EPAS Findings Log Q40.xlsx
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- Solicitation number
- 19R0069
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This is a request for proposal for the operation and maintenance of Hawthorne Army Depot from fiscal year 2021 through 2030. The services required include base operations support, safety, security, and demilitarization activities. A best value tradeoff source selection will be used to award a firm-fixed-price contract consisting of a base period and five option periods, as well as two additional evaluated option periods. Technical data packages were posted in July and August 2019 applicable to demilitarization requirements. Questions regarding this solicitation must be submitted by January 6, 2020 to the procuring contracting officer and contract specialist listed. An industry day will be held January 14-15, 2020 to discuss the requirement further.
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| Finding Number | Class | Repeat/ Carryover | CARM Number | Finding Summary | Person to Correct Finding | Environmental Services Contact | EMS Status | Finding Corrective Action/ Immediate Fix | Root Cause Corrective Action/ | ||||||||
| Permanent Fix | Estimated completion date | Progress | Close date | Scorecard Section | Who? | ICAP Status | WEBCASS | WEBCASS IP | WEBCASS Ready | WEBCASS Closed | Total Open | Total Closed | SOC Open | SOC Closed | AMC Comment | Cardno Questions/Comments | WEBCASS ICAP Info, 19 June 2019 |
| AE_HWAD17-E-001 | I | No | ENV-17-035 | Air emissions permit conditions are not fully met with respect to fuel consumption and operational hours reported for emergency generators. |
1) Monitor and record the fuel consumption rate of #2 diesel (also propane) fuel as measured by the fuel flow meter on a daily basis when operated.
2) Monitor and record the hours of operation of S2.050 (also S2.051, S2.052, S2.053, S2.054, S2.055) while burning #2 (propane) diesel fuel on a daily basis when operated. Foster Kenton and Jeff Matheny, SOC Air Program Managers Foster Kenton and Jeff Matheny, SOC Air Program Managers Closed Finding Corrective Action. Report actual fuel consumption rates and hours of operation in accordance with the Operating Permit conditions. /$0 The Mechanic assigned to maintain the permitted generators records and reports the actual fuel consumption rates and hours of operation to the Air Program Manager IAW the work order generated for the preventative maintenance of the generator. The Air Program Manger used these numbers to calculate emissions IAW Permit requirements. The records of fuel use and hours are filed in the Environmental Services Library, available for review by Environmental personnel. Root Cause Corrective Action. Report actual fuel consumption rates and hours of operation in accordance with the Operating Permit conditions. Obtain written documentation of the NDEP directive before Deviating from Permit requirements $/0 The Air Program Manger used the actual fuel consumption rates and hours of operation to calculate emissions IAW Permit requirements for 2017. NDEP declined to provide written guidance for reporting contrary to the Permit requirements, and accepted the actual emissions. If the situation ever arises again, written documentation of the NDEP directive will be obtained BEFORE deviating from permit requirements. 1) 15 March 2018, Due date of Next Actual Emissions Report
2) February 2018, during drafting of Actual Emissions Report
2) Submit Capital Request for 2018 10/9 - Rebekah is drafting an official request for guidance to NDEP on this issue.
11/7-Actual Fuel and hours are being recorded, Draft Letter in review.
1/22/18- Actual emissins Report is being drafted 1/29 - No Change, Report Due March 1
| 2/27- Report submitted | 27-Feb-18 | 1.3 Clean Air Act Section 602 (a) & (b) | SOC | In Progress | Ready to close 4/19/2018 | 1 | 1 | 1 | If you have email traffic on the email to NDEP showing you asked, please upload that. You can print it out and put a note on it that they did not respond with a date and the name of the person documenting this action at HWAD/SOC - and then scan that in and upload to WEBCASS with the comments you provided, that would be good for closure action and show proof of effort. Other documents uploaded look good. If you can show proof of trying to contract NDEP with no response (as mentioned above), then, if JMC doesn't see any other issues, the finding is ready to close after that is uploaded. Thanks! Halstead | Concur with AMC reviewer | Finding closed in WEBCASS by HWAD personnel; did not address comments by Julie Halstead (no email traffic with NDEP). | ||||
| AE_HWAD17-E-002 | I | Yes / Carryover | ENV-17-036 | Air emissions permit conditions are not fully met with respect to changing oil and filters on emergency diesel generators. | Denis Bunch, Assist Manager, Fleet Manager and Equipment Repair | Foster Kenton and Jeff Matheny, SOC Air Program Managers | Closed | Finding Corrective Action. Change oil and filters on emergency diesel generators every 500 hours of operation or annually, whichever comes first, in accordance with Operating Permit conditions. /$0 The Preventative Maintenance Work Order states that the Mechanic assigned to maintain the permitted generators will change oil and filters on emergency diesel generators every 500 hours of operation or annually, whichever comes first, in accordance with Operating Permit conditions. The Mechanic completes and certifies as completed all steps on the Work order. The Mechanic is trained on an annual basis for the importance of the requirement. | Root Cause Corrective Action. Fully implement the SOC Work Order for Annual Generator PM, to include the change of oil and filters on emergency diesel generators. Conduct periodic reviews to verify that the SOC Work Order requirements are understood and met. /$0 The Fleet Manager conducted Monthly quality checks on PM work orders, The Environmental Manger obtained copies of the PM Work orders and submitted them to the ACO Environmental Protection Specialist for review IAW Letter of Concern Response. These Work Orders are filed in the Environmental Services Record Library. The Environmental Manager will continue to perform quality checks and monthly training of the mechanics will continue. | 17-Aug-17 | 9/27 -PM Work orders updated, awaiting copy |
10/24 - sample on file,
| 12/13- awaiting completed work order for upload, expected End of January | 25-Oct-17 | 1.3 Clean Air Act Section 602 (a) & (b) | SOC | In Progress | Ready to close 4/19/2018 | 1 | 1 | 1 | The CARM forms are done well. This one looks good to close if JMC does not have any other comments. Thanks! Halstead | Concur with AMC reviewer | Finding closed in WEBCASS by HWAD personnel. Concur that the finding is closed. | ||||
| AE_HWAD17-E-003 | III | Yes / Carryover | ENV-17-049 | Plans to eliminate dependency on commercial acquisition of Class I ODS have not been established. | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Closed | Finding Corrective Action. Develop an ODS elimination plan in accordance with Army Regulation (AR) 200-1. /$0 The Air Program Manger, with the help of the Air Conditioning Technician , The Equipment Mechanics Supervisor, and the Facility Manager, developed an ODS elimination plan in accordance with Army Regulation (AR) 200-1. | Root Cause Corrective Action. Ensure corrective actions selected with respect to identified compliance deficiencies completely resolve the deficiency and are implemented in a timely manner. /$0The ODS Elimination Plan is a controlled document under the Environmental Management plan, and owned by the Air Program Manager. It will have annual review in which the Air Program Manger, the Air Conditioning Technician , The Equipment Mechanics Supervisor, and the Facility Manager are required to sign that they have reviewed and approved the document. See attached ODS Management Plan | 30-Dec-17 | 8/30- Draft ODS Plan with Mechanics for review. |
10/23 - Combining Leak detection with ODS Elimination Plan.
