EMS MANUAL _ 2024 _ FINAL_8.16.24.docx

U.S. Coast Guard Yard Environmental Management System Manual Revision Number: 2024-1 Date: 01-07-24

Revision No: 1 Date: 01 – 07 – 2024 Prepared by: Brandace Timbers Approved by:

Revision History

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Equipment

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Table of Contents

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EMS Contacts

SECTION A1: ENVIRONMENTAL MANAGEMENT SYSTEM OVERVIEW

1. ENVIRONMENTAL MANAGEMENT SYSTEM SCOPE

1.1 General requirements

The Environmental Management System (EMS) at the Coast Guard Yard is intended to cover the ship repair, renovation, modifications, updates and engineering activities on Coast Guard vessels as well as equipment for other government agencies. The YARD will establish, document, implement, maintain and continually improve the EMS in accordance with procedures outlined in this manual. The EMS includes units that support the ship repair mission and the tenant commands that are co-located at the Curtis Bay Station.

2. NORMATIVE REFERENCES

None

3. TERMS AND DEFINITIONS

Auditor Person with the competence to conduct an audit Recurring process of enhancing the environmental management system in order to achieve improvements in overall environmental performance consistent with the organization’s environmental policy.

Continual Improvement

Action to eliminate the cause of a detected nonconformity.

Corrective Action Information and its supporting media

Document Surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans and their interrelation.

Environment

Elements of an organization’s activities or products or services that can interact with the environment.

Environmental Aspect (EA) Any change to the environment, whether adverse or beneficial, wholly or partly resulting from and organization’s environmental aspects.

Impact

Environmental Part of an organization’s management system used to develop and implement its environmental policy and manage its environments aspects.

Management System (EMS) Overall environmental goal, consistent with the environmental policy, that an organization sets itself to achieve.

Environmental Objective Measurable results or an organization’s management of its environmental aspects.

Environmental Performance Overall intentions and directions of an organization related to its environmental performance and formally expressed by top management.

Environmental Policy

Detailed performance requirement applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.

Target

Person or group concerned with or affected by the environmental performance of an organization.

Interested Pary Systematic independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the environmental management system audit criteria set by the organization are fulfilled.

Internal audit

Non-fulfillment of a requirement

Nonconformity U.S. Coast Guard Yard

Organization Action to eliminate the cause of a potential nonconformity.

Preventive Action Use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of any type of pollutants or waste, in order to reduce adverse environmental impacts.

Prevention of Pollution

Specified way to carry out an activity or a process

Procedure Document stating results achieved or providing evidence or activities performed.

Record

4. CONTEXT OF THE ORGANIZATION

4.1 Understanding the YARD and its context

The Coast Guard Yard is the only organic shipyard in the Coast Guard and one of five remaining public shipyard in the Unites States. As such it serves a vital role as both a servicer of Coast Guard Cutters and a national defense asset. In this role the Yard operates in an environment of increased visibility and seeks to be the model organization in the Coast Guard and Country. Lastly, as an enforcement agency for environmental laws and regulations it is incumbent upon the Coast Guard to maintain the highest internal standards.

The defined list of internal and external issues that are relevant to the Yard from an environmental perspective is documented in the Yard Environmental SharePoint folder. This list shall be updated annually or when circumstances surrounding the organization change.

4.2 Determining the YARD’s Environmental risks

a. External and internal issues - The external and internal issues shall be listed before determining the YARD’s environmental risks. The external and internal issues are defined as followed:

1. External Issues

· Social issues, public relations

· Technological advances

· Cultural

· Ethical

· Legal governance, regulations and changes in the law

· Political

· Economic trends, economic shifts in the organization’s market

· Pre-existing land contamination

· Climate volatility

· Resource availability

· Social issues, public relations

2. Internal issues

· Values

· Culture

· Knowledge

· Performance

· Environmental

· Governance issues, regulatory requirements

· Strategic direction to adhere to policies and achieve objectives

· Relationship with its staff and stakeholders, including partners and suppliers

· Resources and knowledge (e.g. capital, people, processes and technologies)

· Assets

· Standards, guidelines and models adopted by the organization

· Information systems

· Capability

· Contractual relationship

· Any actions or products and services that may affect environmental performance

b. Risk Assessment

1. To determine risk each identified internal and external issue is rated for severity and control in the Internal External Risk Review Worksheet in Appendix A and on the YARD’s Environmental SharePoint page.

