Colorado Recognized Environmental Professional (CO-REP) Program

Below are our goals for the new CO-REP program. Your commitment to these goals is crucial to its success.

1. Maximize quality of work by encouraging work and submittals (reports, PREQs) for OPS projects that meet OPS published Regulations, Policies, and Guidance.
   1. A CO-REP will be responsible for ensuring all field personnel are trained in proper procedures and practices.
   2. CO-REPs will perform work in accordance with current OPS Regulations, Guidance, and Policies. 
   3. Recognize that when work is not performed in accordance with published Regulations, Guidance, and Policies, this may result in Deficiencies and/or Denial Letters that may  lead to the delisting of a CO-REP (and potentially the Company) from the program.
2. Maintain integrity and public safety by ensuring CO-REPs are engaged in appropriate, risk-based, and cost-effective decision-making at all levels of project development as guided by OPS policy/procedure.
3. Minimize administrative burdens by:
   1. Making the CO-REP approval process less subjective.
   2. Simplifying the CO-REP application and recertification process.
   3. Clarifying and streamlining tracking of items documenting inadequate CO-REP performance.
       

The application process will take a different approach at the company level. Each company that wants to identify CO-REPs within the OPS-Remediation Program must submit a Quality Assurance Plan (QAP). OPS will provide a QAP Template that will follow general EPA Guidelines but has been tailored to fit the needs of the Petroleum Remediation Program.

Once the Company CO-REP application is received by OPS, the process from intake to final approval will be as follows:

1. A company will submit the completed application, which includes a QAP, to OPS. This will be reviewed by an OPS CO-REP review team and approved or disapproved based on the information provided. Items that will cause an application disapproval  are:
   1. A QAP outlining work that is not in accordance with current OPS Regulations, Policies, and Guidance. For example, not outlining proper QA/QC protocol or sampling protocol.
   2. Not identifying personnel within a company with enough experience to be a CO-REP.
   3. The company's CO-REP Lead has not been identified. The CO-REP Lead is a single point of contact for any QAP violations.  OPS recognizes that the CO-REP Lead may not have been responsible for any violations against a Company’s QAP.
   4. Upon approval of the Company CO-REP Application and QAP, all company-identified CO-REPs will take an in-person, proctored, open-book exam. The exam will focus on remediation and fund section topics. Open-book sources will be limited to hard copies of information that the CO-REP brings with them to the test. Computers and other digital media will not be allowed.
       
2. OPS staff reviewing reports and preparing deficiency letters shall demonstrate the same level of competence as CO-REPs.  This includes passing the exam consistent with the existing REP program.
3. Upon passing the exam, a CO-REP will receive an acceptance letter that identifies their CO-REP number. Current REPs will retain their existing number. Additionally, an Acknowledgement Form will be sent to the CO-REP Lead for the Company for signatures from them and all CO-REPs acknowledging the accountability measures within the program, including the possibility of being delisted.
    

To replace the PDHs for recertification:

1. Every three (3) years, every certified CO-REP  will retake an Exam to reset the accountability count. If a CO-REP has no deficiencies, they will not need to take the test.
2. The following may count against a CO-REP as Deficiencies
   1. TCAR Denials
   2. SCR Deficiency Letters
   3. CAP/CAP Mod Denial Letters
   4. MRR Deficiency Letters
   5. NFA Denial Letters - With deficiencies noted
   6. RAP Issues (that pertain to the CO-REP; OPS recognizes that sometimes the Applicant or a third party may prepare these)
   7. Other issues documented by OPS as violations against a company's approved QAP.
   8. OPS documented ethics issues documented against individuals and/or lodged against companies.
       

1. Our COSTIS IA Database will track accountability based on the above deficiency letters and violations against the company QAP. Delisting of an individual CO-REP or QAP Company can occur with the following infractions:
2. The following may result in delisting from the CO-REP Program:
   1. Receiving a combination of deficiency letters that total three in a 12-month period in the following categories:  
      • TCAR Denials 
      • SCR Deficiency Letters 
      • CAP/CAP Mod Denial Letters 
      • MRR Deficiency Letters 
      • NFA Denial Letters - With deficiencies noted
   2. Receiving four (4) deficient issues when the CO-REP is responsible for the RAP Preparation within a three-year period:
      • RAP Issues (that pertain to the CO-REP; OPS is aware that sometimes the Applicant or third party may prepare these)
   3. The following may result in an immediate delisting and could result in the delisting of a company (see No. 3):
      • Other issues documented by OPS as violations against a company's approved QAP.
      • OPS documented ethics issues documented against individuals and/or lodged against companies.
   4. Deficiency Letters may be appealed by writing to the Petroleum Remediation & Storage Tank Fund Supervisor for an opinion on the deficiency that was issued. A discussion can also be held to discuss the specifics of the deficiency that was issued.
   5. Violating the approved QAP can delist the entire Company. One (1) warning letter will be issued. If a second violation against an approved QAP occurs within one year of the first violation, it will be followed by a 365-day suspension from the date of the second violation. If another violation occurs after the suspension, the Company will be delisted.  
3. Before delisting a CO-REP individual or Company, OPS will prepare a statement of infringements and allow up to seven (7) business days for the Review Committee identified by the CO-REP Peer Group to review and submit comments to OPS.  OPS may consider these comments when deciding to delist a Company.  The OPS Division Director, Petroleum Program Manager, and Petroleum Remediation & Storage Tank Fund Supervisor will finalize and convey the decision to the party in question.
4. Every three (3) years, the accountability count will be reset upon a passing retest. As OPS has done in the past, all CO-REPs will be put on the same 3-year testing schedule to minimize the administrative burden.
    

OPS desires to continue collaborative communication with CO-REPs. To foster varying participation, we propose that this peer group consist of five (5) individuals who will rotate off of it every three (3) years at the time of the retest. There can never be more than one (1) individual from a single company at any given time. Responsibilities of the CO-REP Peer Group include but are not limited to:

1. Identify a Chair and Co-Chair;
2. Develop a Review Committee responsible for reviewing potential Delisting of CO-REP Individual Certifications for deficiencies and Company for Violations consisting of three (3) individuals.  This committee should be free of conflicts of interest;
3. Maintain communication with all CO-REPs at large regarding communications with OPS;
4. Gather feedback from CO-REPs at large to bring to OPS for discussion during quarterly meetings;
5. Maintain communication with third-party stakeholders (e.g., labs, drillers, etc.) and bring concerns, issues, etc. to OPS.