11/7 - Draft in review.
12/18 - Plan out for signature.
| 1/22/18 - Plan with Government staff for signature | 23-Jan-18 | NA | SOC | In Progress | Ready to close 4/19/2018 | 1 | 1 | 1 | Please have JMC go through this one - lots of detail to go through | The finding deficiency appears to have been completely addressed with the development of QP BOP ENV 0013 ODS Management Plan; however, recommend that Section 4.2 (Site ODS Coordinator Responsibilities), part 4.2.3 be revised to clarify that maintaining the list of refrigeration equipment includes completing the table in Appendix F to include the amount and type of refrigerant in the listed equipment. Also, the root cause was lack of attention to previous findings to prevent repeats. It appears that root cause corrective actions for other repeat findings include the CARM report; suggest using the same information as provided for AE_HWAD17-004 in this response. | Finding closed in WEBCASS by HWAD personnel; however, comments have not been addressed. | |||||||||||
| AE_HWAD17-E-004 | I | Yes / Repeat | ENV-17-037 | Air emissions permit conditions are not fully met with respect to annual compliance certification. | Foster Kenton and Jeff Matheny, SOC Air Program Managers | Foster Kenton and Jeff Matheny, SOC Air Program Managers | Closed | Finding Corrective Action. Conduct a comprehensive review of the operating permit conditions and the annual compliance certification and update as needed to ensure the certification addresses all conditions of the operating permit. Report the deviation from the operating permit in accordance with Section V.C of the permit. /$0. The Air Program Manager and the Environmental Manager conducted a comprehensive review of the operating permit conditions and the annual compliance certification and update as needed to ensure the certification addresses all conditions of the operating permit | Root Cause Corrective Action. Ensure corrective and preventive actions for previously identified compliance deficiencies are implemented in a timely manner to prevent reoccurrence. /$0. Future Changes to Laws and Permits are tracked by the Environmental Management System with the same process used for Non-conformances. The transfer of Programs is tracked by the Environmental Management system with the same Process used for Non-conformances. The Responsibilities are defined at the time if the issuance of the Corrective Action Risk Management Analysis (CARMA) Quality Assurance Document. | 1-Mar-18 | 10/9 - Rebekah is drafting an official request for guidance to NDEP on this issue. 11/7- Draft Letter in Review 12/13, Jeff M updated template, Close finding Report for upload | 13-Dec-17 | 1.3 Clean Air Act Section 602 (a) & (b) | SOC | In Progress | Ready to close 4/19/2018 | 1 | 1 | 1 | Can't determine whether the initial deficiency has been addressed. The CARM uploaded for WEBCASS mentions that all of the compliance requirements have been included in a spreadsheet developed by Kristi Lammel-Schilling, but that spreadsheet has not been uploaded to WEBCASS. In addition, the 2017 Compliance Certification uploaded to WEBCASS is a template form and has not been completed with all the data required in the permit. | Finding closed in WEBCASS by HWAD personnel; however, comments have not been addressed. | |
| AE_HWAD17-E-005 | I | No | ENV-17-066 | Air emissions permit conditions for the Mobile Mercury Transfer System (MMTS) are not fully met with respect to weekly visible emission inspections. | Rob Mathias, DLA Depot Manager | Foster Kenton and Jeff Matheny, SOC Air Program Managers | Closed | Finding Corrective Action. Conduct and record weekly visible emission inspections on the MMTS Emission Unit S2.002 in accordance with the Operating Permit to Construct. /$0 SOC Environmental Services conducts and records weekly visible emission inspections on the MMTS Emission Unit S2.002 in accordance with the Operating Permit to Construct. Copies of these records are submitted to the ACO Environmental Protection Specialist for review IAW Letter of Concern Response. Copies of these records are filed in the Environmental Services Record Library. | Root Cause Corrective Action. Improve oversight of tenant activities at HWAD with respect to compliance with the Operating Permit to Construct and ensure all permit conditions are being addressed either by tenant personnel or SOC Environmental Services Office personnel. /$0 Copies of the weekly visible emission inspections are submitted to the ACO Environmental Protection Specialist for review IAW Letter of Concern Response on a monthly basis, which is a contract requirement. The responsibilities for weekly visible emission are assigned to SOC Environmental Personnel who have been trained in Method 9, and will be reviewed as a part of Internal EPAS Inspections by Government Staff (annual), Future EMS audits by SOC Management System Auditors (annual), and in Environmental Compliance inspections by Environmental Personnel (as needed). The results of these reviews will be analyzed and corrective actions will be issued IAW established EMS Processes. | |||||||||||||
| 15-Nov-17 | 9/18 - Receiving emails from DLA, Rebekah is doing Smoke readings | |||||||||||||||||||||
| 10/9 - Noah is signed up for Smoke school, scheduled end of October. | 25-Oct-17 | 1.3 Clean Air Act Section 602 (a) & (b) | DLA | In Progress | Ready to close 11/7/2017 | 1 | 1 | The original deficiency appears to have been addressed; however, need additional documentation for upload to WEBCASS. The current CARM shows a record for only one inspection conducted in mid-January 2018. Please provide records showing that the required weekly inspections were conducted during 2018 (suggest a file showing at least 3 months of inspections). The root cause appears to have been sufficiently addressed through EMS/compliance auditing mechanisms in place at HWAD. | Finding closed in WEBCASS by HWAD personnel; additional documentation provided as requested. Concur that the finding is closed. | |||||||||||||
| AE_HWAD17-E-006 | MP | NA | ENV-17-064 | Risk reduction for air emissions management. Recommend maintaining refrigerant leak rate data for all units containing in excess of 50 pounds of Class II refrigerants. | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Closed | Develop an ODS elimination plan in accordance with Army Regulation (AR) 200-1.The Air Program Manger, with the help of the Air Conditioning Technician , The Equipment Mechanics Supervisor, and the Facility Manager, developed an ODS elimination plan in accordance with Army Regulation (AR) 200-1.Ensure corrective actions selected with respect to identified compliance deficiencies completely resolve the deficiency and are implemented in a timely manner. /$0The ODS Elimination Plan is a controlled document under the Environmental Management plan, and owned by the Air Program Manager. It will have annual review in which the Air Program Manger, the Air Conditioning Technician , The Equipment Mechanics Supervisor, and the Facility Manager are required to sign that they have reviewed and approved the document. | Replace Class II ODS equipment | 9/30/2017, 12/31/2017 | 8/30- Draft ODS Plan with Mechanics for review. |