2. The risk score is determined by multiplying Severity x Control. The top 5 ratings in each system with the highest risk score will be considered in the context for the environmental management system. Each issue with a risk factor of 15 or higher will have a defined obligation on the worksheet.

3. Severity: The magnitude of the environmental impact

4. Control: The organization’s ability to control or influence the aspect

4.3 Understanding the needs and expectations of interested parties

a. The Coast Guard Yard is a customer focused service center and therefore maintains a broad range of stakeholders from local governments to supervisory organizations. Interested parties are persons or groups concerned with or affected by the environmental performance of an organization. The defined list of interested parties from an environmental perspective is documented in Appendix B and can be found on the YARD’s Environmental SharePoint page.

b. Each interested party is rated for Influence (power) and Strength of Relevance (interest). The combination of the ratings for power and interest are combined to obtain the relevance rank. The interested parties with a high power and high interest are identified as priority 1 and should be managed closely. The interested parties with a ranking of 1 will be utilized in determining the context of the organization and will be evaluated to determine if they create and additional compliance obligations.

4.4 Determining the scope of the YARD’s environmental management system

a. The environmental management system covers all aspects and operations that occur physically within or are generated from the 113 acre campus. Additionally, the system extends organizationally to all Coast Guard Yard employee action and tenant commands of the Yard.

4.5 YARD Environmental Management System

a. Processes that are required to be followed by all members under the purview of this manual are located in Annex A. Processes that are specified to geographic areas or a certain shop are located in Annex B.

5. LEADERHIP

5.1 Leadership commitment

a. The Coast Guard is committed to environmental stewardship throughout the organization and beyond. The Commandant outlines their leadership in the United States Coast Guard Sustainability, Environmental and Energy Policy Statement. The Coast Guard service centers continually exercise their leadership through policies, resources and oversight. The Commanding Officer of the Yard has outlined the YARD’s priorities in the action areas and environmental policy. Lastly, as an enforcement agency for environmental laws and regulations it is incumbent upon the Coast Guard to maintain the highest internal standards.

5.2 Environmental Policy

a. The YARD Campus Environmental Policy Committee (YARD ECC) has defined the following environmental policy and has determined that it is appropriate to the nature and scale of the YARD Campus activities. It includes a commitment to continual improvement, recognizes regulatory compliance, provides the framework for setting environmental objectives, is documented and communicated to all employees of the YARD, the tenant commands, contact employees working on the facility and the entire Coast Guard community.

U.S. Coast Guard Yard Environmental Policy Statement

The Coast Guard YARD shall be a leader in environmental protection and in the prevention of pollution. Through innovative work and management practices, wise use of our limited resources, a commitment to continual improvement, and by diligent regulatory compliance, we will accomplish our vital Coast Guard missions while preserving the environmental for the future.

5.3 Organizational Roles and Responsibilities

a. Commanding Officer, YARD is responsible for compliance with all applicable environmental laws, regulations and procedures within the CG YARD. The Commanding Officer, YARD shall ensure that the policies and procedures in this manual are followed by everyone under their command. Furthermore, the Commanding Officer, YARD shall ensure that resources are available to meet the requirements of the Environmental Management System.

b. Commanding Officers, Supervisors and Officers-in-Charge of the CG YARD tenant commands are responsible for compliance with all the applicable environmental laws, regulations, and procedures within their commands / units. The Commanding Officers, Supervisors and Officers- in-Charge of the tenant commands shall ensure that the policies and procedures in this manual are followed by everyone under their command / unit. Furthermore, the Commanding Officers and Officers-in-Charge of the tenant commands shall ensure that resources are available to meet the requirements of the Environmental Management System.

c. The tenant commands / units are as follows:

1. U.S. Coast Guard Surface Forces Logistics Center

2. U.S. Coast Guard Sector Maryland-National Capital Region

3. U.S. Coast Guard Legacy Sustainment Support Unit

4. U.S. Coast Guard Station Curtis Bay

5. U.S. Coast Guard Cutter JAMES RANKIN

6. U.S. Coast Guard Cutter SLEDGE

7. U.S. Coast Guard Cutter CHOCK

8. U.S. Coast Guard ESD Baltimore

9. U.S. Coast Guard ANT Baltimore

10. U.S. Coast Guard C3CEN Baltimore

11. Federal Bureau of Investigation

d. The ECC responsibilities include establishing a plan of action to maintain and ensure conformance with the ISO14001:2015 standard, which includes a review every 3 years of the documentation of the Environmental Management System at the CG YARD for legibility, dates of revision, procedures concerning the creation and modification of the documents in the Environmental Management System Manual (EMSM).

