Attachment_4_-__Environmental_Bulletin.pdf

HQS US Army Garrison Picatinny Arsenal Installation Environmental Bulletin

Environmental Quality

Environmental

Protection and

Enhancement

Environmental Affairs Division Directorate of Public Works Picatinny Arsenal, NJ 29 November 2012

Jason C. Mackay

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CoMirntlrlH lication is an installation bulletin which incorporates all environmental requirements at icati Ar nal.

Summary. This bulletin incorporates laws, restrictions, and procedures for all installation activities which may affect the environment at Picatinny Arsenal.

Applicability. This bulletin applies to all personnel, to include contractors, Military and Civilians, who engage in activities on Picatinny Arsenal.

Proponent. The proponent is the Directorate of Public Works, Environmental Affairs Division.

Suggested improvements.

Users are invited to send comments and suggested improvements to Environmental Affairs Division

(DPW), Attn: IIVIPI-PWE, Bldg 319, Picatinny Arsenal, NJ 07806-5000.

Distribution. This publication is available in electronic media and is available to all persons engaged in activities on Picatinny Arsenal.

Restrictions. There are no restrictions.

Table of Contents Chapter 1 Introduction

Section I - General

1-1 Purpose

Section II

Chapter 1 Responsibilities

1-2 Garrison Commander

1-3 Installation Environmental Coordinator

1-4 Environmental Officers

1-5 Legal Office

1-6 Directorate of Logistics

1-7 Directorate of Public Works

1-8 Tenants

1-9 All Contracting Officer Representatives (CORs)

1-10 All Personnel

Chapter 2 Environmental Policy

2-1 Policy Statement

2-2 Legal Requirements

Chapter 3 Regulated Activities

Chapter 4 Prohibited Activities

Chapter 5 Picatinny Environmental Management System (PEMS)

Appendix A Abbreviations

Page4

Chapter 1 Introduction

Section I - General

1-1. Purpose

a. This policy implements Federal, State, and local environmental laws and DOD policies for preserving, protecting, conserving, and restoring the quality of the environment. This bulletin and appendix should be used in conjunction with Army Regulation 200-1 and 32 Code of Federal Regulations (CFR) Part 651 (32 CFR 651) , which provides Army policy on National Environmental Policy Act (NEPA, 42 USC 4321 4347) requirements.

b. This bulletin helps define the framework for the Picatinny Environmental Management System (EMS). Picatinny has implemented a mission focused EMS and must continue to conform with the International Organization for Standardization standard 14001 (ISO 14001) . The Picatinny Installation Environmental Management Plan provides detailed implementation guidance. This Management plan can be obtained on the Environmental Affairs Division Web site and is updated annually. The plan reflects inclusion of the five interconnected EMS areas which include:

(1) Policy. The Picatinny Arsenal Policy Statement reflects the Installation's commitment to environmental protection and enhancement, pollution prevention, and continual improvement.

(2) Planning and implementation. Identifying how operations impact the environment. It set objectives and targets for reducing impacts.

(3) Program management and operation. Assign roles and responsibilities for environmental management, provide required environmental training, establish procedures for communication, document environmental procedures, and provide for emergency preparedness and response.

(4) Checking and corrective action. Picatinny Arsenal will monitor and measure its progress in achieving stated goals, objectives, and targets, and will identify and implement corrective actions.

(5) Management review. Picatinny Arsenal will periodically review program performance and management system implementation and ensure continual improvement through our installation Environmental Quality Control Committee.

c. Abbreviations (See Appendix A)

Section II Responsibilities

1-2. Garrison Commander

.The Garrison Commander (GC) will

a. Ensure that Base Support activities support mission readiness operations, enhance mission accomplishment, and are conducted in a manner conducive to environmental stewardship.

b. Comply with applicable Federal, State, and local environmental laws, regulations, internal directives and goals and Executive Orders (EOs).

c. Investigate regulatory enforcement actions, complaints, and spills/releases, and correct systemic problems. Document investigation, negotiation, and resolution of enforcement actions and submit through the respective chain of command to the Office of Director Environmental Programs (ODEP), and through technical legal channels to the Army Environmental Law Division, (ELD).

d. Ensure environmental requirements that impact ranges and training land are identified and incorporated into the installation range complex master plan.

Ensure the Senior Mission Commander (SMC) is made aware of these impacts.

e. Ensure installation activities incorporate applicable environmental requirements into all procurement actions.

f. Apply for, sign, and maintain all applicable Federal, State and local environmental permits as facility owner. The GC may not delegate approval or signature authority for Hazardous Waste (HW) Permits.

g. Ensure appropriate environmental records are maintained as required by law.

h. Ensure enforcement actions are reported within 48 hours via the Army

Environmental Reporting Online (AERO).