10/23 - Combining Leak detection with ODS Elimination Plan.
11/7 - Draft in review.
12/18 - Plan out for signature.
| 1/22/18 - Plan with Government staff for signature | 23-Jan-18 | NA | SOC | Ready to close 4/19/2018 | 1 | 1 | 1 | The original deficiency has been addressed, as Section 6 of QP BOP ENV 0013 ODS Management Plan addresses the procedures and documentation now required for leaking equipment that contains 50 pounds or more of refrigerant. A root cause corrective action is not required, as this finding is a Management Practice. | Finding closed in WEBCASS by HWAD personnel. Concur that the finding is closed. | |||||
| CR_HWAD17-E-001 | I | No | ENV-17-067 | The HWAD archaeological collection is not maintained in accordance with 36 CFR 79. | Chuck King, ACO Environmental Protection Specialist | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Open | Finding Corrective Action: Obtain a point-of-contact for the UNLV curation facility and reach out to this individual to assess the status of the HWAD archaeological collection. /$0 Contact has been made w/University Las Vegas Nevada (UNLV) wrt this finding. The collection was initially housed @ the Harry Reid Center (HRC) which has since closed. Dr. Barbara Roth, Professor and Chair of the Department of Anthropology stated that UNLV is not in possession of the archeological material and that the Museum of Natural History in Las Vegas took over "many of the HRC collections and are developing a new curation facility." Dr. Roth provided contact information and HWAD will follow up. Contact info for the Las Vegas Museum of Natural History is Marilyn@lvnhm.org | Root Cause Corrective Action: Review the requirements for curation of artifacts as outlined in 36 CFR 79 and periodically verify that responsible personnel, including but not limited to the CRM, are adequately informed of the requirements to ensure the HWAD archeological collection is properly maintained in the future. /$0 Discovered whereabouts of curation items previously located at the Harry Reid Center at the University of Nevada Las Vegas. Artifacts were curated in the 1990s and located at UNLV. Extensive research has revealed that the items are now located in the repository of the Nevada State Museum (NSM) located in Carson City, NV. As time allows, the CRM will travel to Carson City to complete an inventory and obtain an administrative record. Discuss w/curator at the NSM terms and responsibilities of HWAD and the NSM with regards to the artifacts. CRM will visit the NSM before 31 May to inventory and discuss responsibilities of HWAD and the NSM regarding the curated items | TBD | Chuck King has sent an Email, No response as of 10-11 | |||
| 12/21- Collection has been transferred to Nevada Museum of History in Carson City. Will travel to Carson after first of the year to inspect and ensure collection is intact. | NA | ACO | In Progress | In progress | 1 | 1 | What progress has been made in resolving this deficiency? Has the CRM traveled to Carson City to meet with Nevada State Museum personnel? If so, has an inventory been completed and an administrative record developed? Has an MOU or MOA been developed with the NSM? If the collection comes from Indian lands, has the required consent been obtained? Please upload any documents or correspondence that has been generated during the resolution of this deficiency. Also, the root cause will need to be addressed. Has HWAD developed or revised procedures to ensure that requirements for managing artifacts are periodically reviewed? | Finding closed in WEBCASS by HWAD personnel. CRM did meet with NSM personnel in Carson City and obtained an inventory of HWAD artifacts at the museum. Also took photographs of the collection and obtained relevant reports. Has the Administrative Record been developed, as required in the regulations? Has the root cause been addressed (HWAD developed or revised procedures to ensure that requirements for managing artifacts are periodically reviewed)? | ||||||
| CR_HWAD17-E-002 | III | Yes / Carryover | ENV-17-050 | The ICRMP is incomplete and/or inaccurate. | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Open | Finding Corrective Action: The Operating Contractor secured the contract for the ICRMP update, which is scheduled to be complete in September 2019. The Operating Contractor Environmental Services, with the assistance of the Cultural Resource Manager, will implement the update so the management of HWAD cultural resources can be accomplished as planned. Additionally, the Cultural Resource Manager is coordinating with the contractor responsible for the Draft Report for Phases I and II for an Architectural Survey for the Reevaluation of the 1989 National Register Nomination Package and Evaluation of Resources 50 Years or Older (dated February 2016) to route for signature and make the report final. | Root Cause Corrective Action: The ACO Environmental Protection Specialist analyzes the requirements of the operating contract every 2 weeks and reports these to both the operating contractor and to command Personnel in a report called The Scorecard on a monthly basis. 1)The Phases I and II of the Architectural Survey for the Reevaluation of the 1989 National register nomination Package and Evaluation of Resources 50 Years or Older was completed on 2/21/18. The survey has been approved by the NVSHPO. 2) The operating contractor of HWAD has prioritized completion of the ICRMP, which is due for completion in FY19 (August). Chapters 1-4 have been completed along with the TOC. 3) Upon expiration of current contract, the Cultural Resource Management Program will again come under the purview of the Government Staff. AMC has consistently stated CR is inherently a government program. The contractors EMS system, managed by the Environmental Assistant Manager, will be used to track and determine when a document is scheduled for review. In addition, Microsoft Outlook is now populated with notifications of review dates. | 30-Dec-18 | The Contract has been awarded to Redhorse. |
Drafts of chapters 1-4 completed.