1. The ECC membership shall include:

· Commanding Officer (YARD)

· Executive Officer (YARD)

· Industrial Manager (YARD)

· Chief, Facilities Management (YARD), Chairman

· Production Manager (YARD)

· General Foreman (YARD – Shops X10, X20, X30, X40) Quality, Safety, & Training Manager (YARD)

· Business Communications Officer (YARD)

· Chief, Material Management Division (SFLC) (or alternate)

· Logistics Department Head (SECTMARYLAND) (or alternate)

· LSSU (ad hoc)

· CGC JAMES RANKIN (ad hoc)

· CGC SLEDGE (ad hoc)

· CGC CHOCK (ad hoc)

· STA CURTIS BAY (adhoc)

· ESD BALTIMORE (ad hoc)

· ANT BALTIMORE (ad hoc)

e. Facilities Engineering Department – Environmental Branch Personnel are appointed as the EMS Representatives. Their responsibilities include:

1. Development and implementation of procedures and practices to meet the requirements of the ISO 14001:2015 standard.

2. Reporting to the ECC on the performance of the environmental management system for review, including recommendations for improvement.

3. Development and implementation of procedures and practices to meet the requirements of applicable environmental laws and policies.

4. Inspection of all Facilities Management and Industrial projects for environmental compliance.

5. Incorporation of environmental laws and regulations into all construction work projects.

6. Administration oversight of Environmental Compliance and Restoration (EC&R) budgetary requirements.

f. Industrial Manager shall ensure that all waterfront activities take into account the requirements of the EMS, all applicable EMS Manual sections and all legal, regulatory and statutory requirements.

6. PLANNING

6.1 Action Areas to Address Risk

a. General

1. The Yard Facilities branch shall identify both risks and opportunities to achieving the intended outcomes and objective of the EMS program. These risk and opportunities will be brought to the Commanding Officer and the Environmental Compliance Committee on an ad hoc basis to ensure proper resources and action is taken to address the risk and capitalize on opportunities. A formal review of risks and opportunities shall be presented to the ECC for review annually.

6.2 Environmental Aspects

a. The ISO14001:2015 Environmental Management System requires that the YARD identify environmental aspects and impacts. Determination of significant aspects should then be made and addressed as a priority.

b. The method used to determine the significant aspects must provide consistent results and include the establishment and application of evaluation criteria, such as those related to environmental matters, legal issues and concerns of internal and external interested parties.

c. The Environmental Branch will identify the various unit missions and key processes. The Environmental Branch will then review, categorize, and prioritize the activities and processes that could have an effect on the environment. Audit data shall also be reviewed to ensure that all aspects have been identified.

d. The actual determination of the environmental impact for each aspect can be either positive or negative. Examples of negative impacts include increased air pollution, potential contamination of the soil, or depletion of natural resources. Positive impacts can include conservation of natural resources, improved wetlands area, decreased soil erosion, and conservation of natural habitat.

e. A review is conducted of the activities and processes defined with regards to the following:

1. emissions to air

2. releases to water

3. released to land

4. use of raw materials and natural resources

5. use of energy

6. waste and by-products

7. other local environmental and community issues

f. The Environmental Branch will evaluate the activities and processes utilizing the following criteria.

1. Inputs: reviews the resources associated with an activity.

2. Process description: name and explanation of the activity.

3. Outputs: resultant aspects attributed to the activity.

g. The aspects need to address air, water, land, natural resources, flora, fauna, humans and their interrelation.

h. Rating the Impact

1. Determine the Frequency of Occurrence, Regulation level, and Controllability of Impact Occurrence for each selected impact. The rating scale is defined as:

F = Frequency of Occurrence: How often an actual or potential impact may result from the aspect occurring. The list of activities associated with the aspect being rated should be reviewed to determine the appropriate frequency rating.

C = Controllability: The extent to which the impact can be controlled or influenced.

