Compliance Site Inventory EPAS Program Overhaul November 2017

Implementation of the Compliance Site Inventory What can a CSI do for you? Assist in developing your pre-assessment site visit questionnaire Provide data to support more funding and more environmental staff Quantify information for programs and at facilities Provide continuity for personnel turnover If you know what’s going on at your facility, it will help you streamline your site visit and be more efficient during your EPAS.

CSIs and EMS… Emphasize that we are not trying to set up an actual EMS. This is merely intended to set up a framework for management. This makes good and logical business sense. EMS-type language is embedded within program requirements in AR 200-1.

EMS Policy (4.2) (AR 200-1, Chapter 2) Management’s commitment to personnel detailing intentions and overall direction for environmental performance Policy contains commitments to: Pollution prevention Regulatory compliance Continual improvement

Army Environmental Policy Statement Item a. develop and implement Pollution prevention and control strategies… Item a. establish environmental priorities in consideration of the benefits to the sustainment of missions and operations. Item b. strive to achieve continual improvement… Item c. ensure the policy is implemented, maintained, and communicated to all… employees

CSI vs. EMS CSI: Identifies documented information, responsibilities, operational controls, and monitoring and measurement to help minimize risks from legal requirements EMS: Identifies documented information, responsibilities, operational controls, and monitoring and measurement to help minimize risks from significant aspects and legal requirements Biggest difference? EMS formalizes the process for assessing environmental impacts (or risks) that may be directly regulated Example: Encroachment

Relationship Between Environmental Aspects and Impacts Vapor Emissions to Air Diminished Air Quality Discharges to Waterways Diminished Water Quality Solid and Other Wastes Increased Landfills Use of Electricity Diminished Natural Resources Outdoor Lighting Diminished Night Viewing

Environmental Aspects and Impacts Some aspects may have positive impact Recycling Decontamination/remediation Use of recycled materials Water treatment prior to discharge Removing contaminants from air

How Do I Recognize An Aspect? Solvent Cleaning Process Clean Parts Air Emissions Solvents Dirty Solvent Waste Solvent- Contaminated Rags

I Work In An Office−How Does This Apply To Me? Office Work Outbox Electricity, Paper, Light, Heating, Cooling Toner Cartridges Waste Paper, Solid Waste Inbox

Significant Environmental Aspects ISO 14001 requires organizations to “determine those aspects that have or can have significant impact(s) on the environment (i.e., significant environmental aspects).” ISO 14001 requires organizations to “ensure that the significant environmental aspects are taken into account in establishing, implementing and maintaining its environmental management system.”

Determining Significant Environmental Aspects No requirement as to the “How?” Group discussion How would you determine significance? What factors would you consider?

Determining Significant Environmental Aspects Most common method is scoring aspects based on criteria Is it regulated? Mission impact severity Risk associated with non-compliance Probability of occurrence Cost Probability of public complaints Return on investment Discuss here how the CSI can help prepare the desktop audit prior to the EPAS. Since environmental does not have “real property” to connect to funding needs, you need to establish the baseline for the “risks” associated with each facility.

Determining Significant Environmental Aspects and Impacts Activity Aspect Impact Occurrence Severity Duration Total Priority GROUP ACTIVITY Charlotte to lead this?

Compliance Site Inventory (CSI) Aspects can include: Wastewater Air emissions Solid waste Hazardous waste Water consumption Stormwater discharge Impacts can include: Water quality Air quality Excess noise Depletion of landfill space Depletion of resources

Legal and Other Requirements (4.3.2) The organization is responsible for: The adequacy and the accurate determination of the EMS in terms of protection of environmental health and safety The adequacy of the EMS in preventing, reducing, or eliminating significant environmental impacts Compliance with legal requirements must be periodically evaluated Must have access to legal and regulatory requirements to which it subscribes