| 1.9.1 Cultural Resources | SOC | In Progress | In progress | 1 | 1 | 1 | Need to review updated ICRMP | Cardno reviewed ICRMP. Has any progress been made on revising the plan? | |||||||||||||||
| CR_HWAD17-E-003 | I | Yes / Repeat | ENV-17-068 | Native American Graves Protection and Repatriation Act (NAGPRA) requirements are not met concerning the management of human remains. | Chuck King, ACO Environmental Protection Specialist | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Open | Finding Corrective Action: Determine the official property boundaries for HWAD and document the determination of whether the human remains at Walker Lake are on HWAD or BLM property. Communicate with BLM and determine what notification and regulatory coordination has already occurred for the 2012 discovery of human remains. Develop a Memorandum of Agreement between HWAD and BLM to specify what management oversight HWAD will assume for these (and other future inadvertent discovery) remains. If, however, it is determined proper notification and regulatory coordination has not occurred, HWAD should take immediate action to ensure notification is completed with all Native American tribes having potential interest. It has been determined that the remains do, in fact, lie within the authority of the Bureau of Land Management (BLM). The remains were discovered during a Time Critical Removal Action (TCRA) clearance activity of Materiel Potentially Presenting an Explosive Hazard (MPPEH) and Unexploded Ordnance (UXO). Upon discovery, all clearance operations ceased until determination was made of whether the remains were located on HWAD or lands managed by the BLM. It was determined according to GPS readings that the remains were on BLM property. | Root Cause Corrective Action: Ensure the Army's responsibility for management of the BLM land south of Walker Lake is fully understood with respect to cultural resources management. It has been determined that the remains do, in fact, lie within the authority of the Bureau of Land Management (BLM). The remains were discovered during a Time Critical Removal Action (TCRA) clearance activity of Materiel Potentially Presenting an Explosive Hazard (MPPEH) and Unexploded Ordnance (UXO). Upon discovery, all clearance operations ceased until determination was made of whether the remains were located on HWAD or lands managed by the BLM. It was determined according to GPS readings that the remains were on BLM property. The BLM was notified of the finding and dispatched a archeologist to inspect the remains. She determined the probable age and immediately contacted the Walker River Paiute Tribal authorities. The WRPT requested that the remains be stabilized and left in place. HWAD entered into a verbal agreement with the BLM that HWAD would regularly inspect and care for the remains. The CRM is scheduled for NAGPRA training in May 2018 to further enhance understanding of 43 CFR 10.4. HWAD will begin the process of entering into discussions with BLM to determine if it is proper for HWAD to continue to care for the burial site. | TBD | 10/11- Meeting with BLM has been requested. | ||||||||||||
| 4/19- It has been determined that the remains do, in fact, lie within the authority of the Bureau of Land Management (BLM). The remains were discovered during a Time Critical Removal Action (TCRA) clearance activity of Materiel Potentially Presenting an Explosive Hazard (MPPEH). Upon discovery, all clearance operations ceased until determination was made of whether the remains were located on HWAD or lands managed by the BLM. It was determined according to GPS readings that the remains were on BLM property. The BLM was notified of the finding and dispatched a archeologist to inspect the remains. She determined the probable age and immediately contacted the Walker River Paiute Tribal authorities. The WRPT requested that the remains be stabilized and left in place. HWAD entered into a verbal agreement with the BLM that HWAD would regularly inspect and care for the remains. The CRM is scheduled for NAGPRA training in May 2018 to further enhance understanding of 43 CFR 10.4. HWAD will begin the process of entering into discussions with BLM to determine if it is proper for HWAD to continue to care for the burial site. | NA | ACO | In Progress | In progress | 1 | 1 | Did the CRM attend training in May 2018? Also, have discussions with BLM resulted in any agreement on the status of the area south of Walker Lake--is there an MOA with the BLM regarding this area? Please provide copies of correspondence with the BLM relating to this issue. | No change in WEBCASS since fall 2018. | |||||||||||||||
| CR_HWAD17-E-004 | III | No | ENV-17-071 | The HWAD Cultural Resources Manager is not designated in writing. | Chuck King, ACO Environmental Protection Specialist | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Closed | Finding Corrective Action: Complete a CRM Appointment Letter (a template can be obtained from AMC) for the management of cultural resources and have the HWAD Commander sign the letter. /$0 | Root Cause Corrective Action: Ensure all applicable regulations and policies are consistently followed with respect to the management of cultural resources. /$0 | TBD | 10/11 - Draft Letter in review, 10/25 Signed letter on file | 25-Oct-17 | NA | ACO | Closed | Closed 4/19/2018 | 1 | 1 | No information is provided in the WEBCASS ICAP on the corrective actions taken at HWAD to address this deficiency. Has a CRM been appointed in writing by the Commander? Please provide copies of any relevant documentation. | Finding closed in WEBCASS by HWAD personnel; copy of appointment letter uploaded to the system. No root cause information provided in WEBCASS; however, the installation is in the process of developing an updated ICRMP and shifting its Cultural Resources program back to government employees. The root cause is therefore being addressed. Concur that this finding is closed. | |||
