CONCESSION ENVIRONMENTAL AUDIT SYSTEM

Introduction

Background

Environmental Audit Schedule

Scope

Audit Findings, Best Management Practices, and Exceptional Practices

Closing Audit Findings and the Audit

Annual Reporting

For More Information

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Introduction
The National Park Service (NPS) Concession Environmental Audit System (CEAS) supports the Department of the Interior and NPS policies for conducting environmental audits of all NPS facilities and operations, including those provided by concessioners. The CEAS provides one tool for evaluating concession facilities, services, and operations for compliance with environmental requirements and adoption of best management practices, and serves as a means to educate concessioners and NPS staff about environmental management.

The CEAS will assist in ensuring:

Compliance with all applicable environmental requirements;

Implementation of appropriate best management practices;

Promotion of sustainability; and

Awareness and accountability for environmental management

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Background
The U.S. Department of Interior (DOI) Policy, "Environmental Auditing," Departmental Manual 515 Chapter 2 (515 DM 2) directs the NPS to develop and implement an environmental auditing program for "all land, facilities and operations." Baseline audits are to be completed by September 2002, and thereafter, the lands, facilities and operations are to undergo “routine” environmental audits at least every five years. The Policy has been interpreted to include concessioners and other third parties operating in national parks.

The Director of the NPS directed the development and implementation of an auditing program that complies with U.S. Environmental Protection Agency (EPA) regulations and the DOI policy in a memorandum dated March 30, 1998. The NPS Environmental Audit Program (EAP) was incorporated into NPS policy through Director's Order (DO) 30A. Promulgation of this DO is pending. The policies and procedures for the NPS EAP are provided in the NPS Operating Guide originally issued in May 1999. The current NPS EAP Operating Guide issued in June 2002 specifies that concessioner audits will be conducted in conformance with the Servicewide Program (NPS EAP Management Handbook, Section C.1).

In addition to the DOI and NPS directives to conduct concession environmental audits, Executive Order 13148, Greening the Government Through Leadership in Environmental Management, specifies that all Federal agencies, including the NPS, conduct periodic environmental audits including its "contractors and concessioners as appropriate" (Section 402).

The NPS Concession Program established the Concession Environmental Audit System (CEAS) to conduct environmental audits of all concessioners as a component of an NPS-wide audit program to comply with the Departmental mandate. All concessioners, regardless of size or operation type, can benefit from the CEAS environmental audits because they have environmental management liabilities, environmental impacts (positive and negative), and opportunities for improvement in areas of environmental resource protection and stewardship.

CEAS environmental audits conform to the NPS Audit Guide, but also include policies, procedures, and tools specific to concession operations in national parks. Procedures and criteria for auditing NPS concessioners are contained in the draft Version 1.0 of the CEAS Operating Guide (Guide). Until such time the draft Guide is finalized, the Concession Program will adopt the NPS Audit Guide as the minimum criteria and protocol for concessioner environmental audits conducted through the CEAS. It is recognized that certain policies and procedures in the NPS Audit Guide may not be appropriate or applicable to audits of concessioner facilities and services. These issues are addressed as they are identified.

The CEAS environmental audits are separate from the Concessioner Review Program defined in NPS-48 to evaluate concessioner operational performance and contract compliance. However, it is anticipated that the CEAS environmental audits will be integrally linked with the Concessioner Review Program as it is updated. As such, a concessioner’s responsiveness and completion of environmental audit compliance audit findings will be considered during the operational performance and contract compliance evaluations conducted by the NPS.
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Environmental Audit Schedule
All concessioners operating in national parks will undergo a baseline environmental audit conducted by the NPS. Following the baseline, each concessioner will undergo a routine environmental audit at least every 5 years. On an annual basis, a Concession Environmental Audit Schedule will be developed to define the audits that will be conducted for that year. When developing this schedule, four principle criteria will be used to determine which concessioners will be audited.

