DTIC ADA242874: Worldwide Environmental Compliance Assessment and Management Program (ECAMP)

357 Pages·11.9 MB·English

by  Defense Technical Information Center

USACERL Special Report N-91/10
January 1991
F0
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AD-A242 874
U.S Air Frce
91-16448
Approved for public release; distribution is unlimited.
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1. AGENCY USE ONLY (Leave Blank) 2. REPORT DATE 3. REPORT TYPE AND DATES COVERED
January 1991 Final
4. TITLE AND SUBTITLE 5. FUNDING NUMBERS
Worldwide Environmental Compliance Assessment and Management Program
(ECAMP) Project Order
6. AUTHOR(S) 90-08, dated
Dr. Diane K. Mann and Maj Roy Salomon September 1990,
WU YY0
7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES) 8. PERFORMING ORGANIZATION
REPORT NUMBER
U.S. Army Construction Engineering Research Laboratory (USACERL) SR N91/10
2902 Newmark Drive
Champaign, IL 61821
9. SPONSORING/MONITORING AGENCY NAME(S) AND ADDRESS(ES) 10. SPONSORING/MONIrORING
AGENCY REPORT NUMBER
HQ USAF/LEEVO
Boiling AFB
WASH DC 20332-5000
11. SUPPLEMENTARY NOTES
Copies are available from the National Technical Information Service, 5285 Port Royal Road, Spring-
field, VA 22161
12a. DISTRIBUTION/AVAILABILITY STATEMENT 12b. DISTRIBUTION CODE
Approved for public release; distribution is unlimited.
13. ABSTRACT (Maximum 200 words)
Because of the growing number of environmental laws and regulations worldwide, the U.S. Air Force has adopted an
environmental compliance program that includes a mechanism to identify compliance problems before they become notices of
violation by the U.S. Environmental Protection Agency (USEPA).
In 1984, the U.S. Army Construction Engineering Research Laboratory, in cooperation with the Air Force Engineering and
Services Center, began work on the Environmental Compliance Assessment and Management Program (ECAMP). The concept
was to combine Federal, Department of Defense, and Air Force environmental regulations, along with good management practices
and risk management issues, into a series of checklists showing not only the legal requirements, but also what specific items or
operations to review. In addition, each question or protocol would list a point of contact to help assessors review the protocols as
easily as possible.
This manual was developed using existing checklists from the USEPA and private industry. It was tested at 18 Air Force
installations. The ECAMP manual has been updated annually to meet new environmental compliance laws and regulations.
14. SUBJECT TERMS 15. NUMBER OF PAGES
378
Environmental Compliance Assessment and Management Program (ECAMP) 16. PRICE CODE
17. SECURITY CLASSIFICATION 18. SECURITY CLASSIFICATION 19. SECURITY CLASSIFICATION 20. LIMITATION OF ABSTRACT
OF REPORT OF THIS PAGE OF ARSTRACT
STrnclassificd Unclassified Unclassified SAR
NSN 7540-01-280-5500 Slndarl Farm 298 (Rev. 2-89)
Precmbod by ANSI Sid 239-1a
298-102
FORWORD
Thiis work was performed for H~eadquarters United Statdes Air Force, lDirector of Engineering and Ser-
vices, Environmental Division, under reimbursable order niumber 89-01, "Research and Technology
Transfer for Army and Air Force European Environmental Compliance Program", Task number 2, Work
Unit 239. Captain John Aherm (I-IQ USAFAEEVO) was the Technical Monitor.
Thle Work was performed by the Environmental Division (EN) or aime U.S. Armny Conustniction
Engineering Research Laboratory (USACERL). Dr RI.K . Jain is Chief of EN and Dr. D. K. Mann was
the Principal Investigator.
Colonel Everett It. Th1omas is Commander and Director of USACERL, and D)r. L R. Shafl er is Techini-
cal Director.
T .~ .