| HW_HWAD17-E-001 | I | No | ENV-17-038 | Spent fluorescent lamps observed at HWAD are not properly managed (open container, not labeled, missing accumulation start date). | Steve Wilson, Supervisor, Electrical Shop | Kristi Lammel-Schilling, SOC Environmental Assistant Manager | Closed | Finding Corrective Action: The Container was closed and labeled when found by the generating shop personnel. The Shop Supervisor placed pens, labels, and examples were placed near the accumulation point. Shop personnel were trained to remind them of their responsibility to manage the waste. $0 | Root Cause Corrective Action: Waste Management Practices are a part of the annual compliance training that every person on the facility is required to complete. Reminders of the training are distributed to all personnel via internal communication routes (The Morning Call, Quarterly Safety Stand-down.) SOC Environmental Services periodically (randomly) inspects generator accumulation sites to ensure compliance. Bldg 108-1 is the only location where Universal Waste lamps are stored. Additionally all maintenance personnel have been trained as to proper procedures concerning Satellite Accumulation Areas (SAA) and proper storage procedures for all wastes whether hazardous or not. | 17-Jul-17 | Completed | 29-Aug-17 | 1.1 Management of Environmental Programs | SOC | Closed | Closed 06/07/2018 | 1 | 1 | 1 | Concur that this finding is closed. | Finding closed in WEBCASS by HWAD personnel. Concur that this finding is closed. | ||
| HW_HWAD17-E-002 | MP | NA | ENV-17-080 | Risk reduction for hazardous waste management. Recommend that the Memorandums of Agreement in the HWAD Hazardous Materials/Waste Contingency Plan be updated. | Chuck King, ACO Environmental Protection Specialist | Kristi Lammel-Schilling, SOC Environmental Assistant Manager | Open | Update Memorandums of Agreement in the HWAD Hazardous Materials/Waste Contingency Plan. | None | TBD | MOAs will be reviewed for content and updated as necessary | NA | ACO | Closed 06/07/2019 | 1 | 1 | Have the MOUs been updated? If so, please provide copies for upload to WEBCASS. | Finding has been closed in WEBCASS by HWAD personnel; however, MOUs have not been uploaded to the system. | |||||
| HW_HWAD17-E-003 | III | No | ENV-17-072 | The hazardous waste management plan is not being implemented. | Rob Mathias, DLA Depot Manager | Kristi Lammel-Schilling, SOC Environmental Assistant Manager | Closed | Finding Corrective Action: Ensure each SAA is labeled and separated by space, markings, or both. $/0 The Waste Management Plan was implemented as intended at the SAA. The Waste Management Plan used i.e. (meaning "That is') when e.g. (meaning "for Example') was intended. The typo has been changed and the list has been updated with other examples to clarify the intention of the SAA labeling requirement. | Root Cause Corrective Action: The Waste Management Plan is a controlled document that is reviewed annually by multiple Subject Matter Experts as required by the operating contractor's Environmental Management System, and typos are corrected when identified. Waste Management Practices are a part of the annual compliance training that every person on the facility is required to complete. Reminders of the training are distributed to all personnel via internal communication routes (The Morning Call, Quarterly Safety Stand-down.) SOC Environmental Services periodically (randomly) inspects generator accumulation sites to ensure compliance. SOC Form 732 have been utilized since 2015 to document SAAs. | 15-Dec-17 | WMP updated 10/11/2017, administrative change that does not require a revision and new signatures. | 11-Oct-17 | NA | DLA | In Progress | Ready to close 10/5/2017 | 1 | 1 | Based on the finding details, it appears there were more issues with HWMP implementation at these locations than just the labeling problem. First, Section 2.2 states that multiple wastestreams must be separated into different SAAs. The Building 110-66 SAA had 2 wastes, the mercury contaminated HW and the spent aerosols. Were separate SAAs established for these wastes? Second, the finding details also state that neither the SAA in Building 110-66 or Building 110-66A were documented on Form SOC 732 HWAD Waste Stream Profile or included in the HWAD Waste Stream Profile database, which the HWMP says is a requirement. Have these two SAA been added to the database? Also note that the finding details mention 12 drums of mercury-contaminated waste at an SAA. Although there's no picture attached to the finding, based on the description, the 55-gallon SAA limit has clearly been exceeded at that location. Were the excess drums moved to a 90-day or permitted storage area until disposal? | Finding has been closed in WEBCASS by HWAD personnel; however, the comments from October 2018 have not been addressed. | |||
| NR_HWAD17-E-001 | III | No | ENV-17-073 | Planning level surveys (PLSs) are insufficient and not maintained electronically as GIS data. | John Peterson, ACO Natural Resources Manager | Tom Erickson, SOC Environmental Manager | Open | Update and/or develop all required PLSs for HWAD as GIS data. AMC has outsourced Planning Level Surveys in conjunction with the rewrite of the INRMP for HWAD. At this time the current operating contractor of HWAD SOC Nevada LLC does not have the capability to support GIS mapping. PLS's are scheduled to be completed 9/2018 followed by INRMP completion in 12/2018. | Evaluate, revise as needed, and fully implement the installation legal requirements procedure to ensure that personnel with natural resource management responsibilities are aware of all applicable natural resource management legal and other requirements. Planning Level Surveys are currently underway. The Vegetation Communities PLS is 35% complete with further visits scheduled in early June and again in late June. | TBD | 10/12 - When asked by the team, we told them HWAD does not have GIS capabilities , HWAD will have to put it in the contract in 2020 for the contractor to be able to support HWAD. | ||||||||||||