2. Rate each selected impact using the equation: Risk Rating Number = F x R x C

i. Quantitative Rating Scale:

1. Frequency of Occurrence 1 = Seldom (rarely, 6 months or more) 2 = Intermittently (time to time, 1 -6 months) 3 = Regularly (recurring, 1 week to 1 month) 4 = Often (1 day to 1 week) 5 = Repeatedly (again and again, daily)

2. Regulation 1 = Not Regulated 2 = Voluntary 3 = Company Policy 4 = Potential to become regulated 5 = Regulated (permitted, defined regulations)

3. Controllability 1 = Easily controlled (very few resources) 2 = Requires some resources to address 3 = Requires moderate resources to address 4 = Difficult to control (requires significant resources) 5 = Very difficult to control (requires extensive resources)

j. Document the Frequence, Regulated and Controllability ratings for each selected impact as well as the Risk Rating Number (RRN = FxRxC) in the electronic Yard Environmental files.

k. Rank the Aspect(s)

1. Rank the aspects according to the RRN

2. The Aspects with the highest total score (RRN) are the significant aspects.

l. Any re-evaluation of aspects shall be reviewed and approved by the ECC.

m. Annually at the Environmental Management Review, the ECC shall review the suitability of the current Significant Aspects and determine if there is a need to modify the significant aspects.

6.3 Compliance Obligations

a. The YARD ECC shall:

1. Identify and have access to the applicable legal requirements in Appendix C and other requirements to which the organization subscribes related to its environmental aspects, interested and

2. Determine how these requirements apply to its environmental aspects.

b. The YARD ECC shall ensure that these applicable legal requirements and other requirements to which the organization subscribes are taken into account in establishing, implementing and maintaining its environmental management system. The YARD Environmental Division shall stay in close contact with regulators, SILC EMD and review the quarterly SILC EMD Newsletter for emerging environmental issues.

6.4 Planning Action

a. The YARD ECC shall establish objectives and targets for the YARD taking into account legal requirements and the YARD’s significant environmental aspects. This includes the designation of responsibility for achieving the objectives and targets and the time frame for completion.

b. The targets and objectives will be measurable and consistent with the YARD’s environmental policy, pollution prevention, all legal, regulatory and statutory requirements and continual improvements.

6.5 Environmental Objectives and Planning to Achieve Them

a. Environmental Objectives

1. The YARD’s Environmental Objectives are established in Section A1.

6.6 Planning to Achieve Environmental Objective

a. The YARD’s plan to achieve its objectives is established in Section A1.

7. SUPPORT

7.1 Resources

a. Management shall determine and provide the resources needed for the establishment, implementation, maintenance and continual improvement of the environmental management system.

b. These resources include but are not limited to spill materials, secondary containment, personnel, PPE, and other environmental controls.

7.2 Competence

a. YARD Environmental Branch shall develop a program to:

1. Provide training or take other actions to satisfy these needs when training is required and ensure records of the training are retained.

2. Evaluate the effectiveness of the actions taken.

7.3 Awareness

a. YARD Environmental Branch shall develop a program to ensure that employees are aware of the relevance and importance of their activities and how they contribute to the significant aspects and the achievement of the EMS objectives.

7.4 Communication

a. General

1. The YARD ECC will ensure that all pertinent information regarding the Environmental Aspects and Environmental Management System will be communicated through the various levels and functions of the entire campus.

b. Internal Communication

1. The information to be communicated internally will include at a minimum Environmental Aspects and changes to the environmental policy. This information will be communicated at least once a year following the annual management review or as deemed necessary by the ECC or EMD staff. The methods used to distribute internal communications will be YARD News Digest, the YARD News, the Yard Plan of the Week, e-mails, YARD entrance sign and meetings.

c. External Communication

1. The YARD ECC will manage all relevant communications with respect to Environmental Aspects and the Environmental Management System from external interested parties by addressing the issue as a standing item on the agenda. The members of the YARD ECC will place all relevant communications in the Yard shared drive/Environmental folder.

2. The YARD ECC has elected not to voluntarily communicate with external parties concerning its significant environmental aspects. All formal external communications will be received and signed out of either the Command Office or Yard facilities as the designated responsible official.

