1. 1 Building Strong! Environmental Management Systems at US Army Corps of Engineers (USACE) Civil Works Facilities: Lessons Learned and Next Steps Federal Environmental Symposium, East 16 June 2009

2. 2 Building Strong! USACE Civil Works (CW) Overview USACE Civil Works Business Lines –Hydropower, –Navigation, –Flood and Coastal Damage Reduction, –Recreation, –Environmental Stewardship 8 “Divisions” 40 “Districts” Over 400 “Projects” –A single Project may consist of multiple Project Sites, and may support multiple missions (as listed above) –Roughly 700 “Project Sites” have significant Environmental Compliance (EC) requirements –Park Rangers generally have the lead for the Project-level EC program

3. 3 Building Strong!

4. 4 Opekiska Lock and Dam, Monongahela River, Fairmont WV (Navigation)

5. 5 Building Strong! Libby Dam, Montana (Hydropower, Flood Control, and Recreation)

6. 6 Building Strong! John H. Kerr Dam, Boydton, VA (Flood Control, Hydropower, and Recreation)

7. 7 Building Strong! Burnsville Campground, Huntington, WV

8. 8 Building Strong! Evolution of EMS in USACE 2000…2001…2002…2003…2004…2005…2006…2007…2008…2009…2010 Army EMS PolicyDoD EMS Policy USACE Env. Operating Principles (EOPs) EO 13148 USACE EMS Policy Identifying and “Phasing” Appropriate Facilities Re-emphasizing EMS at Appropriate Facilities EO 13423 USACE EMS Metrics Self Assessment Federal Multi-Site Organization (MSO) EMS Guidance USACE draft MSO EMS-Based Compliance Policy Linking “Environmental Operating Principles” and EMS Incorporating “Multi-site Organization EMS” in USACE Policy

9. 9 Building Strong! USACE EMS Self Assessment (FY08 Federal Metrics) USACE Overall: 27 appropriate facilities covered by 22 EMSs……………Red

10. 10 Building Strong! Listening, Learning and Adapting: Summary of EMS Implementation Issues from FY08 Metrics Environmental compliance performance data is being tracked, but its not being reviewed consistently by leadership Intermediate levels of leadership are not “engaged” EMS is viewed as duplicative, particularly of the environmental compliance assessment (“ERGO”) business process EMS is viewed (largely) as another duty assigned to the Environmental Compliance (EC) lead…who is already too busy EMS requires training that is competing with other training requirements EMS is viewed as the EC lead’s “program” EMS creates additional administrative burden at the Project level Resource Issues: Manpower, Funding and Leadership Support

11. 11 Building Strong! Listening, Learning and Adapting: Input from the Field Systematic application of the USACE CW EC Assessment Process (“ERGO”) since 1991 has driven reduction of CW Operations environmental footprint: –Reduced use of hazardous materials and generation of hazardous waste –Reduced the number of regulated underground storage tanks –Virtually eliminated on-site vehicle maintenance activities How can USACE build on ERGO success to move USACE forward with EMS? Comment from the Field: “…EMS appears to duplicate the ERGO process…why are we doing both?”

12. 12 Building Strong! ISO 14001 – USACE ERGO “Gap Analysis” 4.2 Environmental Policy 4.3 Planning 4.3.1 Environmental Aspects 4.3.2 Legal and Other Requirements 4.3.3 Objectives, Targets and Programs 4.4 Implementation and Operation 4.4.1 Resources, Roles, Resp., Authority 4.4.2 Competence, Training, Awareness 4.4.3 Communication 4.4.4 Documentation 4.4.5 Control of Documents 4.4.6 Operational Control 4.4.7 Emergency Preparedness and Response 4.5 Checking 4.5.1 Monitoring and Measurement 4.5.2 Evaluation of Compliance 4.5.3 Non-conformity, Corrective Action & Preventive Action 4.5.4 Control of Records 4.5.5 Internal Audit 4.6 Management Review ER 200-2-3 (Section 1-1 and Chapter 5, ERGO) Pre-assessment scoping, team assignments, etc Pre-assessment checklist * ERGO Manual/TEAM Guide ERGO Performance Measures, ER 200-2-3 ER 200-2-3, Chapter 5 (ERGO) ECC, ERGO, and OMBIL training ER 200-2-3 internal comm. for ERGO ERGO Manual, including procedures Procedure for annual updates of ERGO manual CW Operations mission SOPs Spill Plans, exercises, etc… ERGO is “checking and corrective action” for EC Operations mission SOPs and permits req’ts ERGO and “other” relevant compliance req’ts N/A for ERGO Tracking findings to closure; OMBIL data entry Project-level audits; HQ-level audits Exists for ERGO but isn’t used effectively… ISO 14001 (2004) Elements ERGO Process * Blue Text indicates areas where the ERGO process needs to be enhanced.

13. 13 Building Strong! Environmental Compliance Program Issues Inconsistent management/leadership focus and emphasis on compliance Lack of funding for EC requirements and closure of ERGO findings Lack of manpower to execute ever-expanding EC requirements, i.e., the “compliance lead” can’t make compliance happen on their own Lack of consistency in environmental compliance management Resource Issues: Manpower, Funding and Leadership Support

14. 14 Building Strong! Opportunities to Improve the EC Program EO 13423 (EMS, Transportation, Energy, Toxic Chemicals….) Emerging Federal focus on multi-site organization EMS USACE “Quality Management System” Common missions across USACE Civil Works Robust, and well understood, “ERGO” business process Update of USACE Environmental Compliance policy

15. 15 Building Strong! Next Steps: Using “Opportunities” to Resolve “Issues” Overall approach : Build an EMS using the existing EC assessment (ERGO) business process –Get buy-in – Compliance-focused, multi-site organization EMS –Build a team – recognized experts from across USACE –Do a Gap Analysis –Build the policy – Address “gaps” in USACE Environmental Compliance policy to complete an EMS framework based on the ERGO business process –Provide training, tools and procedures to enable implementation Centrally fund and develop “standard” EMS tools and procedures using USACE “QMS” tools Locally adapt standard tools and procedures = In progress = Complete

16. 16 Building Strong! USACE Multi-Site Organization EMS Concept USACE Division District Project

17. 17 Building Strong! Don’t Lose Focus on EMS Fundamentals… Success in a multi-site organization EMS is founded upon: –Focus on sound management of the “significant environmental aspects” at the project level –For each individual whose job involves a significant environmental aspect: Awareness of his/her role in the EMS The training and competence to do their job in an environmentally sound manner –Maintaining operational control of local mission activities at all times The framework of the EMS will ensure all levels of command are involved as necessary to effectively manage and improve environmental performance

18. 18 Building Strong! Anticipated Benefits of Compliance-Focused Multi-site Organization EMS Take advantage of “common” missions at CW Projects to streamline and standardize EMS, and to reduce “EMS” administrative burden Bring structure to the EC program -- prioritization, measurement, accountability, and leadership engagement/support/oversight Better focus limited resources -- including money, manpower and leadership attention -- at all levels of USACE (project, District, Division, and HQ) on our most challenging environmental issues Improve leadership engagement – establish objectives/targets and environmental management programs to “enable” EC efforts and to measure and document successes and challenges Improve Support for EC program requirements -- Use documented track record of success/failure to improve manpower and funding availability for EC requirements…so we can improve the EC program USACE-wide

19. 19 Building Strong! Questions?