I. Coordinate with ELD early on all environmental agreements, including but not limited to, fine and penalty settlement agreements, prior to signing them. The GC may not delegate approval or signature authority.

j. Ensure that compliance agreements and consent orders that are attributable to a tenant's mission and/or operations are coordinated through applicable legal and command channels to determine the appropriate funding activity.

k. Assess the long-term resource impacts of all environmental agreements.

Coordinate resource implications for agreements through command channels to IMCOM, ACOMs, or other commands as appropriate prior to approval.

I. Ensure that non-DOD Hazardous Materials (HM) (that is, HM owned and/or used by non-DOD entities) is not stored, treated, or disposed of on the installation unless approved by the Asst Secretary of the Army (I&E), his or her designee, or higher authority.

m. Ensure that the installation strategic planning office (or equivalent) incorporates sustainability principles into strategic and other installation management plans;

coordinate installation strategic plans with the SMC prior to finalization.

n. Maintain an installation-wide Hazardous Materials Management Program

(HMMP).

as required.

q.. Implement and maintain a mission-focused EMS in accordance with the ISO

14001 standard.

r. Champion the installation EMS and designate an EMS representative in the appropriate organizational planning cell; ensure all planning incorporates the requirements of the EMS.

s. Participate fully in Environmental Performance Assessment System (EPAS), ensure annual internal environmental compliance assessments are conducted, and assessments are coordinated with all tenants.

t. Prepare and execute the Installation Corrective Action Plan (ICAP); coordinate and monitor completion of installation-wide corrective actions.

u. Ensure all environmental program plans are completed and implemented per Army Regulation 200-1.

v. Designate personnel who are responsible and accountable for executing major program requirements as prescribed in chapters {through 14 of Army Regulation 200-1.

w. Ensure all proceeds are deposited from Conservation Reimbursable Programs as outlined in Section 2665, Title 10, United States Code (10 USC 2665); Section 2667, Title 10, United States Code (10 USC 2667); and Sections 670a and 670b, Title 16, United States Code (16 USC 670a and 670b, Sikes Act).

x. Serve as the Federal Agency Official with responsibility for installation compliance with the Native American Graves Protection and Repatriation Act

(NAGPRA).

y. Establish government-to-government relations with federally recognized Indian Tribes.

z. Maintain a public affairs program that encourages public involvement.

aa. Ensure that the installation master plan incorporates environmental considerations.

bb.ldentify environmental requirements, forward through command channels, and maintain auditable records.

cc. Execute the environmental budget to meet critical requirements.

dd. Maintain an efficient and well-trained environmental staff.

ee. Ensure that Army law enforcement personnel are trained in conservation law enforcement where appropriate.

ff. Ensure that sufficient numbers of professionally trained natural resource

. management personnel and natural resources law enforcement personnel are available and assigned the responsibility to perform tasks necessary to comply with Section 670e, Title 16, United States Code (16 USC 670e).

gg.Approve record of decision (ROD)/decision documents (DDs) for environmental response actions within delegated approval authority.

hh.Approve integrated natural resource management plans (INRMPs).

ii. Hold tenant units accountable for complying with the policies and standards of the installation.

JJ. Approve annual reports of availability (ROA) for timber sales after review by higher headquarters and USAEC.

1-3. Installation Environmental Coordinator/Environmental Affairs Division.

The Installation Environmental Coordinator (IEC) will dual function as the Environmental Affairs Division (EAD) Chief. The IEC will represent the Garrison Commander with full authority to make decisions and commitments within the scope of the Environmental Protection Program. In addition the IEC will

a. Manage and advise on all Environmental Program areas on the installation to include, Cultural and Natural Resources, Compliance and Restoration (Clean-up & Military Munitions Response Program).

b. Develop local environmental policy and procedures.

c. .Monitor and evaluate environmental protection and compliance activities conducted at Picatinny Arsenal; provide technical and administrative guidance to operating organizations.

d. Obtain and maintain all environmental permits and help ensure installation-wide conformance with environmental permitting requirements.

e. Oversee inspections of mission and support activities to help ensure compliance with environmental protection requirements; coordinate action to correct program deficiencies..

f Coordinate environmental protection training and information programs for installation personnel.

g. Act as the main liaison with federal and state environmental protection agencies.

h. Oversee hazardous waste analysis, hazardous waste disposal and process hazardous waste turn-ins.

i. Maintain liaison with environmental staffs at higher headquarters within the

Army & DOD.

j. Respond to and oversee remediation of all hazardous spills and releases.

k. Ensure active hazardous waste minimization/pollution prevention program is in compliance with all Army and other guidelines.