7.5 Documented Information

a. General

1. The YARD Environmental Management System through Sections A, B and C of this manual shall document the following:

· The YARD Campus Environmental Policy, objectives and targets

· Description of the Scope of the YARD’s EMS

· Main elements of the YARD’s EMS

7.6 Creating and Updating

a. When creating or updating this manual follow the EMS Manual Revision Checklist in Appendix D.

b. When creating or updating documented information the PPC shall ensure that it is properly identified, the media and version is appropriate and is approved, saved, or uploaded by the appropriate authority.

7.7 Control of Documented Information

a. The YARD EMS representative will ensure that the records are established, controlled and maintained to provide evidence of conformity to the, ISO 14001:2015 standard.

b. The YARD Environmental Branch shall ensure that applicable environmental records are identified, protected, readily retrievable, retained, and stored. No environmental records are disposed.

c. Records will be legible, identifiable and traceable.

d. The manual will be available to all shops/ departments & units via the YARD Environmental Department SharePoint. A hard copy of the manual is also located in building 4 Environmental office.

8. OPERATION

8.1 Operational Planning and Control

a. Sections A, B, and C of this manual identify and plan for operations that are associated with the campus significant environmental aspects and are consistent with the YARD’s environmental policy, setting the objectives and targets.

b. Sections B and C ensure control of the various activities that prevent deviations from the environmental policy, objectives and targets.

c. The YARD campus significant environmental aspects are identified and it is the responsibility of the Contracting Officer’s Representative (COR) or Point of Contact to communicate the EMSM requirements to suppliers, including contractors.

1. Measurements of the significant aspects will be reported periodically to the ECC by Facilities Management.

2. All decisions about adding/deleting significant aspects and setting/revising measurements shall be made by the ECC members.

9. PERFORMANCE EVALUATION

9.1 Monitoring, Measurement, Analysis and Evaluation

a. General

1. The Yard will maintain both an internal and external audit program to ensure compliance with all applicable regulations and policies.

9.2 Evaluation of Compliance

a. The YARD ECC shall ensure that the Campus is committed to compliance by evaluating all applicable legal, regulatory and statutory (Executive Orders and Commandant Instructions) requirements. Triennially, the Yard will work with SILC to undergo an Environmental Compliance Evaluation and will track and address discrepancies in CPtrack.

9.3 Internal Audit

a. General

1. The Yard environmental staff will keep and internal audit regimen to ensure the industrial shops and applicable tenant commands are maintaining compliance with all applicable regulations and policies.

b. Internal Audit Program

1. The YARD conducts internal audits at planned intervals. The audits determine EMS conformance and environmental compliance and help identify gaps in the compliance program. The results of the internal audits will be reported to the ECC at the Management Review.

2. The Environmental Branch develops the audit plan every 3 years (once within the 3-year certification period), taking into consideration the status and importance of the activities and areas to be audited as well as the results of previous audits. Audits are conducted by the YARD Environmental Branch.

c. Audit Plan

1. The EMS Internal Audit schedule is developed triennially and reviewed annually by the Environmental Branch. The audit schedule is fluid and audits may be changed or rescheduled based on staff availability. The schedule may reflect a higher auditing frequency for activities that have a larger impact on the environment. A spreadsheet of the proposed schedule is kept in the Microsoft Teams Environmental Folder. The YARD functional shops and office areas are to be once audited every 3 years at a minimum and may be audited more frequently as needed.

2. The EMS Internal Auditor Checklist and Internal Audit Report forms are kept in the Microsoft Teams Environmental Folder and a copy may be requested from the Environmental Department.

3. The checklist covers EMS conformance of the ISO 14001:2015 standard and Environmental compliance. Completed audit reports will be stored in the Microsoft Teams Environmental Folder and a copy will be provided to the auditee.

d. Auditors

1. Internal audits of the Coast Guard YARD’s EMS can be performed by personnel from within the organization who are considered competent and qualified. The personnel conducting the audit should be competent and in a position to do so impartially and objectively.

2. The auditor should have competence in the environmental field as well as auditing techniques. Environmental knowledge should cover environmental management, environmental science, and technical aspects of Yard operations that impact the environment.

3. There are two ways to become a competent and qualified internal auditor:

· Attend and ISO 14001 auditor course that teaches audit methodologies.

· Perform 5 audits with an experience auditor who is knowledgeable of YARD operations and how they impact the environment.

