Implementation and Operations - EMS Element 5 - 11

Element Purpose & Overview

MCAS Miramar documents and communicates roles, responsibilities, and programs to ensure effective environmental management and the availability of resources required to implement and maintain its environmental management system (EMS) .  Resources include staff resources with specialized skills, organizational infrastructure, technology, and financial resources.

The Environmental Management Department takes a lead role to ensure that the EMS is properly implemented.  Environmental programs, however, are not assigned exclusively to the Environmental Management Department, and other organizations (e.g., Facilities, Safety, and Medical), play key environmental management roles.  The Organization Chart depicts the EMS Program Manager's reporting relationship relative to other functions within the base. 

References:

MCO 5090.2 (JUN 2018)

Environmental Management Procedure

MCAS documents and communicate EMS roles, responsibilities, and authorities for:       

• The EMS Team (EMS Team include personnel from environmental and other departments, including but not limited to: mission units, logistics, facility, energy, and technical support functional areas and other functional areas as appropriate),     
• EMS Manager,
• Environmental program managers and staff,
• Practice owners including tenants and on-site contractors.
• EMS Management Review Team (The MCAS CO designated the Environmental Impact Review Board EIRB) as the EMS Management Review Team (EIRB Designation Letter).

EMS roles, responsibilities, and required competencies/qualifications are documented in the EMS Roles and Qualifications.  The Human Resources office is responsible for integrating personal EMS performance into organizational reward, discipline, and appraisal systems in accordance with MCAS Miramar policies on such matters.  MCAS identifies contracts that can affect its significant aspects, and maintains an inventory of such contracts if applicable.  MCAS includes requirements in all appropriate contracts to ensure that contractor’s responsibilities under the EMS are properly addressed, to include control of government-owned, contractor-operated practices that have such significant aspects.   

OOD/CDO turnover folders contain an environmental staff recall roster and coordinating instructions for emergency reporting (e.g., hazardous substance spills).  MCAS and tenant unit response plans and other contingency plans or procedures require the OOD/CDO to be contacted immediately after contacting emergency response personnel.

All MCAS units will appoint Unit Environmental Compliance Coordinators (ECCs).  ECCs shall:

• Be an E-5 or above or other individual with sufficient authority to implement environmental requirements at the command, and be appointed for at least one year in this role.  (Unit ECC appointment letter)
• Complete the MCAS Miramar Hazardous Waste Coordinator's (HWC) Course. Unusual exceptions to this requirement must be approved by the station CETEP Coordinator.
• Complete the Environmental Compliance Coordinator's CBT course on Marine Net (or similar certified course) prior to assignment.
• Complete Miramar's Environmental Compliance Coordinator training course.
• Ensure members of the unit who require environmental training receive it.  Coordinate with the installation CETEP Coordinator to schedule environmental training and report training status.
• Coordinate with installation environmental representatives as required to ensure all environmental requirements at the unit are being sufficiently addressed.  Complete applicable unit environmental checklists to ensure environmental compliance requirements are satisfied.  Report problems up the chain of command.

Environmental billet holders must develop and maintain desktop procedures and turnover folders. 

Element Purpose & Overview

MCAS Miramar has identified training needs associated with its environmental practices, aspects, and impacts, and its environmental management system (EMS) and provides this training through Comprehensive Environmental Training and Education Program (CETEP). 

MCAS Miramar maintains a training program designed to make relevant personnel aware of the following:

• The importance of conforming with the EMS Policy and complying with regulations,
• Their responsibilities for implementing the EMS
• Their roles and responsibilities for emergency preparedness and response
• The significant environmental aspects of their practices, the procedures and operational controls that are in-place to control their practices so as to operate in a compliant and environmentally sound manner, and the potential consequences of departure from specified procedures.

References:
 MCO 5090.2 (JUN 2018)

Environmental Management Procedure

Installation environmental training requirements are executed via  CETEP , which is described in MCO 5090.2 (JUN 2018), and which is codified in the MCAS Order 5090.3.

Identifying and Communicating Training Needs

Training needs and requirements are identified for each affected job/function and documented in the Training Topics Summary. 

Providing Training

The CETEP Coordinator works with the Environmental Management Director and affected Environmental Department/Program Managers to maintain the training program.

For more information on the CETEP, go to the CETEP Program Page.

Training Records

Training records with signatures of EMS training participants as well as EMS Certificates of EMS trained personnel are maintained by the CETEP Coordinator and are available upon request.

If training is needed by Miramar personnel, various environmental web-based trainings can be utilized on MarineNet.  MarineNet supplements training, provides a printable certificate once each training course is completed, and retains a history of personnel that have completed each training course.  In addition, MCI West installations have developed Environmental SOPs and computer based trainings (CBTs), which support the SOPs to meet the training requirements for EMS.

Element Purpose & Overview

MCAS Miramar uses this public-facing website as the primary means to communicate environmental and EMS information to all appropriate, interested parties.  This website is intended to serve as the EMS manual and to provide tools for the operation of Miramar’s EMS.  This system allows media managers with no website development experience to edit and update their media webpages.  This website is designed to maximize the effectiveness of communication among environmental program stakeholders.  Additionally, MCAS Miramar uses a variety of other methods and media (e.g., bulletin boards, intranet, world wide web, annual reports, etc.) for internal and external communication.