INERIX ON
PROGRAM BACKGROUND
The United States Air Force (USAF) initiated the Envirmnmnnal Compliare Assess-
ment and Maagement Prgram (ECAMP) as a comprelnsive self-evaluation and pro-
gram nmnmnt system for achieving, maintainin, and monitoring envirmental
man enn t with enviromnnnta evaluations and maagemnt action plans at Air Force
installations Tl objectives of the ECAMP are to:
1. Improve Air Force envirnmntal ml enwnt
2. Build supporlirg financial program and budgets for envimnrnntal requfir-
me'nts
3. Assure M~or Commads (MAJJOMS), installation comrmnlers, environnn-
tal protection committees, environmntal coordintoM, and bioenvirnmental
ergruiem, that therenvimnnmmntal programs are effectively adressing envion-
mental problems lit coul&
a impact mission effectivenss
b. jeopardize the lealth or safely of Air Force personnel or the genral
public
c. significantly degrade de environmet
d. erode public confidence in the Air Force and fx United States
4. Anticipate fubire envimnnmn problems.
The ECAMP regulation, Air Force Regulation (AFR) 19-16, requires periodic intenal
ard extmud em-nountal compfixe evaluation The evaluations me designed to
assess environnt compliance nd to provide mcessmy feedback to conmmders for
organizing, directing, aid controlling envirnenr protection ativities
GOVERNDG POLICY
Policy conceming environmetal compliance at overseas installations is contained in
the fonowiw.
1. Ekecutive Order (BO) 12088
2. Executive Order 12114
3. Depuartex of Def (DoD) Directive 5100.50
4. AFR 19-1
5. AFR 19-3
6. AFR 19-8.
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ECAMP will assist the Air Force in implementing these policies. EO 12088, Federal
Compliance with Pollution Control Standards, requires the following:
1-801. The head of each Executive agency that is responsible for the construction
or operation of Federal facilities outside the United States shall ensure that such
construction or operation complies with the environmental pollution control
standards of general applicability in the host country or jurisdiction.
1-802. Nothing in this order shall create any right or benefit substantive or pro-
cedural, enforceable at law by a party against the United States, its agencies, it
officers, or any person.
[SCAMP does not commit the Air Force to comply with host country law beyond the
current obligation under EO 12088 and the status of forces agreement (SOFA).
[O 12114, Environmental Effects Abroad of Major Federal Actions, requires every
Federal agency with major Federal actions significantly affecting the environment of a
foreign nation to use the following documents in connection with actions:
1. environmental impact statements
2. environmental studies related to the proposed action
3. environmental assessments, summary environmental analyses, or other
appropriate documents.
DoD Directive 5100.50, Protection and Enhdtancement of Enmironmental Quality,
requires DoD components at locations outside the United States to conform at all times
to the environmental quality standards of the host country, international agreements,
and SOFA, and conform to the extent practical to the following:
1. comply with the spirit, as well as the letter, of the National Environmental Pol-
icy Act and all other Federal environmental laws, executive orders, and regula-
tions
2. demonstrate leadership in environmental pollution abatement and enhancement
of the environment.
AFR 19-1, Pollution Abatement and Ewvironmntal Quality, sets up an environmental
protection program. Air Force policy is to make sure facilities outside the United
States territory are designed, constructed, and operated so as to comply with the sub-
stantive environmental pollution standards of general applicability in the host country.
AFR 19-3, bwironmental Impact Analysis Process (EIAP) Overseas, establishes the
policies, procedures, and responsibilities for considering the effects on the environment
by major Air Force actions outside the United States. It describes how the overseas
EIAP is used to identify environmental impact to host nation territory, global
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cosonn, andi/or protecWe global iesuives by m~or Air Florce wtionu outside the
Urited Stabes, its terfitories or possession&
AFR L9-8, Ezironenta1 Protection Conniees and &winrnentpoflin, estab-
lishes the Fi- -mrma Pktection, Committees (EU) andsi gns their iesporsibili-
ties as a mutidisciplimy approach to incorporate envirnmernal concerns into tbie
decision imkir process. It also details the envirnmenstal reporingr procedures appli-
cable worldwide wich support the Air Forve' s pollution ab~atemnt progiin
MANUAL OBEUFIVES
The ECAMP Coniplimxe AsesetMaiu for Ltnsalstions Outside the United
States is intendled to serve asthe primry tool for condueiji environental compli-
aire evaluations at Air Foive installatiorm Mx objectives of the rnuual are to:
1. compile applicable DoD andi Air Foive eniromental regulations associated
with Air Foive operations andi activities
2. synlfrsize good nu rcie n ik 9 issues into con-
3. serve as aad during the evaluation process.