I. Provide representatives on various Picatinny panels to identify and address environmental concerns with regards to implementation of the Comprehensive Environmental Response and Liability Act (CERCLA).

m. Nominate, manage and direct environmental restoration projects funded under/by the Defense Environmental Restoration Act (DERA) and Garrison Environmental Requirements Budget (GERB).

n. Review and provide guidance on installation environmental impact assessments and other NEPA documentation as it applies to total operations of the installation.

o. Conduct liaison with federal and state natural resource personnel in accordance with cooperative agreements in support of site restoration.

p. Review all construction, modification and alteration plans and specifications to assure the project meets current environmental regulations.

q. Provide soil and site clearances in regard to the Installation Restoration Program and the Military Munitions Response Program (MMRP) for construction and field activities on post.

r. Plan and manage the use of the land, surface water and all natural resources of the installation. .

s. Integrate land, forest, fish, and wildlife programs into a balanced land management program and maintain liaison with appropriate agencies in accordance with AR 200-1.

t. Prepare procedures and administer firewood programs.

1-4. Environmental Officers

An Environmental Affairs Officer is a representative assigned in writing, by their Director or organizational head to act as a liaison between the organization and the Environmental Affairs Division. This position is normally assigned to larger activities which have several environmental impacts from their operations. The Environmental Officers will

a. Represent their organization at various environmental meetings and committees to include but not limited to the EQCC and EMS committees.

b. Review and coordinate projects and permits with the Environmental Affairs Division that may have Environmental Impacts on their directorates/tenant operations.

c. Serve at times as an independent auditor (If certified) for internal Environmental Performance Assessment System (EPAS) and ISO audits.

d. Coordinate regulatory, and program specific inspections for their organizations, with the Environmental Affairs Division.

e. Attend annual Environmental Officer training given by the Environmental Affairs Division.

occur.

i. Insure new activities are placed into the PEMs system (Project Checklist) for

Environmental Affairs Division review.

1-5. Legal Office

The Legal office will provide legal advice to both the Garrison Commander and Environmental Affairs Division on environmental actions requested, or as mandated by

AR 200-1.

1-6. Directorate of Logistics (DOL)

The Picatinny Directorate of Logistics is the central point of contact for Hazardous Material (HAZMAT) management on the installation. The DOL will:

a. Manage the Hazardous Material Management Facility (HAZMART) which is located in Bldg 316 and all hazardous material that is not hazardous waste.

b. Keep and maintain an inventory of all hazardous materials stored and used on the installation.

1-7. Directorate of Public Works (DPW)

The Picatinny DPW is the central point of contact for public works on the installation.

The DPW Master Planning Division will also be the central point of contact for all Asbestos work on the installation.

. 1-8. Tenants

A tenant is an authorized activity located on an installation that is not part of the garrison organization. This includes, but is not limited to, Other Army and Navy Command organizations (RDECOM, MEDCOM, NEC, NAVSEA, etc.), both active duty and reserve military units, Corps of Engineers, the Army and Air Force Exchange Service (AAFES), and the Defense Commissary Agency (DECA). Tenants will-

a. Comply with installation policies, applicable Federal, State, and local environmental laws, regulations, and Management Plans.

b. Establish an Installation Services Support Agreement (ISSA) as required with the GC that addresses environmental oversight, to include funding responsibilities and facility access (this does not apply to military units).

c. Participate in the installation's planning, sustainability, and ISO 14001 Environmental Management System (note, the Enhanced Use Lease properties and RCI properties are exempted from the installation EMS).

d. Designate a representative to serve as an Environmental Officer (See Section 1-4 for applicability).

e. Ensure personnel receive required environmental training in accordance with Management Plans.

f. Participate in all installation internal and external assessments and audits, to include programming for corrective actions.

g. Fund environmental requirements not covered in the standard installation services or the ISSA (this does not apply to military units).

h. Identify and submit environmental requirements to the supporting higher headquarters (this does not apply to military units).

i. Identify and coordinate non mission-specific environmental requirements with the GC.

j. Pay environmental fines and penalties resulting from their mission activities.

k. Immediately report spills or releases of hazardous substances to the installation Police desk, x46666. Payor reimburse costs associated with cleanup and spill response if not covered in the standard installations services or the ISSA.

