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Policy Memorandum #23

REPLY TO ATTENTION OF:

IMHM-PWE                                                                                                1 August 2012

MEMORANDUM FOR SEE DISTRIBUTION

SUBJECT:  United States Army Garrison Humphreys Policy Letter #23, Environmental Inspection Program

1. The proponent for this policy is the Directorate of Public Works.

2.  This policy is effective immediately.  It remains in effect until rescinded or superseded.

3. References.

a. AR 200-1, Environmental Protection and Enhancement, 13 Dec 07, effective date 23 Dec 07.

b. US Forces Korea (USFK) Regulation 201-1, Environmental Governing Standards, 18 Jun 12.

 c. Technical Manual (TM) 38-410, Storage and Handling of Hazardous Materials, 13 Jan 99.

4. Applicability.  This policy applies to:

 a. All USAG-Humphreys Headquarters directorates and organizations, all installation support activities and organizations, and tenant units and organizations within USAG-Humphreys and Area III.

b. All permanently or temporarily assigned active duty military and reserve components at USAG-Humphreys and Area III.

 c. All appropriated and non-appropriated funded US and Local National activities permanently or temporarily tenant on USAG Humphreys and Area III.

 d. All Army and Air Force Exchange Service (AAFES) and all Defense Commissary Agency (DECA) activities permanently or temporarily tenant on USAG-Humphreys and Area III.

5. Purpose.  To establish a standardized internal USAG-Humphreys environmental
inspection and assessment program that assures compliance with Department of Defense, US Army, and USFK environmental rules, regulations, standards, and directives.

6.  Responsibilities.

     a. Directorate of Public Works (DPW), Environmental Division will:

          (1)  Conduct semi-annual environmental compliance inspections, annual Environmental Performance Assessment System (EPAS) internal assessments, and coordinate external EPAS assessments of facilities within USAG Humphreys every three years. 

          (2)  Prepare Environmental Performance Assessment Report (EPAR) of the findings observed during the annual internal EPAS assessment and the Environmental Corrective Action Plan (ECAP) to correct the findings reported in both the internal and external EPAS assessments.

          (3)  Provide assistance and technical expertise in correcting deficiencies observed during all other inspections and assessments.

          (4)  Prepare a Report of Findings of all inspections and assessments conducted by the DPW Environmental Division.

 b. Unit Commanders and Organization Supervisors will:

(1) Appoint, on orders, a primary and alternate unit or organizational Environmental Officer (EO) and ensure they attend and successfully complete the EO certification course within three (3) months following appointment.

          (2)  Implement this policy and correct identified deficiencies within ten (10) working days.

          (3)  Provide an EO to accompany all environmental inspectors and assessors during environmental inspections and assessments.

          (4)  Ensure the DPW Environmental Division is notified of anyone entering any unit or organizational facility to conduct an environmental inspection, assessment, audit, etc.

          (5)  Communicate environmental ethics to assigned personnel while training them to be good environmental stewards.

          (6)  Develop and sustain a positive and proactive commitment to environmental protection.

          (7) Protect the environment during training and other operations.

          (8)  Train peers and subordinates to identify the environmental effects of plans, actions, and missions.

          (9)  Counsel personnel on the importance of protecting the environmental and the consequences of noncompliance.

          (10)  Understand the links between environmental considerations and the associated impacts on safety and other aspects of protection and force health protection (FHP).

 c. Unit and Organizational Primary and Alternate EO.
(1) Brigade and Battalion Level Primary and Alternate EOs will:

(a) Conduct quarterly inspections of facilities and areas to determine compliance with applicable environmental rules, regulations, standards, policies, and directives.

(b) Accompany or ensure a qualified representative accompanies inspectors and assessors during internal and external environmental inspections and assessments.

(c) Ensure environmental inspectors and assessors have access to all facilities and storage areas.

(d) Correct all identified deficiencies and submit work orders to the DPW for corrective actions as needed.

(e) Submit Unit Corrective Action Plans (UCAPs) as required by DPW Environmental Division.

(2) Company Level Primary and Alternate EOs will:

(a) Conduct monthly inspections of facilities and areas to determine compliance with applicable environmental rules, regulations, standards, policies, and directives.

(b) Accompany or ensure a qualified representative accompanies inspectors and assessors during internal and external environmental inspections and assessments.

(c) Ensure environmental inspectors and assessors access to all facilities and areas.

(d) Correct all identified deficiencies and submit work orders to the DPW for corrective actions as needed.

(e) Submit UCAPs as required by DPW Environmental Division. 

7. Inspections, Intervals, and Requirements.

a. Hazardous Waste Accumulation Point (HWAP) Inspections.