9.4 Management Review

a. The Environmental Compliance Committee (ECC) is the group that is designated to conduct management review of the EMS and to recommend policy to the U.S. Coast Guard YARD and the tenant commands that reside at 2401 Hawkins Point Road, Baltimore, MD 21226-1797. The review the program annually and shall at a minimum cover the topics below:

1. The status of actions from previous management review

2. Changes in external and internal issues that are relevant to the environmental manage system; the needs and expectations of interested parties including compliance obligations; its significant environmental aspects; risks and opportunities

3. The extent to which environmental objectives have been achieved

4. Information on the organization’s environmental performance, including trends in nonconformities and corrective actions, monitoring and measure results, fulfillment of its compliance obligations and audit results

5. Adequacy of resources

6. Relevant communication(s) from interested parties, including complaints

7. Opportunities for continual improvements

b. The outputs of the management review shall include:

1. Conclusions on the continuing suitability, adequacy and effectiveness of the environmental management system.

2. Decisions related to continual improvement opportunities.

3. Decisions related to any need for changes to the environmental management system including resources.

4. Actions, if needed when environmental objectives have not been achieved.

5. Opportunities to improve integration of the environmental management system with other business processes if needed.

6. Any implications for the strategic direction of the organization.

7. The organization shall retain documented information as evidence of the results of the management review.

c. The Yard shall maintain the documentation of these reviews in the Environmental SharePoint Folder.

10. IMPROVEMENT

10.1 General

a. The Yard shall always seek to be better environmental stewards and continually improve its environmental performance through process improvement, proficiency and consideration of all recommended improvements.

10.2 Nonconformity and Corrective Action

a. The Yard shall always seek to be better environmental stewards and continually improve its environmental performance through process improvement, proficiency and consideration of all recommended improvements.

b. The Environmental Corrective Action Request (ECAR) form (Appendix E) may be issued for:

1. Repeat non-conformance with the Yard’s EMS, permits, environmental laws and regulations

2. Serious environmental non-conformance issues (to be determined by the Yard’s environmental branch)

3. Environmental spills/releases (repeat offenses, spills into the water, severity)

4. Failure to correct environmental non-conformities in a timely manner (dependent on the severity of the finding)

c. The ECAR should be issued to a responsible party who has the authority to resolve the discrepancy and can institute procedures to prevent the discrepancy from re-occurring. The ECAR will be issued by the YARD Environmental Branch and shall be completed and returned within 3 business days of issuance (an extension may be granted at the Environmental Department’s discretion).

d. Once returned, the ECAR will be reviewed by the Environmental Branch. If the corrective action is deemed appropriate and effective the Environmental Branch will accept the response, if it is not deemed appropriate and effective the ECAR shall be returned to the assigned party for correction.

e. The purpose of the ECAR is to:

1. Identify and correct nonconformities and take action to mitigate their environmental impact

2. Investigate nonconformities determining the causes and taking actions to avoid recurrence.

3. Evaluating the need for action to prevent occurrence of nonconformities

4. Recording results of action taken

5. Reviewing corrective and preventive action taken

10.3 Nonconformity and Corrective Action

a. The YARD shall continually enhance environmental performance by improving the effectiveness of the environmental management system. Continual improvement opportunities are discussed at annual Management Review meetings. Additionally, internal communication processes shall ensure that persons can contribute to continual improvement.

SECTION A2: MEASURES

1. BACKGROUND

1.1 ISO14001:2015 Environmental Management System requires that the organization conduct a periodic management review and have measures for each of its objectives and targets.

2. OBJECTIVE

2.1 To define the required aspects and measures. These measures are reported at the ECC and apply to all persons on the CG YARD Campus.

3. SIGNIFICANT ASPECTS

3.1 Preceding Section 6.2 outlines the procedure for determining significant aspects.

3.2 The Significant Aspects with the highest rankings are:

a. Painting Operations

b. Hazardous Material Management

c. Stormwater Management

4. ENVIRONMENTAL OBJECTIVES AND TARGETS

4.1 Objectives and targets were developed to be consistent with the environmental policy, pollution prevention, and the significant aspects.

4.2 The objectives and targets are:

a. Prevention of Environmental Incidents

b. Impervious Surface Area Reduction

c. Hazardous Materials/Hazardous Waste Reduction

d. Effective Stormwater Management

5. PREVENTION OF ENVIRONMENTAL INCIDENTS

5.1 Objectives and Targets:

a. Reduce the overall number of incidents and reportable spills to the National Center and Maryland Department of the Environment

b. No more than one reportable spill to the NRC per quarter

c. No more than one reportable permit violation per quarter

d. No more than two (2) incidents/violations of the Yard’s EMS per quarter (ECAR, inspection non-conformity, etc.

