Dennis Lew and Bruce Parrish
Environmental Engineering &
Technology Division
General Physics Corporation
Columbia, MD
Tim McNamara
Directorate of Safety, Health and
Environment
U.S. Army Garrison Aberdeen Proving Ground
ABSTRACT
The U.S. Army Garrison Aberdeen Proving Ground (APG) has developed a Strategic Environmental Compliance Plan (SECP) to manage its environmental regulatory requirements in a more "forward looking" manner. APG has also begun the task of developing an Environmental Management System (EMS) with the goal of eventual certification under ISO 14001. The SECP has provided APG with a solid base on which to build their EMS. This paper presents the major elements of the SECP, how they relate to the requirements for an EMS under ISO 14001, and a discussion of additional elements that must be developed to fulfill the requirements of ISO 14001.
INTRODUCTION
The final ratification and release of ISO 14001, the standard for Environmental Management Systems (EMS) has begun the process of EMS development in earnest throughout the world. One of the problems that many companies and facilities face is how to develop and EMS out of our existing management systems and what new tools are appropriate for EMS development. The U.S. Army has initiated a program in which each major installation will be tasked to develop a Strategic Environmental Compliance Plan (SECP) to provide direction and support for the appropriate environmental programs. General Physics Corporations (GP) Environmental Engineering Division aided the Directorate of Safety, Health and Environment (DSHE) develop the first SECP for the U.S. Army Aberdeen Proving Ground Garrison (APG) in 1994. The SECP is now being reviewed and used as a tool for the development of an EMS under ISO 14001.
ISO 14000 EMS: COMMITMENT TO COMPLIANCE
One of the primary tenets for developing and implementing an ISO 14001 Environmental Management System is a commitment to compliance. Current regulatory systems tend to be reactive versus proactive and are usually based on achieving minimal compliance with existing regulatory requirements. The U.S. Army, in an effort to demonstrate its commitment to environmentalexcellence has embarked on a program to provide comprehensive planning for its facilities in the area of environmental management. APG was the first post tasked to develop a Strategic Environmental Compliance Plan to demonstrate and ensure a commitment to compliance. Elements that have been included in the SECP will help APG demonstrate the commitment to compliance that is crucial to the success of an Environmental Management System in conformance with ISO 14001.
STRATEGIC ENVIRONMENTAL COMPLIANCE PLANS: TOP TIER PLANNING
The Strategic Environmental Compliance Plan for APG was developed to provide a structured means of focusing on achieving long-term objectives for environmental compliance and pollution prevention. It reflects the goal-oriented approach currently being used by the Directorate of Safety, Health and Environment to manage and coordinate the wide range of compliance activities at APG. It is intended to be a dynamic document, periodically updated to reflect changes in regulatory requirements and APGs goals and program status.
APG is an active U.S. Army Test and Evaluation Command (TECOM) within the U.S. Army Materiel Command (AMC). It includes 13 offices, 10 directorates, and approximately 52 tenant activities or liaison offices. The APG is primarily responsible for planning and testing weapons systems, rocket and missile systems, munitions, vehicles and various equipment.The Aberdeen Proving Ground Support Activity (APGSA) serves as the host and provider of support services for the post. Impetus for development of the SECP came from the Army Environmental Office at the Pentagon. Planning for the project started, therefore, at a level above the garrison commander. DSHE, the umbrella environmental organization of APGSA, was tasked by the post commander to undertake the development of the SECP. This approach to planning coincides with the ISO 14001 principle of "top management commitment."
Army Regulation (AR) 200-1 defines the Army Environmental Quality Goals. APG has also developed a set of Installation Environmental Compliance Goals to be used as guidance in developing the SECP. They are:
These goals provided the framework for the development of the SECP, and serve as a focal point for the evaluation the various environmental programs that are ongoing at APG. These types of goals and objectives have also been prescribed as part of an EMS under ISO 14001.
SECP: A PRACTICAL TOOL FOR COORDINATING MULTIFUNCTION SITES
General Physics' Environmental Engineering Department worked with representatives of DSHE to review the status of the major environmental compliance programs on the post. Aberdeen Proving Ground is comprised of approximately 72,000 acre of land and water located on the Chesapeake Bay in Maryland. This facility supports 50+ "tenant organizations" ranging from the Army Ordinance School to the Chemical and Biological Defense Command. Industrial operations at the facility involve ordinance manufacture; fuel storage and dispensing; wastewater treatment; welding, degreasing, metal finishing and painting; incineration; steam and power generation. A comprehensive review of all current and potential compliance activities was undertaken for the following 17 site-wide environmental programs:
Air Quality Management Radiological Management
Drinking Water Management SARA Title III and Pollution Prevention Program
Wastewater Management Noise Abatement
Stormwater Management Endangered Species Management
Hazardous Waste Management Erosion and Sediment Control
Solid Waste Management Wetlands Management
Underground Storage Tank/Aboveground Storage Tank and Oil Pollution Act National Environmental Policy Act Management
Cultural Resources Management Pest Management
Land Use Management
Each program was analyzed and rated with respect to level of current compliance. Potential future compliance issues were also identified and specific programs were targeted for improvement. Tasks to establish or maintain compliance were identified and incorporated into the "Compliance Action Schedule" project management software tool for resource allocation and tracking.