(1) The unit or organization EO, Alternate EO, or assigned HWAP Manager will conduct the weekly HWAP inspections using the Inspection Checklist at enclosure one (1) of this policy.  No other checklist is authorized for use.

(2) The weekly HWAP inspection will be conducted regardless of whether the person assigned management responsibilities of the HWAP is on leave, out sick, on a FTX, on US, Korean, or training holidays, etc.

(3) The unit or organization will maintain completed HWAP Weekly Inspection Checklists for a minimum of four years on site.  Current year’s checklists will be maintained at the HWAP protected from the weather.  The previous three years’ checklists will be kept on file and be readily accessible to the unit’s or organization’s EO and Alternate EO.

(4) The unit and organization EO will make recommendations to the commander on ways to correct management and operational deficiencies and submit maintenance service orders or work orders to DPW for the correction of facility deficiencies within one day after discovering the deficiency.

b. Company and Shop Level Environmental Compliance Inspections.

(1) Company or organizational EO or Alternate EO will conduct monthly compliance inspections using the Environmental Compliance Inspection Checklist at Enclosure two (2) or the Korean translated Environmental Compliance Inspection Checklist at Enclosure three (3) of this policy.  Findings from any environmental compliance inspection or assessment conducted within the facility by others who use the checklist at Enclosure two (2) or Enclosure three (3) can be used as the company’s or organizational Monthly Environmental Compliance Inspection for the month the inspection occurred.  The EO does not have to conduct an additional compliance inspection in that month.  However, the EO must comply with all other provisions of this policy.

(2) Completed monthly environmental compliance inspection checklists will be kept and maintained on site for a minimum of four (4) years.  Current year’s monthly environmental compliance inspection checklists will be maintained in an active file and the previous three years’ checklist in an inactive file. If the current year’s inspection checklists are not maintained in the Unit Continuity Book, a notation will be made in the continuity book as to the exact on-site location of the completed checklists.

(3) The unit and organization EO will make recommendations to the commander on ways to correct management and operational deficiencies and submit maintenance service orders or work orders to DPW for the correction of facility deficiencies within ten working days after discovery.

(4) The unit and organization EO will seek support of the chain-of-command and the DPW Environmental Division as needed to correct deficiencies.

c.  Brigade and Battalion Level Environmental Compliance Inspections.

(1) Brigade, Battalion, or Organizational EO or Alternate EO will conduct quarterly inspections using the Environmental Compliance Inspection Checklist at Enclosure two (2) or the Korean translated Environmental Compliance Inspection Checklist at Enclosure three (3) of this policy.  Findings from any environmental compliance inspection or assessment conducted within the facility by others who use the checklist at Enclosure two (2) or Enclosure three (3) can be used as the quarterly environmental compliance inspection for the quarter the inspection occurred.  The EO does not have to conduct an additional inspection in that quarter.  However, the EO must comply with all other provisions of this policy.

(2) Completed quarterly environmental compliance inspection checklists and inspection reports will be kept and maintained on site for a minimum of four (4) years. Current year’s monthly environmental compliance inspection checklists will be maintained in an active file and the previous years’ checklist in an inactive file. If the current year’s inspection checklists are not maintained in the Unit Continuity Book, a notation will be made in continuity book as to the exact on site location of the completed checklists. 

(3) The inspected unit and organization EO will make recommendations to the commander on ways to correct management and operational deficiencies and submit maintenance service orders or work orders to DPW for the correction of facility deficiencies within ten working days after receiving the written Inspection Report from the Battalion or Brigade EO.  The Battalion or Brigade EO may require their units or organization to provide periodic reports of corrective action status.

(4) The unit and organization EO will seek support of the chain-of-command and guidance from the DPW Environmental Division as needed to correct deficiencies.

(5) The quarterly inspection requirement is waived for separate detached companies or organizations with no brigade or battalion headquarters within USAG- Humphreys.  Monthly Environmental Compliance Inspections shall still be conducted.

d. DPW Environmental Division Compliance Inspections and Assessments.

(1) Semi-Annual Environmental Compliance Inspections.

           (a)  DPW Environmental Division personnel will conduct semi-annual environmental compliance inspections using the Environmental Compliance Inspection Checklist at Enclosure two (2) or the Korean translated Environmental Inspection Compliance Checklist at Enclosure three (3) of this policy.

           (b)  A written Inspection Report will be provided to the EO of the inspected unit or organization within ten work days after completion of the inspection.  The Inspection Report will consist of a copy of the Inspection Checklist and UCAPs (if applicable). 

           (c)  The completed Semi-Annual Environmental Compliance Inspection Checklists and Inspection Reports will be kept by the unit or organization and maintained for a minimum of four (4) years.

           (d)  The unit or organization inspected by the Environmental Division is responsible for correcting all deficiencies. The EO will submit a Unit Corrective Action Plan (UCAP) to the DPW Environmental Division within ten working days after receipt of inspection results and findings. UCAPs are maintained as part of the inspection record for four (4) years.

