MCAS Miramar-EMS HomeDivisionsCompliance DivisionEnvironmental Compliance Evaluation (ECE)
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Environmental Compliance Evaluation (ECE)
Program Manager

858-577-1137

Federal regulations, Executive Orders, and the EPA’s Federal Facility Compliance Act of 1992 encourage environmental "auditing" (i.e., internal and external evaluations) to ensure environmental compliance. The Marine Corps ECE (Environmental Compliance Evaluation) program evaluates the overall environmental compliance of Marine Corps installations and the units and tenant commands operating on the installation. 

The ECE program assesses each of the following:

  • command's compliance risk level, 
  • actions necessary to correct compliance deficiencies, 
  • the monitoring of corrective measures, and 
  • the facilitation of continual improvement of environmental compliance and risk mitigation.
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ENVIRONMENTAL REQUIREMENTS

Department of Defense and Marine Corps Orders

Environmental Compliance Evaluation Scope
All Marine Corps installations shall participate in the ECE Program. Evaluations conducted under the ECE evaluate compliance with all

environmental program requirements and will include all operations and activities within the installation boundaries. The scope of evaluations will include tenant:

  1. activities, 
  2. out grants, 
  3. leases, and 
  4. all other activities under the purview of the United States Marine Corps. 

This program includes self-evaluations of installation programs with environmental requirements, evaluations of installation commands and tenants, and an HQMC oversight Benchmark ECE program. 

Installations are required to implement an annual Self-Audit Program that inspects each of the following:

  • every permitted site and source, 
  • every process which generates a waste or may be considered a potential source, and 
  • every command/unit and tenant. 

Installations shall also perform an annual EMS evaluation. HQMC will conduct “Benchmark ECEs” every three years to periodically assess installation environmental compliance and EMS conformance from an external point of view.

PROGRAMS, PLANS, RESOURCES AND RESPONSIBILITES

MCAS Miramar's ECE Responsibilities

  • Participate in the Marine Corps Benchmark ECE Program. 
  • Establish and implement a Self-Audit Program that annually evaluates installation environmental compliance by visiting every permitted site and source in addition to every practice which releases pollutants to air or water, generates a waste, or may be considered a significant environmental risk, and every command/unit and tenant. 
  • Publish ECE procedures as part of the installation ECPSOP. 
  • Supplement the IGMC inspections with installation environmental staff as needed to assess tenant units at the installation. 
  • Encourage cooperation between installation Safety and Environmental programs. 
  • When identified, follow up on safety-related findings identified through the ECE. 
  • Provide oversight of occupational safety and hazardous communication training requirements that are mandated by various references in conjunction with environmental programs.
TRAINING AND COMMUNICATION
CMC (LF) publishes a Baseline ECE schedule annually. The schedule establishes a three-year Baseline ECE cycle with a Benchmark ECE conducted at each installation every third year. CMC (LF) shall provide each installation a two-month advance written notice of the Benchmark ECE. In this notice, the installation shall be tasked with providing pre-ECE questionnaire and POC information.

The CMC (LF) and contractor Benchmark ECE team leaders will conduct an in-brief with the installation commander. The CMC (LF) and contractor Benchmark ECE team will normally meet each afternoon to discuss evaluation progress, problem areas, and coordinate the next day's schedule. Installation representatives are encouraged to attend these meetings. If the Benchmark ECE schedule permits,the CMC (LF) ECE team leader may allow installation or unit staff to read media-specific portions of the Benchmark ECE draft report for their information before the out-brief with the installation commander.

The CMC (LF) and contractor Benchmark ECE team leaders will conduct an out-brief with the installation commander and provide a copy of the Benchmark ECE draft report. The out-brief shall summarize significant findings or concerns including any that are important for the commander’s
awareness or that require the commander’s authority to correct.
PRACTICE-ASPECT-IMPACT-RISK

An ECE (Environmental Compliance Evaluation) is designed to identify practices/processes occurring on the installation and assess any environmental aspects applicable to those practices. Below, we list some examples of what an ECE will cover for a few of the major practices on the installation.

1. Practice: Aircraft Operations and Maintenance

Environmental Aspects:

  • Hazardous waste generation (e.g. spent fuels, oils, paints)
    • 90-day accumulations sites and satellite accumulation sites
  • Hazardous material storage
  • Abrasive Blasting
  • Paint Booths
  • San Diego Air Pollution Control District (APCD) air permits
  • POL (Petroleum and Lubricant) storage
  • Spill prevention control and countermeasure
  • Aerospace coatings
  • Stormwater pollution prevention
  • Authorized Use Lists (AULs)

2.Practice: Facilities Operations

Environmental Aspects:

  • Hazardous waste generation (e.g. household hazardous waste and universal wastes)
  • Hazardous material storage
  • Boilers
  • Emergency generators
  • Spill prevention control and countermeasure
  • Solid waste and recycling
  • San Diego APCD air permits

3.Practice: Vehicle Maintenance and Motor T Operations

Environmental Aspects:

  • Hazardous waste generation (e.g. spent oils, antifreeze, oil filters, spent fuels, and oily rags)
    • 90 day accumulation sites and satellite accumulation
  • Hazardous material storage
  • Stormwater pollution prevention (e.g. oil drip pans under vehicles)
  • Spill prevention control and countermeasure
  • Spill response procedures
  • Solid waste and recycling
  • Authorized Use Lists (AULs)
OBJECTIVES-TARGETS-ACTIONS TO IMPROVE PERFORMANCE

Conducting an annual self-evaluation within timeframes established by leadership. Each environmental media manager proactively identifies problems, deficiencies and/or positive findings within the established self-evaluation timelines, and reporting each finding and corrective action with the WEBCASS system.

Providing a framework and atmosphere of cooperation and assistance to external auditing teams during triennial evaluations. Correcting and completing all corrective actions identified by external auditing teams within established  timeframes, and properly documenting those corrective actions with associated EMS root causes within the  WEBCASS system within required deadlines.

AUDIT AND EVALUATION OF COMPLIANCE

The installation Self-Audit program is evaluated during the HQMC triennial Environmental Compliance Evaluation. Program elements of the ECE program are also evaluated at this time.