I. Report all instances of non-compliance to the Installation Environmental Affairs Division immediately.

m. Ensure that non-DOD hazardous material is not stored, treated, or disposed of in your facilities.

n. Ensure that no Solid Waste or hazardous waste is brought onto Picatinny Arsenal property for purposes of storing, treating or disposal.

o. Identify potentially regulated areas to the Environmental Affairs Division via the PEMs process (Project Checklist).

1-9. Acquisition Center/Contracting Officer Representatives (CORs)

The CORs will act as the liaison and responsible individual over the contractors which work on Picatinny Arsenal. The CORS will:

a. Ensure all contracts and contract modifications in coordination with the Acquisition Center specify that contractors are liable for any enforcement actions, fines, and/or penalties resulting from their failure to comply with applicable environmental requirements.

b. Ensure contractors get an environmental in-briefing on ISO 14001 prior to work commencing.

c. Ensure all construction projects are placed into the Picatinny Environmental Management System (PEMS) for review.

d. Ensure contractors bringing chemicals onto the installation remove the excess when work is completed, as long as they will not be stored on base at anytime.

If they will be storing the chemicals, they will not be exempt from the requirements of reporting them to the HAZIVIART.

e. Ensure compliance with Green Procurement provisions working with the contracting office to satisfy Affirmative Procurement requirements in a cost effective manner, taking into account the contract type.

1-10. All Personnel

All personnel referred to in this bulletin include, all military and civilian employees who physically perform their duties at Picatinny Arsenal. All personnel will:

a. Comply with Chapter 3 of this bulletin.

b. Refrain from Prohibited Activities in Chapter 4 of this bulletin.

c. Report any spills or chemical releases to the police desk, x6666 upon discovery.

d. Ensure approvals are obtained for any regulated unit from the Environmental Affairs Division, before operations commence in accordance with Chapter 5-1, paragraph e of this Appendix.

Chapter 2 Environmental Policy 2-1. Picatinny Environmental Policy Statement (Policy Statement)

a. Picatinny Arsenal will comply with applicable Federal, State, and local environmental laws, regulations, executive orders (EOs); develop and implement pollution prevention and control strategies; and establish environmental priorities in consideration of the benefits to the sustainment of missions and operations.

b. Picatinny will strive to achieve continual improvement in overall environmental performance and supporting management systems.

c. All Picatinny organizations will ensure that this bulletin is implemented, maintained, and communicated to all military and civilian employees and supporting contractors. In addition, this bulletin will be made readily available to the public upon request.

2-2. Legal Requirements

All references to legal requirements in this Appendix are intended to refer to laws, regulations, and executive orders that, in the opinion of legal counsel, are applicable to the Army. While most environmental laws apply to the Army, some include exemptions (or provisions for requesting exemptions) for military activities under certain conditions.

It is essential that Army counsel, including but not limited to the Office of the Judge Advocate General, Army Environmental Law Division, JALS-EL), be consulted on the applicability of all laws, regulations, initiatives, and executive orders. Similarly, all permits, agreements, notices of violations, enforcement actions, especially reports of potential liability, require early and close coordination with Army legal counsel that is responsible for direct support to the command or activity. The requirement to consult with legal counsel supporting a command or activity is considered an essential part of effectively using this Appendix. Additionally, this Appendix prescribes program requirements in terms of "will" and "must", which mean that the actions are mandatory.

All organizations will incorporate environmental considerations and requirements into all aspects of the organization's mission.

Chapter 3 Regulated Activities The following resources involve regulated activities at Picatinny Arsenal, and shall be coordinated by use of the Environmental Checklist referenced in Chapter 5-1, paragraph e. If you are unsure whether your project or piece of equipment requires this checklist contact the appropriate EAD Program Manager directly.

3-1. Air resources

a. Ensure a checklist is provided:

1. Before changing approved operating procedures for any air pollution emitting operation.

include, but are not limited to; fuel burning equipment (such as boilers, hot water heaters, internal combustion engines, process heaters); tanks for storage or processing of materials (such as fuel oil, propane, chemical or waste materials); mixers, extruders, kettles, surface coating equipment (such as spray booths), degreasing units, air compressors, generators, or rock crushers. The Air Program Manager must be provided with specifications of the equipment.

5. Contractors must have state issued air permits for any equipment (which may require it) before bringing the equipment onto the facility.

3-2. Water resources

a. Ensure a checklist is provided prior to:

sewer system.