A secondi, country-specific nuzum (if availale), should be used in corjunrtion with
the Worldwide mnual The counhy-specific mnuel contains the Air Fozve inherpretee
tion of the enmntal pollution confrmi standards of general appficability for 63dt
country.
ECAMP OGM MANAGWFlOEiS
Tlu ECAMP progamIVM F- proces begins with thuenvnnu~leauto
andI written report that idetiie contliance andixiwwa iiniua le conmuzxier,
through his --i ronmIal Prtection Conwitlee (EP45), then am . pppnate staff
.eret o work each isue
Tbe path fllimiatad on the ffr left of Fiur 1 represents the process the installation
follows in reewlvig mos issus. Inmediate lads shoxld, of course, be aikhrmed.
aquickly asposd~ b~ef pruocedura1, effly-to-fiX isUes, are corrected duni the pro-
cess arKd documnrted in the report
TIU 1,th in the center, for the tough and expemeive ismss bicudes prepwation. of a
,I f ction plan by the instdllaton, descrzibizlw tius problemu will be
addressed.
PH -E AT"it ACTIVTmES
ENVIRONMENTAL COMPLIANCE EVALUATION REGULATORY
(IDENTIFY DEFICIENCIES AND ISSUES) AGENCY FINDINGS
vMMEO&ATEASY TOQUOtdEPENSNE
GORIRCT QUICI(LY OE 1,.P ALTERNATIVES
DOCUMENT ACTION PLAN (EPC)
FINAL ENVIRONMENTAL EVALUATION REPORT
COW IAUCE ISSUES
FOLLOW-UP (EPC)
Figure 1. ECAMP Managuiwt rrocms
ENVIRONMENTAL EVALUATION PROCESS
The ECAMP program management process described above can be divided into three
distinct phases:
1. pre-evaluation activities
2. site evaluation activities
3. post-evaluation activities.
The ECAMP Environmental Assessment Manual deals with the first two phases of the
program management process. For detailed information on the post-evaluation phase
of the process, the user is referred to the ECAMP policy. Brief descriptions of the
pre-evaluation and site evaluation activities are presented below.
Pre-evaluationA ctivities - There are five key activities that should be completed before
an evaluation team begins the evaluation activities:
1. Pre-Visit Questionnaire (external evaluations only). The purpose of the pre-
visit questionnaire is to collect information which will familiarize the evaluation
team with the installation and its operations so the evaluation team is able to
review the applicable regulations and prepare a detailed evaluation schedule. A
sample pre-visit questionnaire has been included as Attachment 1.
2.' Define Evaluation Scope and Team Responsibilities. The installation or
MAJCOMS may wish to place special emphasis on certain protocols or to
review additional areas not cove.,ed in the manual. These goals must be clearly
stated so the evaluation can be properly planned. Additionally, the duration of
the evaluation, appointment of team members by the EPC, and handling of
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teut and off-bas sites must be addrssed. FMly, responsibilities for each
protocol must be assigned to one of the teamaners.
3. Review Relevant Regulations. Once the evaluation scope and responsibilities
are known, the evaluators should undertake a thorough review of the relevant
host nation and local regulations affectirg the installation The applicable
envimnmental regulations mst be detemnined before the evaluation is begun.
If not aheady avdidable, checklist items for host nation and local
must be added to the checklists in the ECAMP Environmental Assesnent
Manual.
4. Develop Evaluation Schedule. The team should develop a detiled evaluation
schedule tit includes the activities planned for each day.
5. Review Evaluation Protocols. Each evaluator should know the regulatory
reqinents, scedule, and be familiar with the evaluation checklists tit will
be used.
Ste Fi xuation Actidities - On site, the evaluators will conduct record searchis, inter-
views, and site surveys to detemine the compliare staus of the installation Opera
tior are compared with envimn-rl standards, and any defidencies me written up
as findings. The data collected sboiud be suffcient, reliable, and relevant; to provide a
sound basis for evaluation findings and reconm rtlaions. AF Form 1955, ECAMP
Flirling Sanury, is avail6ble to assist evaluators in copilir needed infommtion
during an ECAMP evaluation An AF Fbm 1965 should be completed for each
finding during the evaluation. These forms comprise the basis for the ECAMP report
The format and content for ECAMP evaluation reports we covered in AFR 19-16.