5.2 Designation of Responsibility:

a. Environmental compliance is the responsibility of all YARD employees, visitors, contractors and all tenant commands.

b. The Environmental Brach will provide training on the prevention of environmental incidents at a minimum of once annually.

5.3 Means and Timeframe:

a. General Foremen will be responsible for including pollution prevention in industrial work. Preventative maintenance and repair of equipment is required.

b. ECC Representatives will promote participation and ensure personnel training. Environmental Branch will be responsible for training personnel as appropriate.

5.4 Measure:

a. The method for monitoring this measure will be to track ECARS, reportable incidents and reportable spills in the Quarterly EMS Metrics (Appendix F) managed by the Environmental Department. The quarterly metrics will be provided to top management on a quarterly basis and will be discussed annually during the management review.

6. Impervious Surface Area Reduction

6.1 Objectives and Targets:

a. Decrease the YARD’s impervious surface areas per the YARD’s MS4 Permit. The overall goal is 20% reduction by 2023 and this goal has been exceeded as of May 2024. The YARD is expecting an additional restoration goal to be set by the Maryland Department of the Environment (MDE) in CY2024.

6.2 Designation of Responsibility:

a. The YARD’s Environmental and Faculties Branch

6.3 Means and Timeframe:

a. The Environmental Branch and Facilities Management Department will implement plan and schedule for the construction and implementation of selected BMP’s.

b. Annual MS4 Progress Reports will be prepared by the Environmental Branch and sent to the MDE.

c. As of May 2024, the YARD is in good standing with the MDE and the restoration target has been met.

6.4 Measure:

a. The method for monitoring this measure will be to track the completion of each BMP and the acreage credit for each.

b. The progress of the BMP’s will be tracked by the MS4 Restoration Activity Schedule (RAS). The RAS will be updated as BMP’s are planned and completed.

c. Facilities Management will present the status of the RAS during the Management Review

7. Hazardous Material / Hazardous Waste Reduction

7.1 Objectives and Targets:

a. Order and use Hazardous Materials (HM) efficiently

b. Reduce hazardous waste disposal quantities

c. Recycle 10% of hazardous / nonhazardous waste

7.2 Designation of Responsibility:

a. SFLC Retail Inventory Managers, Yard Shop Planners/Procurement, and Yard 4 PL team are responsible for efficient ordering.

b. HM users are responsible for monitoring expiration dates and using oldest material first.

c. Facilities Management is responsible for implementation and administration.

d. Waste Coordinator is responsible for determining if the Hazardous Waste can be recycled or reused.

7.3 Means and Timeframe:

a. Facilities Management will work with the Yard 4PL team to ensure efficient and effective use of HM within the Yard command.

b. ECC Representatives will promote efficient procurement and use of HM.

c. The time frame for meeting the target is CY2022.

7.4 Measure:

a. The method for measuring hazardous waste reduction will be to track the weight of hazardous waste received at building 20 for disposal versus the weight of the hazardous waste that is sent out for disposal. Each shipment will be reviewed by the Environmental Branch and concerns will be brought to the ECC when applicable.

b. Measured at each shipment and recorded monthly on the Quarterly EMS Metrics (Appendix F).

c. The YARD campus will be included in this measure.

d. Facilities Management will present the data from the metrics annual management review.

8. Effective Stormwater Management

8.1 Objectives and Targets:

a. Compliance with the YARD’s stormwater permits

b. Reduce total copper (Cu) and total zinc (Zn) in stormwater

c. Meet NPDES total Cu effluent limit of 0.013 ppm

d. Meet NPDES total Zn effluent limit of 0.120 ppm

8.2 Designation of Responsibility:

a. The Environmental Branch and Facilities Management is responsible for implementation and administration.

8.3 Means and Timeframe:

a. Reduce pollutants and contaminants from entering the stormwater system.

b. The timeframe for meeting this target is CY2022.

8.4 Measure:

a. Copper and zinc levels will be monitored at required outfalls on a quarterly basis.

b. Concerns will be brought to the ECC when applicable.

c. The measure will be reported quarterly.

d. Facilities Management will present information and the annual management review.