The criteria include:

Contract expiration dates and prospectus due dates;

Park and/or concessioner requests for an environmental audit;

Size of concessioner facilities and services and potential impacts those services may have on park resources; and

Location of parks and concessioner facilities within that park.

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Scope
Audit criteria are the laws, regulations, policies, or other standards against which concessioners are evaluated. CEAS criteria includes those elements applicable to concessioners and as specified in Concession Environmental Audit System Guide. These criteria include:

Federal laws, as specified in 515 DM 2.

Environmental Executive Orders (EOs), such as EO 13148, Greening the Government through Leadership in Environmental Management.

Federal regulations authorized under the above-referenced environmental laws and EOs and administered by U.S. Agencies such as the Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), Department of Commerce, and the Department of Transportation (DOT), in accordance with the authority.

State environmental laws and regulations that relate to Federal criteria. More stringent state environmental requirements supersede federal environmental requirements.

Regional and local environmental codes and ordinances that relate to Federal criteria. More stringent regional and local environmental requirements supersede federal and state environmental requirements. For instance, regional boards and/or authorities may set air quality and/or water quality standards; and the local fire marshal may have specific codes for siting, construction, and operation of aboveground fuel storage tanks.

Department of the Interior (DOI) and NPS policies and procedures, which include Departmental Manual and other DOI policies, the NPS Management Policies and Director's Orders (DOs).

Environmental Management Systems as described in the NPS Code of Environmental Management Principles, ISO 14001, and other standards governing environmental management.

The audit criteria address the following environmental management. To review the actual audit criteria (in the form of NPS EnviroCheck Sheets), click here:

Air Quality

CFC and Halon Management

Emergency Planning and Reporting

Environmental Purchasing

Fuel Storage Tank Management

Hazard Communication (HAZCOM)

Hazardous Materials Management

Hazardous Waste

Laboratory Chemical and Waste Management

Pesticide Management

Respiratory Protection Program

Solid Waste Management

SPCC Planning

Storm Water Management

NPS EnviroCheck Sheet - Universal Waste Management

Universal Waste Management

Used Oil

Wastewater Management

The scope of the audit did not include activities prior to October 1, 1999. The scope of the audit also did not include drinking water issues (the NPS is in the process of developing drinking water audit criteria), asbestos, lead-based paint, or radon since these are managed by other NPS programs.
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Audit Findings, Best Management Practices, and Exceptional Practices
Audit Findings and Corrective Actions
Audit findings are areas of non-compliance with Applicable Laws. Applicable Laws are the laws of Congress, including, but not limited to, the rules, regulations, requirements and policies promulgated under those laws (e.g., 36 CFR Part 51), whether now in force, or amended, enacted or promulgated in the future, including, without limitation, federal, state and local laws, rules, regulations, requirements and policies governing nondiscrimination, protection of the environment and protection of public health and safety.

Recommended corrective actions for each audit finding are provided in the Preliminary and Final Audit Reports. The recommended corrective actions provide one solution for addressing the corresponding audit finding. They do not limit the Concessioner to other solutions, as long as those solutions meet Applicable Laws and regulations and meet or exceed the intent of the recommended corrective actions and corresponding citations. Note that in many instances, corrective actions involve multiple components.

Guidelines for when to complete corrective actions have been developed for each audit finding priority (see the table below); however, these timeframes are for guidance only. In some instances, completion dates for corrective actions may vary based on the timing of the audit, operating season, specific circumstances of the audit finding, or other Park-specific issues. Recommended dates to complete a corrective action (including each of the multiple components of the corrective action) are designated as “deadline to close audit finding” in the Preliminary and Final Audit Reports.

Priority	Description	Deadline to Close Audit Finding
1	Non-conformances with laws and regulations that pose immediate actual or potential harm to human health or the environment, or the potential for significant liability exists.	Within 90 days of distribution of the Preliminary Audit Report.   *If a concessioner is closed for the season for the above date, then these audit findings should be addressed within one month after the start of the next operating season.
2	Non-conformances with laws and regulations that do not pose an immediate threat to human health or the environment.	Within 180 days of distribution of the Preliminary Audit Report.   *If a concessioner is closed for the season for the above date, then these audit findings should be addressed within one month after the start of the next operating season.
3	Non-conformances with Executive Orders; DOI, NPS, or park policy; or the concession contract that do not pose an immediate threat to human health or the environment.	Within 180 days of distribution of the Preliminary Audit Report.   *If a concessioner is closed for the season for the above date, then these audit findings should be addressed within one month after the start of the next operating season.