3. Any activity that will require connecting to any potable or non-potable water resources.

drains or body of water.

cabinets.

9. Any activity which occurs within a defined wetland, transition zone or stream encroachment area.

3-3. Land resources

Land resources are the ranges, cantonment areas, and associated natural resources (to include soils and the biota they support).

a. Ensure a checklist is provided or Natural Resource Manager is contacted before:

documentation is conducted.

stream encroachment area.

9. Any erection or installation of nest boxes or artificial roost structures.

b. Ensure coordination with the Natural Resource Manager for the following:

1. Any request for fuel wood or wood products such as wood chips, are needed.

2. Any changes to established hunting, fishing or trapping program or policies.

3-4. Pest Management

a. All pest management issues, to include application of pesticides, insecticides, fungicides and herbicides on Picatinny Arsenal must be coordinated with the Installation Pest Manager.

b. Only properly certified personnel on record in the Environmental Affairs Division are allowed to apply pesticides on Picatinny.

3-5. Cultural Resources

The Cultural Resources on Picatinny include all historical and archeological sites and area on Picatinny.

a. Ensure a checklist is provided before:

1. Any outdoor/exterior construction and/or additions are conducted.

3-6. Pollution Prevention

a. Comply with Section 6002 of the Resource Conservation and Recovery Act (RCRA) of 1976 for compliance with Green Procurement (GP) and Executive Orders 13423 and 13514.

b. Comply with the Installation Pollution Prevention (P2) Plan.

3-7. Hazardous materials

The Directorate of Logistics is the proponent for Management of Hazardous Materials.

The HAZMART Manager is the program manager for this program.

a. Ensure all chemicals being ordered, get sent through the HAZMART, Bldg 316.

b. All Hazardous Materials as defined under Department of Transportation (DOT) Regulations and or require an MSDS to accompany the product, will be processed through the Installation HAZMART (Bldg 316), prior to delivery to the user. The following Hazardous Materials are exempt from this requirement:

(a) Explosives (Ammunition, pyrotechnics)

(b) Radioactive Materials

(c) Office Supplies

(d) Fuels and re-refined motor oils

(e) Medical supplies

(f) Office supplies/Janitorial supplies

(g) Batteries

c. Contractors bringing chemicals onto the installation that are required as part of the work being performed, such as painting or lawn care are exempt from the requirements of reporting them to the HAZIVIART, as long as they will not be stored at anytime on the base, and the contractor removes the excess when work is completed.

3-8. Toxic substances

As used in this Appendix, toxic substances include asbestos, polychlorinated biphenyls (PCBs), and lead-based paints (LBP).

a. Ensure a checklist is provided before:

1. Any demolition or modifications to buildings or structures that have LBP painted surfaces or potential asbestos is performed.

3-9. Hazardous waste

Hazardous wastes are defined in 40 Code of Federal Regulations (CFR) Part 260 through 265 and the Resource Conservation and Recovery Act (RCRA).

a. Ensure the Program Manager for Hazardous Waste is contacted prior to:

mercury lamps, thermostats and switches, batteries).

3-10. Solid waste

Solid Wastes are defined in this Appendix as any soil, liquid or gas material which as a result of a process or activity cannot be reused, recycled or otherwise is to be disposed

of. This does not include office wastes, garbage

a. Ensure a checklist is provided before or Solid Waste ProgramlVlanager is contacted prior to:

3-11. Storage Tanks, Oils and Spill Response

Storage tanks, oils and spill response are all managed under the Picatinny Spill Prevention, Control and Countermeasure (SPCC) Plan.

a. Ensure a checklist is provided before:

1. An activity installing or utilizing a mobile or stationary tank equal greater than 55 gallons on the installation.

2. An activity or operation using greater than 55 gallons of any type of oils in one location.

3. An activity utilizing more than 55 gallons of any chemical liquid in one location. .

3-12. Site Restoration & Clean-up

Site restoration and cleanup for purposes of this Appendix; refer to the specific cleanup requirements on Picatinny Arsenal under the Comprehensive Environmental Response, Compensation & Liability Act (CERCLA). Under agreement with EPA and the State of New Jersey we must cleanup, monitor, sample, and restore numerous areas of the facility.

a. Ensure a checklist is provided and The Picatinny Program Manager for Site restoration must be noti'fied prior to:

3-13. National Environmental Policy Act (NEPA) Documentation

a. Comply with Federal, State and Army regulations, to include but not limited to;

National Environmental Policy Act (NEPA, 42 USC 4321-4347) and 32 Code of Federal Regulations (CFR) Part 651 (32 CFR 651).

b. All Federal Actions conducted on Picatinny Arsenal are subject to NEPA requirements.

c. The Picatinny Program Manager for NEPA must be contacted prior to:

1. All construction and renovation work is performed.

2. All demolition work is performed.

3. Any new test ranges or labs are created.

4. Any new lease or other real estate agreements are made.

5. Any new test or research project is started.

Chapter 4

Prohibited Activities

The following Activities are strictly prohibited on Picatinny Arsenal:

1. No dumping of material(s) from activities being performed on the base unless specific approvals and/or permits are granted by the Environmental Affairs Division.

