What is EPAS? • Environmental Performance Assessment System • Mandated by AR 200-1 • Program for auditing installation-level environmental performance ‒ Key element in the plan-do-check-act framework of EMS as part of ISO 14001 • Provides a proactive approach to compliance with environmental laws ‒ Includes federal, state, and local regulations; Executive Orders; Army regulations; Department of Defense (DoD) directives and instructions; and DoD, Army, and USAR policies UNCLASSIFIED / FOUO 1 Leadership. Energy. Execution.
What is EPAS? • Purpose is to identify risks that may affect their Triple-Bottom-Line of Mission, Environment, and Community • Allows for economic analysis and recommended solutions to issues before they become high-level concerns • Designed to identify compliance deficiencies, develop corrective and preventive actions, determine resource requirements, and track the implementation of corrective and preventive actions. • Internal vs. External Assessments UNCLASSIFIED / FOUO 2 Leadership. Energy. Execution.
Goals of EPAS • Minimize environmental impacts and risk while improving mission readiness • Identify potential environmental problems that may result in Notices of Violation (NOVs) and fines before the regulators find them • Assist in correcting environmental problems through Installation Correction Action Plan (ICAP) Management • Prevent environmental problems through root cause analysis in an EMS Framework UNCLASSIFIED / FOUO 3 Leadership. Energy. Execution.
Solid Waste & TEAM Guide • Legislation surrounding SW: ‒ Resource Conservation & Recovery Act of 1976 ‒ Solid Waste Disposal Act of 1965 ‒ OSHA ‒ CAA ‒ Executive Orders ‒ State and local regulations ‒ Readiness Division (RD) Policies and Guidance UNCLASSIFIED / FOUO 4 Leadership. Energy. Execution.
Solid Waste & TEAM Guide Key Compliance Requirements: • Storage/Collection/Containers (SO.10.1.US – SO.10.6.US) • Recycling (SO.25.1.US – SO.25.8.US) UNCLASSIFIED / FOUO 5 Leadership. Energy. Execution.
Solid Waste Mgmt. Plan Actions • Implement an Integrated Solid Waste Program Foundation • Create and Manage a Recycling Program RD Facilities • Increase Solid Waste Diversion through Source Reduction, Reuse, and other Methods • Develop a Sustainable Procurement Program UNCLASSIFIED / FOUO 6 Leadership. Energy. Execution.
Recycling Training Develop and Implement a Recycling Awareness and Education Plan Issues observed: • Posters promoting recycling and diversion left over from a previous support command and were not provided by the RD • Posters observed in areas were no recycling containers were provided • Recycling dumpsters available but no educational material in the facility to promote the use of the dumpster • Outdated information at facilities Implementation: • EPAS Assessors are the primary education and training source available to staff and Soldiers at facilities • Environmental Division staff should assess current educational materials available, identify additional needs, and develop an education and promotion plan UNCLASSIFIED / FOUO 7 Leadership. Energy. Execution.
Recycling Containers/Supplies Provide facilities with Recycling Containers/Supplies Issues observed: • Recycling containers are not consistently provided at RD facilities • Recycling containers are observed at some facilities but there is no consistency for the type, size, use, or location of these containers • Some facilities have recycling dumpsters available but no way of collecting material for recycling inside of the facility • Some facilities are using the recycling containers for refuse because they do not have an adequate number of refuse containers Implementation: • Inventory the facilities that already have recycling containers • Obtain containers for remaining facilities • Costs could be high because of the number of facilities; gradually roll out to spread costs over multiple years • Initial rollout of containers should be to facilities that have recycling dumpsters and/or have many employees UNCLASSIFIED / FOUO 8 Leadership. Energy. Execution.
Recycling Integrate Recycling into Battle Assemble Activities for Soldiers and Staff Issues observed: • Dumpsters often observed overflowing with waste until collection day • Under these circumstances, refuse was also observed in the recycling dumpsters because of a lack of available space in the refuse dumpsters Implementation: • Develop a standard operating procedure for implementing a recycling program for Battle Assemble weekend training sessions Identify Innovative Opportunities that May Lead Toward Net Zero Waste Issues observed: • Promotion of net zero strategies are not observed at facilities or mentioned during staff interviews Implementation: • Explore opportunities to reduce, reuse, recycle, or donate excess material before disposal; continue to monitor for new technologies and track improvements made other Army facilities for initiatives that could be implemented at RD facilities UNCLASSIFIED / FOUO 9 Leadership. Energy. Execution.
Recycling and Custodial Contracts Modify Custodial Contracts to Include Collection of Recyclables Issues observed: • Lack of personnel responsible for taking the recyclables out to the dumpster • Current custodial contracts only cover emptying refuse containers, which disincentives the use of any available recycling containers in the facilities • People were less likely to use the recycling containers if they are available when they knew they had to empty the container themselves • Custodial contractors are observed emptying the recycling containers but into the same dumpster as the refuse Implementation: • Assess contracts for all facilities should be conducted by the RD • Modify contracts to include the type of recycling services needed (e.g., empty desk- side recycling bins nightly, empty centrally located recycling bins, dispose of recycling in the designated recycling dumpster, and how often to collect materials) • Require in contracts that custodial staff be educated about contract requirements surrounding the recycling program at each facility • Include custodial staff as partners in the program to help lower contamination levels and increase diversion UNCLASSIFIED / FOUO 10 Leadership. Energy. Execution.
Recycling Data Tracking Implement Data Tracking and Reporting to Evaluate Effectiveness of Diversion and Recycling Programs Issues observed: • At the time of the data gathering, no tracking of actual waste tonnages was being conducted at RD facilities Implementation: • Track the quantity of materials recycled and disposed UNCLASSIFIED / FOUO 11 Leadership. Energy. Execution.
Recycling Actions Impact? • Increased awareness of the recycling potential • Increased participation in recycling programs • Increased probability of meeting diversion goals • Improved administrative structure and convenience of the program by assigning specific responsibilities to staff • Assists in complying with federal, DoD, Army, state, county, and local regulations UNCLASSIFIED / FOUO 12 Leadership. Energy. Execution.
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