements for a global electronics manufacturer.  Audits were conducted at numerous manufacturing sites throughout the U.S. including Arkansas, California, Colorado, Florida, Minnesota, New York, Texas, and others.  The project deliverable consisted of a narrative compliance audit report with a summary of findings, industry practices, and recommended corrective actions.  In addition, the client was provided with further compliance-related services including authoring articles for internal compliance newsletters; preparation and presentation of training webinars on emerging regulatory topics; and ongoing compliance support on remediation projects for waste management and DOT hazmat compliance.

    Confidential Client
    Due Diligence

    Completed environmental due diligence consisting of single ASTM E 1527-13 Phase I environmental site assessments with compliance and portfolio due diligence of industrial operations worldwide.  Findings used to quantify risk associated with each transaction.

    Confidential Client
    Third-Party E-Waste Audits

    Kristen served as the client manager for a third-party electronic waste audit program for a Fortune 500 multinational manufacturer of consumer electronics.  Responsibilities included the oversite and technical support for third-party audits of electronic waste vendors compared to the U.S. Environmental Protection Agency’s e-Stewards and R2 recycling standards as well as corporate sustainability criteria.  The waste vendors were located in Europe, the UK, Africa, India, and Asia.  The deliverable included a narrative summary of each site’s operations; the environmental, health and safety compliance and management systems programs; and their compliance with local, regional and international regulations and management standards including ISO 18001, ISO 9001, R2, e-Stewards, Basal Convention, IPPC Directive, WEEE, and others.  Findings were uploaded to the company’s internal database for tracking and risk evaluations.  Audits were conducted annually.

    Confidential Client
    Third-Party Compliance Audits for Beverage Manufacturer

    Conducted third-party environmental compliance audits of manufacturing and distribution sites for a global beverage manufacturer at sites in California and Kansas.  Compliance audits included the evaluation of each site for compliance with RCRA, SARA, Clean Water Act, Clean Air Act, DOT hazardous materials, and TSCA.  The project deliverable included the preparation of a narrative report with a description of the site operations, a legal register with all local, state, and federal regulations applicable to the site, and a summary of findings and recommendations.  The findings were used by the Corporate Environmental Management Team to track trends and to systematically address compliance matters across the organization.

    Confidential Client
    Air Compliance Support for Food and Beverage Company

    Provided compliance support for a food and beverage company under the California Air Resource Board (CARB)’s regulations for Transport Refrigeration Units (TRUs).  Evaluated applicability of the rule and reporting requirements for the company’s refrigerated fleet vehicles and distribution centers throughout California.  The deliverable included a summary of the applicability of the rule to the company’s facilities and the preparation of reporting forms, where applicable, for the CARB.  Compliance support helped the facilities understand and stay ahead of the emerging and evolving rule.

    Confidential Client
    Third-Party Audits under Department of Justice Consent Order

    Conducted third-party environmental compliance audits at chemical manufacturing plants in Illinois under the direction and supervision of the U.S. Environmental Protection Agency per a Department of Justice Consent Order.  The deliverable included the preparation of a narrative audit report with a summary of findings.  The audit findings were presented to EPA as part of negotiation of company’s environmental penalties under the Consent Order.

    PUBLICATIONS AND PRESENTATIONS

    Publications

    • Data Centers: Common Environmental, Safety, and Fire Protection Challenges and a Look at Emerging Energy Issues Environmental Quality Management, 2010
    • EPA’s Partnerships with Industry:  A More Sustainable Approach.  Environmental Quality Management, 2006
    • Due Diligence and Environmental Site Assessments:  Impact of EPA’s Upcoming “All Appropriate Inquiry” Rule Changes to the Phase I standard.   Environmental Quality Management, 2004

    Presentations

    • Managing the Risk of Hazardous Materials Compliance: Where’s the “T” [Transportation] in EHS&S, Webinar for the NAEM, April 7, 2016
    • Environmental Diligence 101 and the New ASTM Standard for Phase I Environmental Site Assessments, WSP | Parsons Brinckerhoff and McClister Law, LLC, to the Society of Women Environmental Professionals, Rocky Mountain Chapter, December 2013