           (2)  Follow-up Environmental Compliance Inspections.

           (a)  Follow-up inspections are complete re-inspections of all facilities and administrative documentation.

           (b)  Follow-up inspections will be conducted within 30 days, but not sooner than ten working days, after the initial semi-annual inspection by DPW Environmental Division personnel.

           (c)  The EO will submit a Unit Corrective Action Plan (UCAP) to the DPW Environmental Division within ten working days after the follow-up inspection and maintain UCAPs as a part of the inspection record for four (4) years. The Unit Corrective Action Plan will include the following:

           1 Description of the finding(s).

           2 Description of how the finding(s) is/are being corrected (who, what, when, where, how).

           3 Estimated date that the finding(s) will be corrected.

           4 Engineer work order numbers or service order numbers as appropriate.

          (d)  Other follow-up inspections may be performed as deemed necessary by the Environmental Division to assure unit or organizational compliance.  If additional follow-up inspections are warranted, a written Inspection Report will be provided to the next higher level Commander.

          (e)  Follow-up inspections will be conducted using the Environmental Compliance Inspection Checklist at Enclosure two (2) or the Korean translated Environmental Compliance Inspection Checklist at Enclosure three (3) of this policy.

          (f)  Follow-up inspection checklists and reports will become a part of the unit or organization environmental inspection record and maintained in the appropriate active and archived files.

          (g) The USAG-Humphreys Commander will be notified of habitual noncompliance of any unit or organization.

          (3)  Unannounced Spot-Checks. 

          (a)  Environmental Division personnel are authorized to enter any facility except private quarters to conduct environmental spot-checks.  Private quarters may only be entered with consent of the residents or prior approval by the commander.

          (b)  No checklist will be used and no official report will be generated except under the following circumstances; the unit or organization personnel are uncooperative in making simple on-the-spot corrections; a situation that is determined to be immediately dangerous to life, health and the environment is observed; or a blatant disregard of environmental regulations is observed.

          (c)  Environmental Division personnel will submit engineering service orders or work orders to DPW for those deficiencies noted in the spot checks that are beyond unit or organizational personnel’s capabilities to correct.  If a service or work order was previously submitted by the unit or organization, the Environmental Division employee will make note of the service or work order, check with DPW of status, and report status update information to the unit or organization EO.

8.   Inspection Standards.

 a. Hazardous Waste Accumulation Point Inspections.   This inspection will receive no score.  All elements listed in the Hazardous Waste Accumulation Point Weekly Inspection Checklist at enclosure one (1) must be answered “yes” to be classified as “compliant”.  All deficiencies noted will be immediately corrected.

 b. Environmental Compliance Inspections.  Each inspection element listed in the Inspection Checklist at Enclosure two (2) or the Korean translated Environmental Inspection Checklist at Enclosure three (3) will be rated based on the following rating scheme:

RATING RATING KEY
C Compliance:  Sufficient programs and activities completely in place to fulfill the intent of the inspection item.
NC Noncompliance: Programs and activities are not fully in place to support the inspection item; partial completion will be rated as “NC”
N/A Inspection item “Not Applicable” at the facility being inspected

c. Inspection Results.

(1) Initial Inspection: Commendable = must have no Noncompliance (“NC”) ratings. Satisfactory = must not exceed two (2) “NC” ratings in each section. NOTE: Failure to comply with any item marked with an asterisk (*) on the Inspections Checklist at Enclosure two (2) or the Korean translated Environmental Inspection Checklist at Enclosure three (3), will be considered an automatic “NC” for the entire inspection regardless of final grade.

(2) Follow-up Inspection:  Satisfactory = must not exceed one (1) “NC” rating in each section.  NOTE:  Failure to comply with any item marked with an asterisk (*) on the Inspections Checklist at Enclosure two (2) or the Korean translated Environmental Inspection Checklist at Enclosure three (3), will be considered an automatic “NC” for the entire inspection regardless of final grade.

(3) Inspection items marked N/A are “Not Applicable” in that particular facility and will not be rated against the facility being inspected.

9. Site Assistance Visits (SAVs).  DPW Environmental Division personnel will conduct
site assistance visits at any facility, if requested.  Site assistance visits are a resource tool to aid unit and organization EOs in achieving a positive compliance posture.  Site assistance visits are not environmental compliance inspections and cannot be used in lieu of the weekly, monthly, or quarterly compliance inspection requirements of this policy.

10.  Point of contact for this policy is the Chief, DPW Environmental Division, 753-7964.

 

3 Encls                                                                           DARIN S. CONKRIGHT
as                                                                                   COL, SF
                                                                                      Commanding

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