2. No solid or hazardous waste is to be brought onto the installation, for purposes of storage, treatment and/or disposal.

3. No chemicals are to be brought onto the installation unless they are to be used for

DOD purposes and approved by the HAZMART.

4. No application of pesticides, fungicides or insecticides is to be applied to the environment, unless approval is obtained from the Installation Pest Manager.

5. No removal or abatement of any asbestos or Lead Based Paint containing material without prior approval.

6. No hazardous waste or Asbestos is allowed to leave the installation, unless a hazardous waste manifest or Bill of Laden is approved by the designated officials in the

. Environmental Affairs Division.

7. No storage of ignitable or reactive wastes within 50 feet of installation boundary.

8. No outside storage of drums or containers holding chemicals unless prior approval is granted from the Environmental Affairs Division.

9. No chemicals are to be put into any drain, unless prior approval is granted by the

Environmental Affairs Division.

10. No disturbances in any wetland areas, unless prior approval is received from the

Environmental Affairs Division.

11. No wildlife is to be harmed, harassed or otherwise disturbed. This does not apply to hunters or wildlife biologists performing studies, provided each is properly licensed or authorized lAW federal and State laws.

12. No equipment which requires air pollution controls, such as generators, boilers, engines, etc. shall be brought onto the base without prior approval from the Environmental Affairs Division.

13. No looting of archaeological or historical articles or items.

Chapter 5 Picatinny Environmental Management System (PEMS) 5-1. Access to the PEMS system

8. General.

(1) The Environmental Affairs Division will maintain an environmental database on the Picatinny Intranet called PEMS. The link for PEMS is the following https://picac2w5/PEMS/ . This database and associated web pages provide the following information:

(a) Guidance documents to include Major Program Plans, individual management plans for regulated units and links for regulations and policies

(b) Inspection requirements and access to electronic inspection forms

(c) Environmental training

(d) EQCC Meeting charts and minutes

(e) Project/Permit environmental checklists

b. Inspections and audit compliance.

(1) The Environmental Affairs Division maintains an inventory of compliance sites and activities with potential to impact the environment. Operators, supervisors and environmental officers for regulated areas will only see their areas when they log into the system. Each unit contains a management plan which provides operators and supervisory responsibilities under federal and state regulations and permits. These responsibilities include training requirements, inspection requirements and reporting requirements.

(2) Depending on the regulated unit there may be a weekly, monthly or quarterly inspection required. When inspections come due, they are shown in red on the operator screen. By clicking on the unit an inspection form appears which when filled out will be sent electronically to the Environmental Affairs Division.

c. Internalassessments.

(1) Internal EPAS assessments will be conducted annually, at a minimum, by Environmental Affairs Division personnel as part of their regular management, checking, and corrective action functions, unless an external assessment is conducted that calendar year. The internal EPAS will be performed as three separate organizational audits; Garrison, ARDEC and Other Tenants. The Environmental Affairs Division will provide required internal assessment data into the Army approved application/database (AEDB-EPAS) to assist in producing the draft Installation Corrective Action Plan (ICAP).

The purpose of these inspections is to determine a compliance status with regulations and identify areas of improvement.

(2) During other times of the year, the Environmental Affairs Division will perform compliance assistance visits of regulated operations listed in PEMS, construction sites and new operational walkthroughs. Corrective Actions will be provided for any deficiencies noted, but these deficiencies will not be put into the Army EPAS database.

The purpose of these visits will be to conduct training and to ensure an understanding of the environmental requirements.

d. External Regulatory Inspections

(1) All External Environmental Regulatory inspections must be coordinated with the Environmental Affairs Division (EAD). In addition a member of the EAD staff must accompany the inspector at all times when on the installation.