All items of theiE CAMP Finding Smarmy must be filled in up to "Samplirg Results"
for negative findings and up to "Criteria' for positive findgs. The condiion is a fac-
tusla descdbi the status of the process, pemit, or situation under investiga-
tion. A condition may be positive if the imiallifion is going above and beyond the
equirenin. The cris me the env irantal standard (DoD, Air Force, Good
Manegexmnt Paftice (GMP), I-lst Nation Stanlads) te installation is violating. The
ca= is the reason the condition edsts Cames can include staffmg problems,
inconect or lack of bimg, procedues wlich we not followed, inadequate equipment
or faciesT. T e ffue cm be sctual or potential, and can include health and safety,
envirominctl dmage, cost, effectivemss of operation, legal consequences, and mis-
sion ipswt Fbztlw instrutions for completing AF Fbmi 195 me on the reverse side
of the form.
For exa*e, a teem member assigned to evaluse thei n tallafton's zardous waste
progrn visited the accu lalion point at building 5000. The evaluator
noticed some drus were damged, and took a count of the total mnter of dnums and
the nmner of danmged drums to obtain an accurae description of the finding. Five of
the twenty-five drums were rtsted and bulging. Item 3-16 states tiut containers slhuld
be tightly sealed and not be lealding, bulging, nsting, or badly dented. The damaged
drums were behind the others, so the acumadton point manger mny have over-
looked iem during his regular inspetions. he acumdation point manger immdi-
ately put overpwk drums on order. The evaluator is now ready to fill out an AF Form
1955 for this findirt. A completed sample form for this findirg is shown in Attach-
nmrt 2.
MANUAL APPROACH
Air Force installations engage in mny operations and activities, which can cause
environmental impats on public bealth and the environment if not controlled or prop-
erly manaed. Man of these activities and operations are regulated by local,
National, DoD, and USAF directives, as well as SOFA provisions and host nation
stardards of germal applicability.
After a review of these acivities at Air Force installtons, it was appamnt that there
were nor categoies of enviroimental compliarce into which most environmental
regulations and Air Force activities could be grouped.
This manial is divided into ten maor sections, which correspond to these nor
envirornm l categoies:
Section Evimronmntal Category
I Air Enisions
HI H-azarus Maeral MI ge t
HI Hazardous Waste Iasee
IV Natura and Cultural Resources
V Em---nzn Noise
VI Pesticide M seet
VII POL
VIII Solid WaseMmem
IX Special Progr ame
x Water Quality
Each section is oiaized in the following format:
A. I IIk i1 Y of this Protood
9 This part provides guidmce on tf major activities mud opemtions included in
the cbecklist and a brief description of the maor application.
-A .
R DaD Reg
0 This part identifies any USEPA or DoD Regulations flit address qiremnnts
associated with the specific environmental category.
C. US. Air Farce Rluqtimn
* This part identifies thse USAF regulations that address sasmsoictsia ted
with the specific enviromnmntal category.
D. Iit for
* This part identifies and sumonemizes the individual organizations at an Air Force
installation with responsibility for maintenazxe, opertion, or envirormntal
monitoring of activities associated with the envirmnmntsl category.
E. Key CmIMx~ Dei&w9
* This part presents definitions for those key terms associated with each environ-
mental category.
AJECEN C MMKUS
The finl paIt of each section contains evaluation procedures (checidists) composed of
A.,t of req tr or guidelines which serve as indicators to point out possible
W!
envimnmental problems, as well as pctices, conditions, and sitimions dt could indi-
cate potential problems. They me intended t focus atention on the Iey questions and
issues tit should be investigated. Insuctions me provided to direct the evaluator to
the appropriate action, refeences, or activily that conesponds to the specific require-
ment or guideline.
IqMtODEON TO MANUAL
The checldist portion of eech section in the ECAMP mmml is divided into 2 coltmu.
The umw columns conta s of a requiremenL Tese nmy be m Air Force
or DoD repiiremn4 or it may be a requimen, considered to be a GMP not
specifically mandated by regulation
The wide colum gives instrtnions to help conduct the evaluation qnese instrtions
me intended to be specific action items that should be acomplished by the
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