| 12/21- INRMP scheduled to be rewritten in 2018. Planning Level Surveys began Dec 17 in preparation for INRMP rewrite. GIS will be incoporated into revised INRMP | NA | ACO | In Progress | In progress | 1 | 1 | Please provide an update on progress with the PLS--were they completed in September 2018? Has the INRMP update been completed? Note that the information provided in the Root Cause CA column does not address the root cause, it provides further information on the PLS. Has the NRM attended additional training regarding the Army's NR management requirements? Or have HWAD procedures been updated to reflect the NR management requirements? | No change in WEBCASS since fall 2018. | |||||||||||||||
| NR_HWAD17-E-002 | III | No | ENV-17-074 | The INRMP is not fully implemented in that it is not reviewed annually. | John Peterson, ACO Natural Resources Manager | Tom Erickson, SOC Environmental Manager | Open | Complete an annual review of the INRMP to include coordination with stakeholders, and add the documentation of the review to Appendix I of the INRMP. The HWAD INRMP is currently being renewed and due for issue by Dec 2018. | Ensure completion of natural resources management tasks is provided sufficient priority and adequate personnel resources are dedicated to maintain compliance with AR 200-1. Ensure that the INRMP is reviewed annually IAW AR 200-1, para1-24a, 4-3d(1)(a) through (d), 4-3d(1)(d). Natural Resources is an environmental program, however HWAD has chosen to place the NR duties with the Facilities Manager who reports to the Administrative Contracting Office (ACO). This has made it difficult to ensure that the INRMP is reviewed annually as required, however the Environmental Directorate will work jointly with Facilities Manager to ensure that it is completed IAW AR200-1. | TBD | 10/12 - Data call was sent out to Stakeholders, no response so far. | ||||||||||||
| 12/21 - Status unchanged. INRMP scheduled to be rewritten in 2018 | NA | ACO | In Progress | In progress | 1 | 1 | Has the INRMP update been completed? Did the update include coordination with the stakeholders, which is required for the annual reviews? Does the new INRMP include a procedure for annual reviews and include a form or other means to document the annual review? Have procedures been developed or revised to ensure that the annual review occurs (e.g., has a compliance calendar been updated to include the review, or has an EMS procedure been updated)? Please provide copies of any relevant documentation for upload to WEBCASS. | No change in WEBCASS since fall 2018. | |||||||||||||||
| O1_HWAD17-E-001 | III | No | ENV-17-051 | The HWAD NEPA program is not addressed in the installation's Environmental Quality Control Committee (EQCC) meetings. | Kristi Lammel-Schilling, SOC Environmental Assistant Manager | Kristi Lammel-Schilling, SOC Environmental Assistant Manager | Closed | Finding Corrective Action: The status of NEPA Evaluations were briefed by the HWAD NEPA Coordinator and Assistant at the August 2017 Commander's Environmental Meeting and is a standing agenda item for future meetings | Root Cause Corrective Action: Contracting personnel charged with assisting the HWAD NEPA Coordinator Checks once per quarter for changes in 32 CFR 651 and relevant Policies. | 30-Aug-17 | Presented to CEM 8/30/2017 | 25-Sep-17 | 1.5.7 NEPA Documentation | SOC | Closed | Closed 06/07/2018 | 1 | 1 | 1 | Concur that this finding is closed. | Finding closed in WEBCASS by HWAD personnel. Concur that this finding is closed. | ||
| O1_HWAD17-E-002 | I | Yes / Carryover | ENV-17-039 | Installation has not performed its role in the implementation of NEPA adequately. |
1. The NEPA program is integrated into all activities and programs at the installation (refer to 32 CFR Section 651.5).
2. Develop and publish local guidance and procedures for use by NEPA proponents to ensure that NEPA documentation is procedurally and technically correct (refer to 32 CFR Section 651.4[p][3]).
3. NEPA awareness training and/or training is provided for professional staff, installation-level proponents, and document reviewers (refer to 32 CFR Section 651.4[o][12]). Kristi Lammel-Schilling, SOC Environmental Assistant Manager Kristi Lammel-Schilling, SOC Environmental Assistant Manager Closed Finding Corrective Action: Operating Contractor Personnel developed and implemented procedures for the NEPA program at HWAD that include procedures for evaluating the effectiveness of the NEPA Program. . Project Engineers, Maintenance Supervisors and Managers, and other Personnel in Key functions were trained on the requirements of NEPA evaluation and when the need for NEPA analysis might be triggered and engagement with environmental staff is required. Key personnel are trained annually. Root Cause Corrective Action: Personnel responsible for the management of NEPA reviewed 32 CFR 651 while developing procedures for the NEPA Program to ensure all requirements are included. The Procedures are a controlled document under the Environmental Management System and will be reviewed annually. 9/30/2017, 12/31/2017 8/28/2017 -new/revised NEPA training has been developed based on information provided by AMC.
October 10, 2017 training was provided to the government staff for approval.
