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Environmental Management (S-7)

 

Environmental Management (S-7)

"MORE THAN OUR CODE . . . IT'S OUR CORPS"

The Environmental Management System of MCAS Miramar
Compliance
 

DIVISION DIRECTOR
PHONE: 858-577-1137
Fax: 858-577-4200

PROGRAM OVERVIEW

The Compliance Division is the MCAS Miramar Environmental Management Department (EMD’s) section that monitors and evaluates environmental compliance through audits and inspections which assess:

  • Compliance findings
  • Identifies actions necessary to correct compliance deficiencies
  • Monitors corrective measures
  • Facilitates continual improvement of environmental compliance and performance

The EMD conducts audits and inspections of all units, tenants, waste generators and contractors to ensure environmental compliance and awareness.  During the audits and inspections, EMD does the following:

  1. reviews records, 
  2. observes work practices/equipment, and
  3. interviews personnel and surveys personnel on policies and procedures.  

The audits and inspections are conducted to support the units and tenants: preparing them for HQMC audits and regulatory inspections from local, state and Federal regulatory agencies.  These audits are designed to prevent Notices of Violations (NOVs) from outside regulatory agencies.

ENVIRONMENTAL REQUIREMENTS
PROGRAMS, PLANS, RESOURCES AND RESPONSIBILITES

The Compliance Division consists of the follow roles and associated responsibilities:

  1. One Operations Officer

Responsibilities of the Environmental Operations Officer include:

  • Manage the operations of the Environmental Management Department by coordinating with Division Directors of the Natural Resources, Engineering, Waste Management, Compliance, and Headquarters Divisions.
  • Manage the administration and day to day operations of the Division's Environmental Program Specialists and Comprehensive Environmental Training and Education Program Plan and Environmental Management System (EMS/CETEP) Coordinator.
  • Ensure all tenant units aboard Marine Corps Air Station Miramar maintain compliance with all environmental training and regulatory requirements based on Marine Corps Air Station Miramar, Marine Corps, Department of Defense (DoD), local, county, state, and federal laws, policies, and regulations.
  • De-conflict environmental actions with station and tenant unit mission requirements.

2. Two Compliance Inspectors

Compliance Inspectors are responsible for auditing/inspecting the following areas:

  •      Air Pollution Sources/Processes 
  •      Food Establishment Wastewater Discharge (FEWD) /Grease Traps
  •      Aboveground Storage Tanks (AST) and Spill Containment Control and Countermeasures (SPCC) 
  •      Underground Storage Tanks (UST)

3.   One EMS Auditor.

The EMS Auditor is responsible for auditing and assisting the Compliance Inspectors with:

     Annual Environmental Compliance Evaluation Annual Audit (ECE) which includes inspecting for the following:  

  • Environmental Management System (EMS) 
  • HW/MW Compliance

 

TRAINING AND COMMUNICATION

Training

Compliance Inspectors require multi-environmental media training as part of their role within the Environmental Management Department (EMD) in accordance with the Comprehensive Environmental Training Evaluation Plan (CETEP).

Training is completed in the following areas-

-       RCRA Training
-       Hazardous Waste Generator Training
-       APCD Source Training (Gas Station Operations, Painting Operations, etc.)
-       Internal environmental media training through subject matter experts (SMEs) and division directors
-       Lead Auditor Training
-       Environmental Compliance Coordinator (ECC) Training
-       Hazardous Waste Coordinator (HWC) Training
-       www.MiramarEMS.com

Communication

Communication regarding the most up-to-date Compliance issues for Station personnel (Military, Civilian and Contractors) is conveyed through:

-       Environmental Compliance Coordinator (ECC) Quarterly Meetings
-       Hazardous Waste Coordinator (HWC) Monthly Meetings
-       www.MiramarEMS.com
-       Emails, newsletters, etc.

 

To prepare and inform Units about upcoming inspections, Audit schedules are sent out with each environmental media inspection checklist which are reviewed and updated annually by media managers.

PRACTICE-ASPECT-IMPACT-RISK

 

Environmental compliance inspections/audits are designed to prepare units and tenants for HQMC, outside local, county, state and federal agency audits. These audits are designed to keep units, tenants, and installation personnel in compliance with environmental regulations and additionally prevent impacts to the environment, notices of violation (NOVs) and associated monetary fines.

Releases to the environment are prevented in order to ensure the protection of health, the environment and property.  Violations and fines have the possibility to adversely impact the Station, impede mission readiness, or negatively impact public opinion.

In order to ensure compliance and minimize the interruption of regular operations, the Station environmental media inspections look at the following criteria:

1.       Recordkeeping requirements

  •      Permits
  •      Plans
  •      Inspection records
  •      Training records
  •      Logs and other required documentation
  •      Billet Descriptions/Appointment Letters for designated personnel

2.       Site management

3.       Containers/labeling/accumulation time limits (HW/MW inspections)

4.       Equipment condition/leaks/other

5.       Operating instructions

6.       Knowledge of personnel (all media areas apply)

Unit inspection and audit reports / evaluations are submitted and reviewed through the following process:

1.    Reports are produced upon the completion of formal or informal audits and inspections. The purpose of these reports is to bring attention to the units, facilities or area where improved environmental compliance must be exercised.. 

2.    Formal reports containing findings from the audits and inspections are sent to the Commanding Officer/Department Head of the unit inspected.  Units are required to submit Corrective Action Plans (CAP) with supporting documentation (i.e. actions taken, photos, copies of documents/certificates/training rosters, etc.) to the EMD verifying the corrections have been completed.


 

OBJECTIVES-TARGETS-ACTIONS TO IMPROVE PERFORMANCE
AUDIT AND EVALUATION OF COMPLIANCE
The Compliance Division evaluates the efficiency of the Compliance Program by way of annual Self-Audits, as well HQMC triennial Audits.  Annual Self-Audits review and monitor Marine, Navy, Army, Civilian and Contractor units for Compliance with EMS requirements and Hazardous Waste compliance, both based upon Marine Corps Orders and local, county, state and federal regulations.

HQMC triennial Audits review and monitor all environmental media areas, as well as several other areas not encompassed under the EMD.