MCO 5090.2 (JUN 2018)

Environmental Management Procedure

Each environmental program page at this website has a section titled TRAINING AND COMMUNICATION which presents material specific to that program and relevant to this EMS element. 

Internal Communication

The EMS Team is responsible for communication of the EMS Policy to all employees by using this website.

The EMS Coordinator communicates with the EMS Team, environmental program managers, members sitting on the Management Review, unit Environmental Compliance Coordinators (ECC), and others within the Marine Corps who are interested in the installation's environmental affairs. 

Unit ECC's communicate environmental information to personnel in their units.

Personnel report EMS deficiencies or refinements to their unit ECC or directly to the EMS Coordinator.  The EMS coordinator will respond to reports of deficiencies or shortcomings in accordance with the Problem Solving EMS Element 14  (scroll down to EMS Element 14).

EMS documentation is uploaded to ECMS per guidance in MCO 5090.2 (JUN 2018)
 .

External Communication of Information

Regulatory Agencies - The Environmental Management Division Director has authorized Environmental Program Managers to contact the regulatory agencies as needed.  With the ever-changing flexibility and diversification of electronic media, Program Managers maintain individual pertinent documentation within their own email and telephone logs as appropriate.  If the communication notification relates to an enforcement action, EMD staff will follow the procedure established in MCO 5090.2 (JUN 2018).

Non-regulatory External Parties - Inquiries and communications concerning the MCAS’s EMS and/or environmental performance are directed to EMS Team, the EMD staff, or other cognoscente staff for determination of an appropriate response.  Based on the circumstances of the communication received, the EMS Team or other appropriate staff will determine the best course of action and notify the EMD Director.  The EMD Director will direct action, as appropriate; recording relevant information in email or telephone logs as appropriate.  With the exception of regulatory agencies, the Public Affairs Office will often select the most appropriate method to communicate with external stakeholders and interested parties.

As a standard of business practice, any communication with external parties other than regulatory agencies, is made between the program manager and the interested party with a courtesy copy (cc) to the EMD department heads as appropriate.  All documentation of conversations with these interested parties is maintained by the appropriate person (Program Manager, SME, EMD Dept Head, etc.) within the department.  The EMD Director maintains copies of all communications from external parties, other than regulators, on environmental matters as needed.  All records of external communications are maintained in accordance with the Control of Records EMS Element 15  (scroll down to EMS Element 15).

Outreach to Interested Parties

MCAS Miramar may solicit the views of external interested parties on its environmental program EMS, as the need arises.  Such situations may include facility expansions, application for issuance or renewal of environmental permits, special events such as Earth Day, occurrence of an emergency response situations, etc.  The Public Affairs Office will coordinate and document these kinds of outreach.

The results of, effectiveness of, and need to continue, proactive external communication efforts will be evaluated during the Management Review process.

Communication of Emergency Situations 

All personnel are responsible for reporting environmental hazards, accidents, and emergency situations immediately upon discovery, in accordance with the Facility Response Plan. 

Element Purpose & Overview

Miramar uses this website, its internal intranet, and the USMC’s EMPortal and ECMS websites to maintain its EMS documentation.  The intent is that the MCAS EMS resides “in the cloud” so that all EMS stakeholders can have access to current, controlled documentation from most any location.  This website, in particular, communicates:

• EMS elements (a description of EMS elements, their interaction, the environmental management procedures to implement them),
• The location of documents and records relevant to the EMS.

References:
MCO 5090.2 (JUN 2018)

Environmental Management Procedure

The EMS Coordinator and any assisting EMS Team will maintain EMS documentation and or links thereto at the appropriate EMS element on this website.  Documents necessary to ensure the effective planning, operation, and control of processes that relate to significant environmental aspects or to facilitate effective environmental management will be maintained by EMD program managers at the appropriate program page or at one of the other "cloud" sites. 

A list of items required to be posted to the EM Portal is included MCO 5090.2 (JUN 2018)

Element Purpose & Overview

  MCAS Miramar inventories documents appropriate to its environmental programs and practices and identifies other documents essential to the efficient operation of its EMS.  Miramar implements a system to maintain documents "in the cloud” so that they:

• Can be located,
• Are reviewed and updated as necessary, and
• Are available in their current, controlled versions.

References:
MCO 5090.2 (JUN 2018)

Environmental Management Procedure

The EMS Coordinator, EMS Team members, and EMD program managers will identify document requirements appropriate to environmental programs and practices and essential to the effective operation of the EMS, based on applicable regulatory and policy requirements, EMS Policy and conformance requirements, and best management practices.

All EMS and environmental program managers will:

• approve documents prior to issue or publishing,
• review and update documents, as necessary,
• ensure documents changes and revision status are identified,
• ensure documents are available when and where needed,
• ensure documents are legible and identifiable,
• ensure documents of external origin determined by the organization to be necessary for the planning and operation of the EMS are identified and their distribution is controlled,
• if obsolete documents are retained for any purpose, identify and archive them so as to prevent their unintended use.

