Once every three years, the U.S. Army is obligated to conduct an external Enhanced Environmental Performance Assessment System (EPAS) evaluation at each of their installations. Since 2012, Cardno has provided support to Headquarters Army Materiel Command (HQ AMC) to develop and implement their Enhanced EPAS and related services.
As each Army installation is unique, the project required Cardno’s team of assessors to evaluate compliance with relevant statutes, regulations, policies, and procedures issued at the Federal, State, Department of Defense, Army, and Command levels, as well as maintain a working knowledge of Federal, State and Army environmental compliance requirements.
Continuity and consistency was key, so we ensured teams of experienced auditors were available to execute assessments in the Enhanced EPAS program. The teams traveled to all designated installations to conduct the onsite assessments, including facility visits, interviews, and document reviews. We also completed a comprehensive review of compliance across environmental media to include, but not limited to, air emissions, hazardous waste, hazardous materials, toxics programs, storage tanks, oil storage, water quality, wastewater, NEPA, cultural and natural resources, solid waste, pesticides, etc.
At each installation, the operations were audited against the relevant Federal, State, and local environmental regulations, as well as Army and Department of Defense policy, contained in The Environmental Assessment and Management (TEAM) Guide, and Federal, State, and Army regulations.
Our team also performed a review of the activities and operations at each installation and identified environmental deficiencies, documented findings, described root causes, and recommended corrective actions as applicable to include planning level estimate cost of corrective actions where the root cause indicated a funding requirement. In addition, the team was responsible for identifying the best opportunities for sustainable materials and process management and reduction of high volume and/or risk chemical constituents through readily available technologies, technologies nearing maturity, management practices, or solutions offered through pollution prevention-related Executive Orders and government or industry-developed programs.
A briefing of installation command leadership and key installation staff at the start and conclusion of each audit, as well as daily briefings, ensured staff were aware of any potential findings as they were identified. Results of the EPAS efforts for the week, including the findings, root cause analysis, and corrective action were also be communicated.
The Cardno team was also responsible for providing on-site internal EPAS training to several installations; preparing past EPAS Installation Corrective Action Plans (ICAPs) from FY13 through FY16 for transfer into the new WEBCASS EPAS data tracking system; providing complete ICAP reviews and assisting with some ICAP closure actions; and participating in periodic EPAS WEBCASS improvement meetings.
In total, Cardno prepared for and conducted onsite Enhanced EPAS assessments and Environmental Management System (EMS) audits at 23 installations over multiple cycles. This program-level support and the provision of technical recommendations for program improvement contributed to the overall EMS cycle of continual improvement.