Assessing Environmental Performance Overseas

Department of Defense (DoD) operations at overseas military installations are subject to the same environmental regulations and standards as general industry in the country. Environmental compliance at DoD installations is the ultimate responsibility of the installation commanders, and installations are responsible for identifying all environmental requirements that apply to them. Installation commanders are typically supported by a local or regional environmental program office. To support Army installations, the U.S. Army Environmental Center (USAEC) funds and administers a computerized assessment tool referred to as the Army Environmental Performance Assessment System (EPAS). A critical aspect of using EPAS is an understanding of the requirements to which an installation is subject.

When looking at overseas installations, the question then becomes "what are the environmental regulations and standards that the installation must follow?" This question arose recently when Battelle assisted the U.S. Army Center for Health Promotion and Preventative Medicine (CHPPM) in EPAS reviews of 10 Army installations in Korea. By agreement, the DoD and the Republic of Korea (ROK) defined the United States Forces Korea Environmental Governing Standards (EGS). The EGS represent the set of environmental rules and regulations by which the Army installations located in Korea will abide. It became the responsibility of the installation assessors to be aware of the requirements and the manner in which they must be implemented. As one of the assessors, Battelle then had to evaluate the operations at the installations and determine if they were in compliance with the EGS.

Related to these assessments is the DoD environmental quality program, which includes procedures for identifying high-priority environmental activities thatrequire attention in order to maintain compliance with environmental requirements. As presented in a recent report by the U.S. General Accounting Office (GAO - Better DOD Guidance is Needed to Ensure That the Most Important Activities are Funded, GAO-03-639, June 2003), the DoD's environmental quality policy uses a general classification system to prioritize environmental activities as follows: (see box)

The Army's current policy is that all Class 0 and 1 activities be funded and corrected. EPAS provides a single tool to write, organize, and track all findings/ corrective actions for an installation. The EPAS process includes a findings report and an Environmental Performance Assessment Report (EPAR) which details the corrective actions for the findings. To allow implementation of the policy for funding corrective actions, the assessors had to define each finding as a Class 0, 1, 2, or 3 and estimate the cost to correct the situation. The decision to fund a corrective action is then made by the installation commander in response to DoD policy.

Some of the more difficult aspects of conducting an EPAS in a foreign country include ensuring the accuracy of both the regulatory requirements and the Class of a finding. Subtle differences exist between regulatory requirements in the U.S. compared to foreign countries. For example, installations in the U.S. would rarely, if ever, consider releasing domestic sewage to an open channel. Because no EGS exists that prohibits such action in Korea, however, finding raw domestic sewage in an open ditch could only be classified as a Class 3 (i.e., good management practice) finding. Another difficult aspect of using the EGS

General classification system to prioritize environmental activities: Class 0 represents recurring activities needed to keep an environmental program running, such as employee salaries, permit costs, and supplies. Class 1 represents a condition of noncompliance with existing federal, state, or local regulation. Class 2 represents a condition of potential noncompliance with future regulatory requirement or deadline. Class 3 represents a condition of noncompliance with Army/DoD regulation or inconsistency with good management practice.

is that some standards are included by reference. For example, the National Fire Protection Act (NFPA), which in part specifies separation distances between fuel storage tanks and facility boundaries, is included by reference in the EGS for tanks. Because many installations did not have direct access to a full set of the NFPA, the assessor was responsible for determining if the installations considered standards they may not have even been aware of during design and construction of new tank facilities.

Coupled with these technical challenges was the need to respect the social and cultural differences between our countries. This was accomplished by valuing the exchange of culture while bringing current knowledge of environmental practices to the client.

Information on Battelle's capabilities to support environmental compliance programs at government and industrial facilities can be obtained by contacting Mr. Joe Carvitti at (614) 424-4843, carvittij@battelle.org.