Park and Regional Concession Management staff or NPS Concession Environmental Management Program (CoEMP) staff may review a concessioner’s progress in accomplishing corrective actions. Supplemental documentation to ensure the corrective action was completed may be required from a concessioner to meet specific monitoring requirements of a park if it is not readily apparent that a corrective action has occurred.

Best Management Practices
Best management practices (BMPs) are recommended practices from industry, regulations, or other sources that may result in the following:

Help ensure compliance related to regulations, such as developing standard operating procedures when they are not required;

Prevent pollution and/or minimize compliance responsibilities, such as eliminating the use of solvents; or

Help the NPS meet its goals to promote environmental management and demonstrate commitment to environmental stewardship and sustainability.

The resources and time needed to implement BMPs varies. Some may be implemented in the short-term with fewer resources. Others may be implemented if a longer timeline and more resources are available.

BMPs identified in the Preliminary and Final Audit Reports are not required to be implemented. These BMPs may not be technically and economically feasible at the time that they are identified for a concession operation. However, the concessioner can evaluate the technical and economic feasibility of these BMPs and is highly encouraged to implement them where appropriate as a means to help further protect park resources.

Exceptional Practices
Exceptional practices are exemplary products used or exemplary activities undertaken not often seen at park concession operations that demonstrate the Concessioner’s commitment to environmental protection beyond compliance. They are not required by Applicable Laws.

The Concession Environmental Management Program (CoEMP) recognizes that each concessioner adopts and implements a number of best management practices (BMPs). Although audit teams observe a number of BMPs during each site visit, not all of the practices observed rise to the level of an "exceptional practice." However, many BMPs adopted and implemented by concessioners are recorded and recognized in the "Finding Notes" field under individual audit findings in the Preliminary and Final Audit Reports, as applicable.
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Closing Audit Findings and the Audit
An audit finding is closed when a park verifies that appropriate corrective action has been implemented to address the audit finding. Once all audit findings have been addressed, the audit as a whole can be closed by the CEAS.
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Annual Reporting
Progress made toward implementing corrective actions should be routinely documented and tracked by the park and the concessioner in the MS Access file that will be sent with the Final Audit Report. Annual updates should be forwarded by the park to the CEAS by September 15th of each year.

For park instructions for entering corrective action information, click here.

For concessioner instructions for entering corrective action information, click here.

To assist the park with the corrective action process, the CEAS will review corrective action information submitted in the first annual update on progress made toward closing audit findings. Subsequent to this first annual update, audit finding closure determination will be the park’s responsibility. However, the CEAS will conduct random site visits and spot checks of concessioner operations and facilities to verify that audit findings have been closed and concessioner corrective actions that have been confirmed by the park meet the intent of the recommended corrective action.

Annual updates should be provided to the CEAS until all audit findings are closed. The status of all audit findings is included in the annual report from the Associate Director to the Regional Concession Chiefs apprising them of each concessioner’s audit finding status and audit closure.
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For More Information
The CoEMP has established a technical assistance telephone line (GreenLine Assistance Number: 303/987-6913) and email address (NPS_GreenLine@nps.gov) available to Park staff and the Concessioner to provide support throughout the audit and corrective action process as well as questions regarding the CoEMP in general.

The CoEMP publishes a bi-annual environmental GreenLine Newsletter that provides information on on-going environmental programs, issues and topics. Copies can be requested via the GreenLine Assistance Number or email address.

For other questions and comments, contact the CEAS Coordinator, Moe West,
at 303/987-6710 or Maurice_West@nps.gov.
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