Compliance Site Inventory EPAS Program Overhaul November 2017

Compliance Site Inventory EPAS Program Overhaul November 2017 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 1

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 2

CSIs and EMS… UNCLASSIFIED / FOUO Leadership. Energy. Execution. 3

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 4

Army Environmental Policy Statement UNCLASSIFIED / FOUO Leadership. Energy. Execution. 5

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 6

Relationship Between Environmental Aspects and Impacts Aspect UNCLASSIFIED / FOUO Impact 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 Leadership. Energy. Execution. 7

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 8

How Do I Recognize An Aspect? Solvents Dirty Parts Solvent Cleaning Process Dirty Solvent Waste UNCLASSIFIED / FOUO Leadership. Energy. Execution. Air Emissions Clean Parts Solvent. Contaminated Rags 9

I Work In An Office−How Does This Apply To Me? Electricity, Paper, Light, Heating, Cooling Inbox Office Work Toner Cartridges UNCLASSIFIED / FOUO Leadership. Energy. Execution. Outbox Waste Paper, Solid Waste 10

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. ” UNCLASSIFIED / FOUO Leadership. Energy. Execution. 11

Determining Significant Environmental Aspects • No requirement as to the “How? ” • Group discussion – How would you determine significance? – What factors would you consider? UNCLASSIFIED / FOUO Leadership. Energy. Execution. 12

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 13

Priority Total Impact Duration Aspect Severity Activity Occurrence Determining Significant Environmental Aspects and Impacts GROUP ACTIVITY UNCLASSIFIED / FOUO Leadership. Energy. Execution. 14

Compliance Site Inventory (CSI) • Aspects can include: – Wastewater – Air emissions – Solid waste – Hazardous waste – Water consumption – Stormwater discharge UNCLASSIFIED / FOUO • Impacts can include: – Water quality – Air quality – Excess noise – Depletion of landfill space – Depletion of resources Leadership. Energy. Execution. 15

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 16

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 Reg. Scan (subscription required) AR 200 -1: Each Chapter Includes – Policy – Legal and other requirements – Major program goals – Program requirements UNCLASSIFIED / FOUO Leadership. Energy. Execution. 17

Legal and Other Requirements (4. 3. 2) • Group discussion – How do you keep up to date on legal and other requirements? UNCLASSIFIED / FOUO Leadership. Energy. Execution. 18

How to Prepare a CSI UNCLASSIFIED / FOUO Leadership. Energy. Execution. 19

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 20

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 21

Identify Requirements for Your Facilities • Identify requirements for your facilities • Federal, state/territory, municipal, and Do. D environmental regulatory requirements • Documenting environmental activities • Clearly define how to minimize impacts with appropriate management programs, controls, and measurements UNCLASSIFIED / FOUO Leadership. Energy. Execution. 22

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) UNCLASSIFIED / FOUO Leadership. Energy. Execution. 23

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 24

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! UNCLASSIFIED / FOUO Leadership. Energy. Execution. 25

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 UNCLASSIFIED / FOUO Leadership. Energy. Execution. 26