Documents related to environmental management are maintained by EMD program managers at the appropriate program page or linked on the webpage to one of the other cloud sites.

EMS and environmental program managers will use the electronic document library function of the EM Portal and this website to meet document retention and control requirements of MCO 5090.2 (JUN 2018).  The EMS coordinator will approve any hard-copy versions of documents to be retained without an electronic controlled version residing “in the cloud.”

A list of items required to be posted to the EM Portal is included at MCO 5090.2 (JUN 2018). 

Personnel who print documents from a “cloud” source are notified here that such printed documents are, by definition, uncontrolled the instant they are printed.

Element Purpose & Overview 

Miramar ensures that each significant practice on the installation is controlled to sufficiently minimize risk to mission and impacts to the environment and to comply with all applicable regulations and policy.  “Owners and operators” of significant practices have procedures for the proper control of their practices which reduce environmental risks.  These procedures are included in Marine Corps or higher tier orders, the Miramar ECPSOP (StaO 5090.4) and other station orders, environmental media management plans such as the Spill Prevention Control and Countermeasures Plan and the Integrated Natural Resources Management Plan, and Environmental Standard Operating Procedures (ESOPs).

References:
MCO 5090.2 (JUN 2018)

Environmental Management Procedure

The EMS Core Team, in cooperation with environmental program managers, will determine what operational controls are needed for practices with significant environmental risk.  They will also determine the most effective means to establish these controls: plan, order, ESOP, etc.  They will also periodically review practices for the potential to cause significant environmental impact, and will incorporate or reference environmental control requirements as necessary.

Whatever the means, practice control procedures will include instructions for operational control, internal communication, emergency preparedness and response, inspection and corrective action, and training and awareness applicable to the practice, as well as who is responsible for implementing actions and how often they are to be carried out. 

Operating procedures are developed, approved, reviewed, updated and distributed in accordance with the EMS Element 9, Control of Documents.  EMD program managers will ensure relevant Environmental SOPs are shared with contractors and suppliers that are affected by the procedures.

Program-specific orders, plans, and ESOPs are located or linked at each program page at this website under the sections, Environmental Requirements; Programs, Plans, Resources & Responsibilities;

Unit Environmental Coordinators are responsible for developing operating procedures specific to their unit and for providing training in relevant operating procedures to affected personnel.

A list of items required to be posted to the EM Portal is included at MCO 5090.2 (JUN 2018).

Element Purpose & Overview

MCAS Miramar  has established, implements, and maintains procedures to identify potential emergency situations and potential accidents that can have an impact(s) on the environment and how it will respond to them.

 MCAS Miramar responds to actual emergency situations and accidents and prevents or mitigate associated adverse environmental impacts.  MCAS Miramar also periodically tests its procedures, where practicable.  

MCAS Miramar periodically reviews and, where necessary, revises its emergency preparedness and response procedures, in particular, when new practices are initiated or after the occurrence of accidents or emergency situations. Procedures to be followed in the event of an accident or emergency are communicated to building managers and practice owners in scope and detail appropriate to their responsibilities.

References:
MCO 5090.2 (JUN 2018)

Environmental Management Procedure

MCAS Miramar's defense posture includes emergency preparedness and response scenarios that are diverse and ever-changing.  With today's threats, come challenges of preparing for and overcoming new practices and potential new types of accidents or emergencies.  The MCAS Miramar Mission Assurance Division of the air station's Operations Department (S-3) is responsible for identifying environmental impacts/scenarios associated with potential emergency situations and accidents.  

The MCAS Miramar All Hazards Plan is maintained by the Mission Assurance staff assigned to S-3 and identifies S-7's responsibilities for responding to and mitigating potential impacts to the environment.

MCAS Miramar's Environmental Management Department maintains the Command Duty Officer (CDO) Procedures for Environmental Incidents that Involve Hazardous Materials or Threatened Natural Resources.  This station order is distributed to each unit on the installation through the unit's Environmental Compliance Coordinator and is linked here: CDO Procedures

The MCAS Miramar Above Ground Storage Tank (AST) and Underground Storage Tank (UST) Program Manager maintains spill response procedures in a Spill Contingency Plan (SCP).  The MCAS Miramar Facility Response Plan (FRP) was developed and contains the SCP.  The procedures are for discovery, identification, and notification of a spill; immediate action and on scene coordination; containment and control; clean up and decontamination; disposal; and spill reporting documentation and cost recovery.  MCAS Miramar's Mission Assurance Division is responsible for the maintenance and distribution of the Facility's All Hazards Plan.  

Distribution and control of the Response Plans are performed in accordance with the EMS element 9, "Document And Record Control". However, due to the nature of emergency events and the need to have immediate access to relevant information during an emergency, response plans are distributed in hard copy to members of the various Facility Teams.

Next Page: Checking and Corrective Action - EMS Elements 12-16