Legal and Other Requirements (4.3.2) U.S. TEAM Guide (Federal requirements) State Supplements All Army Supplement U.S. Army Reserve Supplement Internet Resources RegScan (subscription required) AR 200-1: Each Chapter Includes Policy Legal and other requirements Major program goals Program requirements AR 200-1: Chapter 4 - Environmental Asset Management Air resources Water resources Land resources Chapter 5 – Pest Management Chapter 6 – Cultural Resources Chapter 7 – Pollution Prevention Chapter 9 – Materials Management Hazardous Materials Toxic Substances Chapter 10 – Waste Management Hazardous Waste Solid Waste Chapter 11 – Storage Tank Systems/Oil and Hazardous Substances Spills Chapter 12 – Environmental Cleanup Chapter 13 – Environmental Quality Technology Chapter 14 – Operational Noise

Legal and Other Requirements (4.3.2) Group discussion How do you keep up to date on legal and other requirements?

How to Prepare a CSI

CSIs Identify Gaps in Program Data Review facility documentation/information and audit reports Interview facility personnel Discuss program-specifics with Program Managers Existing processes with the intent of minimizing re-work and maximizing efficiencies Covers not only auditing aspect but mgmt aspect for when plans need to be updated etc. Collect quantitative and/or qualitative data on the characteristics of its activities (vehicle maintenance) products (haz) and services such as inputs and outputs of materials or energy, processes and technology used, facilities and locations, transportation methods and human factors

CSIs Support Risk Management Identify features that may have significant environmental aspects and impacts Identify legal requirements Identify actions around significant aspects and impacts and legal requirements Identify key performance indicators around significant impacts and legal requirements Goal: Understand your risk areas and how best to manage them Aspects can help you understand the

Identify Requirements for Your Facilities Federal, state/territory, municipal, and DoD environmental regulatory requirements Documenting environmental activities Clearly define how to minimize impacts with appropriate management programs, controls, and measurements

Track Key Environmental Program Measurements HW Generator status Permits associated with the facility (agency, type of permit, expiration date, specific notes associated with the permit) Tanks located at each facility (tank ID, size, type of tank, material stored, manufacturer/serial number/model, status, description) Use 99th CSI and talk through the content.

Track Key Environmental Program Measurements Facility-specific plans applicable at each facility (SPCCP, SWPPP) Div (R)-specific plans (HWMP, ISWMP, IPMP) Required inspections Special sanitary or drinking water systems Oil water separators (location, OWS ID, capacity, description, notes) Parts washers (unit ID, capacity, type of tank, manufacturer/serial number/model, status, description) MVAC certificates Boilers (regulated) EPCRA Use 99th CSI and 81st Environmental Matrix and talk through the content.

CSI Benefits… What is the Point? Preparation – desktop assessment, checklists, and maximizing time in the field Develop a plan for where to go and what to look at (fence line, outdoor storage areas, maintenance shops, office spaces, cages) Develop strategies for records review, level of findings, and assessment documentation Become familiar with plans, permits and procedures before the site visit Standards to be used, regulations to be considered, reporting requirements Timeframe or “look back” period for records and document review Hit the ground running! A failure to plan is a plan for failure! The completed CSI may provide background information necessary to plan and conduct the specific facility visit and facilitate the site assessment activities, including but not limited to HW generator status, applicable permits to the facility, equipment (such as oil/water separators and parts washers) located at the facility, and plans applicable to the facility).

CSI Benefits… Tracking – facility plan updates, permits renewals Communication – coordination with facility staff and HQ Program Managers Planning – Proactively planning actions vs reactive fire drills Understanding of site specific environmental risks Training – understanding specific compliance supports knowing exactly how to train new employees Continuity/turnover – critical information is maintained – points of contact, roles and responsibilities, less time to “relearn” facility compliance status Assessing programmatic roles from a facility perspective Communicating risks with facility/program staff Being proactive rather than reactive Knowing the risks associated with your facilities Training at the facility level to prevent non-compliance issues You have to find ways to become more efficient in every facet of your operations. Without a doubt, the CSI will reduce the amount of time that new personnel spend in learning their new jobs and integrate into their assigned facilities. As a direct by-product of the more rapid integration of new staff, the negative effects of personnel turnover to mission readiness can be greatly minimized.