(2) The EAD will enter enforcement actions (ENF) using official electronic Army Environmental Quality Reporting System ((for example, Army Environmental Data Base

- Environmental Quality (AEDB-EQ)) reporting mechanisms with verification/confirmation through proper Command channels (for example, ACCS, DRUs, MSCs, regional offices, ACOMS) to the AEC. Initial reports for ENFs must be reported in accordance with current Army environmental quality reporting policy requirements as published and updated by the HQDA. Initial reports will be entered via

. the Army Environmental Quality Reporting System within 48 hours (2 business days) for any ENF involving:

(a) Criminal enforcement;

(b) A fine, penalty, fee, or tax;

(c) Installation-wide (major mission restriction), Army-wide, or DOD-wide impact, media attention, or community (on/off post) impact; or,

(d) Third party fault (that is, a non-Army entity is responsible in whole or part for the alleged violation(s)).

(3) The aforementioned 48 hours (2 business days) reporting includes notification to HQDA (DAIM-ED (ODEP) & JALS-ELD (Army Legal Office) through proper Command channels. Additionally, coordinate with JALS-ELD (Army Legal Office) in writing, through technical legal channels, regarding litigation, administrative proceedings, and settlement negotiations.

d. Nonconformance and corrective and preventive action

(1) All regulated areas that have deficiencies requiring corrective actions will be notified either electronically or hard copy during EPAS out briefings, of any non conformances or deficiencies.

(2) All non-conformances and deficiencies found are briefed at the EQCC and tracked until corrective actions are completed.

e. Environmental Project/Permit checklist.

(1) When any employee has the potential to effect the environment through obtaining a piece of equipment, construction, demolition, testing, renovations or maintenance, the EAD needs to be involved. The EAD has provided on their website a Project/Permit Checklist which shall be filled out when there may be potential for impacting the environment.

(2) The checklist questions are designed to ensure the projects or equipment is seen by the appropriate Program Manager based upon the proponent's answers.

(3) Once the Checklist is filled out and submitted, the project or equipment can be tracked on the Project Checklist Tracking database from the EAD webpage.

(4) The checklist will be reviewed by the EAD Program Managers. The various Program Managers will do one of three things

(a) Comment and disapprove until the comments can be incorporated.

(b) Approve with comments that need incorporation.

(c) Approve with no comments.

(5) The project checklist allows an interactive comment dialogue box in the tracking system, so proponents can address comments directly back to the Program Manager.

(6) No project shall be allowed to move forward until the project is- totally approved by the EAD Program Managers.

Appendix A

Abbreviations

Abbreviations

ACHP

Advisory Council on Historic Preservation

ACOM

Army Command

ACSIM

Assistant Chief of Staff for Installation Management

ADUSD (E)

Assistant Deputy Undersecretary of Defense (Environment) - now ADUSD (ESOH)

ADUSD (ESOH)

Assistant Deputy Undersecretary of Defense (Environment, Safety, and Occupational Health)

AEDB

Army Environmental Data Base

AEDB-CC

Army Environmental Data Base - Compliance-Related Cleanup

AEDB-EQ

Army Environmental Data Base - Environmental Quality

AEDB-R

Army Environmental Data Base - Restoration

AERO

Army Environmental Reporting Online

AHERA

Asbestos Hazard Emergency Response Act

AHPA

Archeological and Historical Preservation Act

AMC

Army Materiel Command

APP

Affirmative Procurement Program

AR

Army regulation

ARNG

Army National Guard

ARPA

Archeological Resources Protection Act

ASA

Assistant Secretary of the Army

ASA (ALT)

Assistant Secretary of the Army (Acquisition, Logistics and Technology)

CC

ASA (FM&C)

Assistant Secretary of the Army (Financial Management & Comptroller)

ASA (I&E)

Assistant Secretary of the Army (Installations and Environment)

AST

aboveground storage tank

ATSDR

Agency for Toxic Substances and Disease Registry

BMP

best management practice

CAA

Clean Air Act compliance-related cleanup

CCR

Consumer Confidence Report

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

CG

Commanding General

CRM

Cultural Resources Manager

CWA

Clean Water Act

DA

Department of the Army

DAPAM

Department of the Army pamphlet

DASA (ESOH)

Deputy Assistant Secretary of the Army (Environment, Safety, and Occupational Health)