Training will occur the week of November 27, 2017.
The requirements integrated into all activities and programs are scheduled for December 2017.
11/20/2017 - Procedures are Finalized and being routed for signature, Training scheduled for Tuesday Nov 28
| 1/22/2018 - Awaitng signed QP to Upload | 11-Dec-17 | 1.5.7 NEPA Documentation | SOC | Closed | Closed 06/07/2018 | 1 | 1 | 1 | Please provide a copy of the NEPA procedure for upload to WEBCASS. Also, please provide copies of training class rosters for NEPA training for upload. | Finding has been closed in WEBCASS by HWAD personnel. The NEPA procedure has been uploaded to WEBCASS; however, training class rosters have not been provided. As lack of appropriate training was specifically called out in the finding as an issue, it needs to be addressed in the corrective action. The root cause corrective action has been addressed. | |||||||||||
| O2_HWAD17-E-001 | III | Yes / Repeat | ENV-17-075 | Noise levels are not adequately assessed. | Chuck King, ACO Environmental Protection Specialist | Tom Erickson, SOC Environmental Manager | Open | Finding Corrective Action: Solicit contractor support to update the noise survey. /$15,000. In talks w/operating contractor to solicit support wrt Noise Study. Initial focus will pertain to the New Bomb Open Detonation Unit. Several comments have been rec'd from Mono County residents in California. All comments have been logged and reviewed. | Finding Corrective Action: Solicit contractor support to update the noise survey. /$15,000. Discussions with AMC have discovered that AMC will fund noise study if placed into the STEP. Continuing discussions w/operating contractor as to path forward. | TBD | 10/11 - Researching funding options | ||||||||||
| 12/21 - ACO Staff will reach out to USAPHC Central for Noise Level Survey | NA | ACO | In Progress | In progress | 1 | 1 | Please provide an update on progress with the noise survey--has it been funded? If so, has the work been conducted, or is there a proposed date for the survey? | No change in WEBCASS since fall 2018. | |||||||||||||
| O2_HWAD17-E-002 | III | No | ENV-17-076 | Operational noise complaints are not adequately recorded and archived. | Chuck King, ACO Environmental Protection Specialist | Tom Erickson, SOC Environmental Manager | Closed | Finding Corrective Action: Ensure that operational noise complaints are monitored, recorded, and archived in accordance with Army Regulation 200-1. HWAD has established a noise complaint record within the Command Group. The PAO (a collateral duty) logs the calls and notifies the Commander, HWAD Environmental Coordinator and the operating contractor. | Root Cause Corrective Action: Evaluate, revise as needed, and fully implement Depot document control procedures to ensure that environmental noise complaints are appropriately documented. HWAD has established a noise complaint record within the Command Group. The PAO (a collateral duty) logs the calls and notifies the Commander, HWAD Environmental Coordinator and the operating contractor. Outreach program to the public was started in the Fall of 2017. Most comments (noise) are received from Mono County, CA. HWAD representatives visited a Town Hall meeting to brief the citizens of Mono County as to procedures during Open Detonation activities. Residents primary concern was fire danger. HWAD explained that Operating Contractor Fire and Emergency Services stands by during and after the shot to provide cover for small brush fires. HWAD will continue outreach program wrt noise and safety concerns. | ||||||||||||
| TBD | 10/11 - Log has been started | ||||||||||||||||||||
| 12/21 - Log being maintained by HWAD PAO | 1-Dec-17 | NA | ACO | In Progress | In progress | 1 | 1 | Has a noise complaint procedure been developed under the EMS? If so, please provide a copy for review and upload to WEBCASS. Also, please provide scans of the noise complaint logs for upload to WEBCASS. Based on the information provided in the ICAP, this finding is closed--why is it still designated as "In Progress" in WEBCASS? Does the installation intend to develop further procedures relating to noise complaints? | No change in WEBCASS since fall 2018. | ||||||||||||
| O3_HWAD17-E-001 | I | No | ENV-17-046 | Land Use Controls (LUCs) are broken and not maintained. | Greg Jacobs, ACO Environmental Protection Specialist | Tom Erickson, SOC Environmental Manager | Closed | Conduct an inspection of LUCs for all applicable CERCLA sites at HWAD and make repairs to signage and fencing as necessary. Perimeter fencing is generally covered under the Security Performance Work Statement (PWS). With regards to Land Use Control (LUC) fencing/signage, specifically the closed Walker Lake Test Range, the operating contractor has been lax in replacing signs and maintenance of fencing. In conversation w/Security and Facilities Maintenance PWS owners it has been decided that the operating contractors scorecard will reflect a lower score in order to hold the contractor accountable. This forcing function will require the contractor to perform the required maintenance. Fencing located around Walker Lake MRS has been repaired and signage replaced. | Ensure that identified environmental deficiencies (inspecting and maintaining land use control signs) are resolved in an expeditious manner. LUCIP being developed by Army Environmental Command via contractor. Government Staff Environmental Directorate in conjunction w/Security will inspect fencing/signage semiannually. | TBD | 12/21 -Signs have been replaced. | 21-Dec-17 | NA | ACO | In Progress | In progress | 1 | 1 | Based on the information provided, it appears that the initial deficiency (poor signage and fencing) has been addressed. Please provide photographs showing the new signs and fencing. Has the LUCIP been developed? Have semi-annual inspections been conducted? If so, please provide scans of inspection documentation. | No change in WEBCASS since fall 2018. | |