SECTION B1: POLLUTION PREVENTION PLAN

1. SUMMARY

The CG YARD Pollution Prevention Plan (P2 Plan) is designed to reduce long- term liabilities of waste disposal, focus management review of processes that require hazardous materials, save money by reducing the facility's material purchases and waste treatment costs, and protect public health and the environment. CG YARD will actively demonstrate its leadership in environmental protection by incorporating pollution prevention practices in every process and activity.

Environmental liabilities increase directly with the volume of hazardous substances and materials in use. While performing the CG YARD missions it is necessary to identify alternatives that require less hazardous chemicals. Reducing liabilities also requires actively searching for opportunities to reduce the amount of toxic materials, fuels, and chemicals used in the front end of the process as well as reduction of the waste generated while still accomplishing the mission of the CG YARD.

It is the YARD’s policy that:

a. Pollution should be prevented or reduced at the source whenever feasible.

b. Waste that cannot be reduced at the source should be recycled whenever feasible.

c. Waste that cannot be reduced at the source or recycled should be managed in accordance with applicable regulations.

2. REFERENCES

2.1 Executive Order 13693

2.2 COMDTINST M16455.10, EPCRA & POLLUTION ACT

2.3 40 CFR 260-265, SUBPART I

2.4 COMAR 26.13, DISPOSAL OF CONTROLLED HAZARDOUS - SUBSTANCES

3. RESPONSIBILITIES

3.1 The Environmental Compliance Committee (ECC) is the policy-setting and decision-making body for pollution prevention at CG YARD. The ECC shall:

a. Ensure Hazardous Material is ordered and used efficiently in their area of responsibility.

b. Recommend priorities for funding pollution prevention projects and equipment.

c. Participate and promote the Yard recycling program to reduce solid waste.

3.2 Pollution Prevention Coordinators (PPCs). They have overall responsibility for carrying out the pollution prevention policies established by the ECC. The PPC has the responsibility for organizing, implementing, managing, and monitoring the following pollution prevention methods and programs:

a. Reviewing all hazardous material procurement requests. The intent of this review shall be minimization of quantities purchased and to ensure that the safest, least toxic material is selected for the job at hand.

b. Develop pollution prevention projects.

c. Promote and track program recycling.

3.3 The Chief of Facilities Management is responsible for:

a. Ensuring hazardous material is ordered and used efficiently in their area of responsibility.

b. Ensuring reduction of solid waste is included in all facilities managed contracts.

c. Designating and requesting the funding for Pollution Prevention Efforts.

d. Ensuring construction and demolition debris is recycled when feasible in all facilities managed contracts.

4. HAZARDOUS MATERIAL PURCHASE REQUEST (HMPR)

4.1 The use of the HMPR as outlined in EMSM chapter B4 is the current environmental control of Hazardous Materials. Hazardous Material purchases are evaluated for toxic chemical use, needed quantity, emissions that are released to the air, the cost of processing the waste, and the potential to recycle the waste stream.

4.2 Adherence to the recycling processes in EMSM chapter B5 will work to reduce solid waste.

4.3 All contracts administered by the Facilities Branch should include contract requirements to reduce solid waste and recycle construction and demolition debris.

SECTION B2 – RESERVED

SECTION B3: PROCUREMENT OF EQUIPMENT AND SERVICES

The CG Yard is required to comply with the reporting provisions of the Pollution Prevention Act (PPA), multiple Environmental Permits, and Environmental regulations. Equipment or services that use hazardous material (Hazmat), create Industrial / Hazardous Waste (HW), or create environmental pollution require review before procurement is complete. Procedures and responsibilities for the procurement throughout the CG Yard are outlined below. The Coast Guard exists to perform its assigned operational missions, but those missions must be executed in the most environmentally sound and safest manner possible.

2. REFERENCES

2.1. THE HEAD OF CONTRACTING ACTIVITY GOVERNANCE MEMORANDUM

2.2. COMDTINST M16455.10 (EPCRA & P2 Manual)

2.3. Executive Order (EO) 13693 Planning for Federal Sustainability in the Next Decade

2.4. EMSM YPM 5090.1 – Section B7 – Stormwater Management

2.5. EMSM YPM 5090.1 – Section B10 – Waste Management

2.6. EMSM YPM 5090.