DENIX

Defense Environmental Network and Information Exchange

DERP

Defense Environmental Restoration Program

DOD

Department of Defense

DODD

Department of Defense Directive

DODI

Department of Defense Instruction

DPTMS

Directorate of Plans, Training, Mobilization, and Security

DPW

Directorate of Public Works

DRMS

Defense Reutilization and Marketing Service

DSMOA

Defense and State Memoranda of Agreement

DUSD

Deputy Under Secretary of Defense

EA

Environmental Assessment

EAD

Environmental Affairs Division

EIS

Environmental Impact Statement

ELD

Environmental Law Division

EMS

Environmental Management System

ENF

enforcement action

EO

executive order or environmental officer

EOD

explosive ordnance disposal

EPA

Environmental Protection Agency

EPAS

Environmental Performance Assessment System

EPCRA

Emergency Planning and Community Right-to-Know Act

EQCC

Environmental Quality Control Committee

ERP

Environmental Restoration Program

ESA

Endangered Species Act

FFCA

Federal Facilities Compliance Act

FIFRA

Federal Insecticide, Fungicide, and Rodenticide Act

GC

garrison commander

HAZMATor HM

Hazardous Material

HMMP

Hazardous Materials Management Program

HQ

Headquarters

HQDA

Headquarters, Department of the Army

HQIMCOM

Headquarters, Installation Management Command

HSMS

Hazardous Substance Management System

HW

hazardous waste

IC

Installation Commander

IEC

Installation Environmental Coordinator

ICAP

installation corrective action plan

ICRMP

integrated cultural resources management plan

IMCOM

Installation Management Command

INRMP

integrated natural resources management plan

IPM

integrated pest management

IPMC

integrated pest management coordinator

IPMP

integrated pest management plan

IRP

Installation Restoration Program

ISO

International Organization for Standardization

ISR

installation status report

ISSA

Installation Services Support Agreement

LBP

lead-based paint

LUC

land use control

MBTA

Migratory Bird Treaty Act

MCA

Military Construction, Army

MEDCOM

Army Medical Command

MMRP

Military Munitions Response Program

MOA

memorandum of agreement

MOM

measure of merit

MOU

memorandum of understanding

MPRSA

Marine Protection, Research, and Sanctuaries Act

NAGPRA

Native American Graves Protection and Repatriation Act

NEPA

National Environmental Policy Act

NESHAP

National Emissions Standards for Hazardous Air Pollutants

NHPA

National Historic Preservation Act

NPDES

National Pollutant Discharge Elimination System

NPL

National Priorities List

NRC

National Response Center

OACSIM

Office of the Assistant Chief of Staff for Installation Management

OASA (ALT)

Office of the Assistant Secretary of the Army (Acquisition, Logistics, and Technology)

OASA (I&E)

Office of the Assistant Secretary of the Army (Installations and Environment)

ODEP

Office of the Director of Environmental Programs

ODS

ozone depleting substances

OPORD

operation order

OSC

on-scene coordinator

OSD

Office of the Secretary of Defense

OSHA

Occupational Safety and Health Act or Occupational Safety and Health Administration

OTJAG

Office of the Judge Advocate General

PAO

Public Affairs Office

PCB

polychlorinated biphenyl

PEMS

Picatinny Environmental Management System

PL

public Law

POL

petroleum, oil, lubricants

PPA

Pollution Prevention Act

QA/QC

quality assurance/quality control

RAB

Restoration Advisory Board

RCRA

Resource Conservation and Recovery Act

REC

regional environmental coordinator

ROA

reports of availability

ROD

record of decision

RPMP

real property master plan

SA

Secreta ry of the Army

SARA

Sup~rfund Amendments and Reauthorization Act

SCP

spill contingency plan

SDWA

Safe Drinking Water Act

SDWAA

Safe Drinking Water Act Amendments

SHPO

State historic preservation officer

SMC

senior mission commander

SOFA

Status of Forces Agreement

SPCC

spill prevention, control and countermeasures

SWARS

Solid Waste Annual Reporting System

SWPPP

stormwater pollution prevention plan

T&E threatened and endangered

TAG

The Adjutant General

TB

technical bulletin

TBMED

technical bulletin, medical

TDA

tables of distribution and allowances

TJAG

The Judge Advocate General

TM

technical manual

TRC

Technical Review Committee

TRI

toxic release inventory

TSCA

Toxic Substances Control Act

USACE·

U.S. Army Corps of Engineers

USACHPPM

U.S. Army Center for Health Promotion and Preventive Medicine

USAEC

U.S. Army Environmental Command

USAES

U.S. Army Engineer School

USC

United States Code

USCG

U.S. Coast Guard

USDA

U.S. Department of Agriculture

USFWS

U.S. Fish and Wildlife Service

USGS

U.S. Geological Survey

UST

underground storage tank uxa unexploded ordnance vae volatile organic compound

WMM

waste military munitions