1. Compliance Site Inventory
EPAS Program Overhaul
November 2017

2. 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.

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

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

10. 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

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

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

13. 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.

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

15. 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

16. 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

17. 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

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

19. How to Prepare a CSI

20. 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

21. 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

22. 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

23. 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.

24. 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.

25. 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).

26. 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.