| O3_HWAD17-E-002 | III | No | ENV-17-079 | Land Use Controls (LUCs) are not incorporated into the installation Master Plan. | John Peterson, ACO Natural Resources Manager | Tom Erickson, SOC Environmental Manager | Open | Continue to review forthcoming drafts of the Master Plan and integrate LUC information as appropriate. The HQ AMC point of contact for master planning is Stephen Evans, and he may be contacted regarding Master Plan questions and funding. Once the Master Plan is finalized, submit to NDEP with the LUCIP. LUCIP will become incorporated into the Master Plan for HWAD. AEC has funded rewrite of the LUCIP and several documents have been forwarded to the contractor performing the update | Ensure that all contract requirements are met and understood with the respect to plan updates and implementation. LUCIP will become incorporated into the Master Plan for HWAD. AEC has funded rewrite of the LUCIP and several documents have been forwarded to the contractor performing the update. | TBD | In Process | NA | ACO | In Progress | In progress | 1 | 1 | Please provide an update on the progress of this corrective action. The latest information provided in WEBCASS is dated April 2018. Has the Master Plan update been completed? Was the LUCIP included in the Master Plan? Has the plan been submitted to NDEP for approval? If the plan has been revised and approved, has it been implemented, particularly the LUCIP portion? | No change in WEBCASS since fall 2018. | ||
| O4_HWAD17-E-001 | III | No | ENV-17-055 | The installation/organization has not established a process for evaluation and reporting of GPP performance. | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Jeff Matheny, SOC Pollution Prevention Program Manager, Cutural Resources Program Manager | Closed | Finding Corrective Action: The operating contractor Environmental Manager and Purchasing Manager revised the Depot's Green Procurement Program procedures to include program performance evaluation. | Root Cause Corrective Action: The operating contractor Environmental Manager, the environmental staff, and other key staff review pollution prevention program management requirements for changes or missed requirements annually when the Green Procurement Procedures are reviewed as required by the EMS. | 30-Dec-17 | 9/29- Draft in review |
10/9 - Tammy and Glo have completed the review and stated that they do not currently have any mechanism to gather the needed metrics. However, the new software may have the capability once it goes live.
12/18 - Plan out for signature 1/29/18 - Plan went missing, Reprint, reroute for signature
| 2/1 - Signed and posted | 1-Feb-18 | 1.5.12 Pollution Prevention | SOC | In Progress | Ready to Close 4/19/2018 | 1 | 1 | 1 | Based on the information provided, it appears that the initial deficiency has been addressed. Has a semiannual review been conducted of the GPP, as stated in the updated plan? If so, please provide meeting documentation. | No change in WEBCASS since fall 2018. | ||||
| O5_HWAD17-E-001 | III | No | ENV-17-061 | Complete annual internal EPAS assessments are not conducted. | Chuck King, ACO Environmental Protection Specialist | Tom Erickson, SOC Environmental Manager | Open | Finding Corrective Action: Fully implement the requirements of AR 200-1, Chapter 16, 16-1 a. (2) & (3) 16-1 c., regarding conducting internal assessments. AMC has developed the WEBCASS database that can record internal and external EPAS assessments, track Installation Corrective Action Plans (ICAPs), and closure of findings. HWAD should work with SOC to conduct an all-program environmental assessment on years when external EPASs are not conducted and track findings in WEBCASS. It is recommended that a standardized procedure for how this assessment is conducted be created. Additionally, AMC is holding training on how to conduct internal EPAS assessments at eight sites. It is recommended that personnel from HWAD attend one of these. HWAD expects to fully implement the requirements of AR 200-1, Chapter 16,16-1,a. (2) & (3) 16-1c. wrt EPAS reviews. HWAD Government Staff has been working w/SOC Nevada LLC to develop a viable EPAS program. Centrally funded training will be provided by AMC sometime prior to the end of FY18. Develop EPAS checklist that conforms to requirements of Environmental management system. | Root Cause Corrective Action: Implement a procedure to ensure that all Federal, state, local, and Army requirements are identified and understood by personnel with environmental responsibilities. HWAD expects to fully implement the requirements of AR 200-1, Chapter 16,16-1,a. (2) & (3) 16-1c. wrt EPAS reviews. HWAD Government Staff has been working w/SOC Nevada LLC to develop a viable EPAS program. Centrally funded training will be provided by AMC sometime prior to the end of FY18 | 30-Dec-18 | 10/12 - WEBCASS access granted to Kristi | |||
| 11/20 - EPAS findings from 2014 closed. | NA | ACO | In Progress | In progress | 1 | 1 | What progress has been made in resolving this deficiency? Has an Internal EPAS SOP and/or checklist been developed? Has an Internal EPAS been conducted at HWAD? | No change in WEBCASS since fall 2018. | ||||||
| PM_HWAD17-E-001 | III | No | ENV-17-077 | The Integrated Pest Management Plan has not been sent to the AMC Pest Management Consultant. | Chuck King, ACO Environmental Protection Specialist | Tom Erickson, SOC Environmental Manager | Closed | Finding Corrective Action: Forward the Pest Management Plan to the AMC Pest Management Consultant for review. The review of the PMP will become a CDRL to ensure compliance with regard to annual reviews. Additionally, the PMP is controlled by the contractor's EMS and has been flagged for annual review and staffing thru stakeholders. | ||||||
| /$0 | Root Cause Corrective Action: Ensure personnel with document review/management responsibilities are fully aware of their responsibilities and execute them in a timely manner. EMS Program reminder set for September to begin annual review. This Task is assigned to to ensure that all personnel fulfil their requirements.The review of the PMP will become a CDRL to ensure compliance with regard to annual reviews. Additionally, the PMP is controlled by the contractor's EMS and has been flagged for annual review and staffing thru stakeholders. | TBD | 9/7 - Pest Management Plan rejected by AMC PM Consultant, Must be reformatted, |
10/31 - Reformat complete, out for internal review.
12/4 - AMC comments incoprporated, Round 2 internal review 12/21 -PMP currently under review by ACO Staff.
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