The programs were evaluated with regard to the following criteria:
This programmatic approach is the most logical choice when dealing with large, multifunction sites. A similar approach may be used at large manufacturing facilities where multiple environmental aspects must be considered.
SECPS: DOCUMENTED CONTINUOUS IMPROVEMENT
APGs SECP is currently being used to document the performance of the various environmental programs at the installation. This documentation can serve to demonstrate commitment to compliance, as well as commitment to continuous improvement. The SECP development process reviews all of the environmental factors at a site that can be used to identify "environmental aspects." The resulting "living" SECP documents Goals, Regulatory Guidance, Policies, Overview, Management Initiatives, Management Indicators, Issues and Concerns, and provides an Action Schedule. All these can be used as benchmarks during periodic reviews to assess progress and to document improvements in environmental compliance and overall environmental stewardship.
ISO 14000 REGISTRATION: EVALUATING THE SECP FOR INCORPORATION INTO AN EMS
The top Command at APG and DSHE are currently evaluating registration or self-certification to ISO 14001. As part of this evaluation, they are analyzing the SECP developed by GP to determine how it can be incorporated into an EMS that conforms with ISO 14001. The following section discusses how the current SECP compares to the key elements of ISO 14001.
4.2 Environmental Policy
The SECP does not provide a definitive environmental policy statement, but it does refer to the Army Environmental Quality Goals and establishes APGs Installation Environmental Compliance Goals. These goals can easily be translated into a policy statement.
4.3 Planning
The SECP demonstrates the ability to identify environmental aspects and to establish goals and objectives based on those aspects. The SECP review process also identifies regulatory and other requirements to which APG subscribes. The SECP also identifies the programs, program structures, and responsibilities for achieving the goals and objectives.
4.4 Implementation
The structure and responsibilities for the environmental compliance program are well established at APG. The additional management structures to ensure adequate training, environmental awareness at all levels, and competence at each relevant functional level have traditionally been less well defined, particularly at an installation like APG where there are so many tenant organizations with very different missions. Many large organizations share the problems that APG has with communication and the centralization of documentation and operational control. Emergency preparedness and response is one APGs strongest areas. This can be attributed to existence of an installation-wide fire department and cooperative agreements with surrounding communities. The basic structure for implementing an EMS resides in DSHE. They will, however, need the authority from the garrison commander to establish the proper procedures and management systems that are required by ISO 14001.
4.5 Checking and Corrective Action
Each of the major environmental programs in the SECP has established procedures for monitoring and measuring environmental performance for both regulated and non-regulated activities. All the regulated operations at APG maintain Standard Operating Procedures (SOPs) for their monitoring activities, for identifying nonconformances, and performing preventive and corrective actions. Most of these procedures are maintained at the site or tenant level, and are not tracked at a central location.
4.6 Management Review
The periodic review cycle and updating of the SECP satisfies the requirements for periodic management review of the EMS.
SUMMARY
The development of the Strategic Environmental Compliance Plan at the U.S. Army Aberdeen Proving Ground has used several existing management systems and integrated them into a comprehensive package. The resulting document and review system appears to satisfy many of the requirements of an Environmental Management System as specified by ISO 14001.
Regulatory compliance is the greatest environmental concern for most industrial sites. Establishing an integrated system for monitoring and tracking compliance becomes a major step toward establishing an EMS. The greatest challenge facing APG and other similar installations on the path to ISO 14000 certification is the centralization of records, procedures, training, and communications under a central organizational structure to ensure top-to-bottom environmental awareness and stewardship.
Dennis J. Lew
Manager, Environmental Engineering Services Group
Environmental Engineering & Technology Division
General Physics Corporation
6700 Alexander Bell Drive
Columbia, Maryland 21046
410-290-2514
lew@columbia.genphysics.com
http://www.genphysics.com/html/engineer.html
Bruce M. Parrish
Principal Scientist
Environmental Engineering & Technology Division
General Physics Corporation
6700 Alexander Bell Drive
Columbia, Maryland 21046
410-290-2512
parrish@columbia.genphysics.com
http://www.genphysics.com/html/engineer.html
Tim McNamara
Directorate of Safety, Health and Environment
U.S. Army Garrison Aberdeen Proving Ground
Aberdeen Proving Ground, Maryland