Spotlight: Compliance Experience

Sustainability Assessment and Implementation Plan, MCAS Camp Pendleton

Marine Corps Air Station (MCAS) Camp Pendleton tasked PHE to assess the state of its environmental programs and their ability to meet emerging sustainability requirements, and to recommend improvements to meet Department of Defense (DoD) sustainability goals in DoD’s FY10 Strategic Sustainability Performance Plan (SSPP).  The DoD SSPP goals were based in Executive Orders (EO) 13423 and 13514; relevant laws and regulations; and DoD, Navy and Marine Corps policy.  PHE provided sustainability analysis and recommendations in a single document that included the following elements:

  • A Sustainability Gap Analysis that identified and assessed strengths and weaknesses of current Air Station sustainability initiatives, and
  • A Sust ainability Implementation Plan that provided recommendations to improve identified gaps and established a detailed strategy for enhancing MCAS Camp Pendleton sustainability initiatives.

The MCAS Camp Pendleton Sustainability Gap Analysis was performed in three distinct steps:  (1) PHE collected information on existing sustainability elements at the Air Station through document/record reviews and onsite interviews with personnel from across the Air Station organizational structure (including environmental, supply/procurement, ROICC, and PWD); (2) PHE then documented findings against SSPP requirements to identify program areas in place and those requiring improvement; and (3) PHE made specific and actionable recommendations for improving those programs in measurable, documentable ways.

Program Areas Assessed:

  • Energy Management (Energy Intensity and Renewable Energy Sources)
  • Water Resources Management (Potable Water Use, Wastewater and Stormwater Management) 
  • Greenhouse Gas (GHG) Emissions
  • Solid Waste Management
  • Sustainable Acquisition (Green Procurement)
  • High Performance Sustainable Buildings (HPSB)
  • EMS and Sustainability Management
  • Chemicals of Environmental Concern (Toxics Reduction, Electronics Stewardship, and Pesticides Management)

Wastewater Treatment Plant Optimization Study and Permitting Support, Marine Corps Air Ground Combat Center Twentynine Palms, CA

PHE completed a detailed Wastewater Treatment Plant (WWTP) Optimization Study to assess WWTP design and operations with a focus on energy, water conservation, and operational efficiency.  As part of this project, PHE completed a comprehensive engineering condition assessment of the WWTP and a detailed evaluation of three alternatives, including:

  • Maintaining current operations with limited physical modifications and improvements to operation and maintenance of systems and equipment;
  • Constructing an aerobic package facility at the current location thereby replacing the current WWTP; and
  • Constructing a new WWTP at an alternate location.

PHE also conducted site visits to perform a detailed assessment of facility equipment and systems with staff and collect energy usage and equipment data.  The team also conducted pump system evaluations and developed an energy baseline for the plant, then prepared a detailed Optimization Study Report that documents the investigation, analysis, and findings of this study.  PHE developed a conceptual design for the preferred alternative that will save an estimated 172.42 million gallons per year in reclaimed wastewater that is currently lost to evaporation as a result of the current use of open ponds.   

Based on our outstanding performance on this study, the Delivery Order was modified to include the following services:

  • Permitting support to assist the Combat Center in negotiating changes to the WWTP NPDES permit with the Colorado Basin Regional Water Quality Control Board
  • Development of a comprehensive Operations and Maintenance Manual for the WWTP
  • Development of DD1391 Forms for a new WWTP as recommended in PHE’s Optimization Study

Wastewater Source Control Pretreatment Program (SCPP), MCB Camp Pendleton

PHE supports Marine Corps Base (MCB) Camp Pendleton’s Wastewater Source Control Pretreatment Program (SCPP) whose purpose is to systematically identify, characterize, and where possible, eliminate the sources of pollutants that can interfere with or degrade the operation of the Base’s wastewater treatment plants or collection system. 

The SCPP focuses both on domestic and industrial sources, and includes quarterly field surveys and inspections, routine surveillance and spot sampling, job-specific training, and a public outreach program.  The SCPP is a critical part of the settlement in response to a lawsuit brought by a number of environmental interest groups, and is essential to ensure compliance with the Base’s NPDES permits.  PHE has supported the SCPP on a continuous basis since 2001. 

Compliance Management Plans and Studies, Camp Lemonier, Djibouti

Camp Lemonnier is a 500-acre forward operating base located adjacent to the Djibouti-Ambouli International Airport.  The Camp serves as the headquarters of the U.S. Africa Command Combined Joint Task Force-Horn of Africa (USAFRICOM).  PHE developed a Hazardous Waste Management Plan (HWMP), an ODS Inventory and Management Action Plan, and a Solid Waste Management/ P2 Plan in accordance with requirements of the Overseas Environmental Baseline Guidance Document (OEBGD) and OPNAVINST 5090.1D.  PHE assessed onsite waste-generating operations and processes, characterized and documented types and amounts of wastes generated, and developed camp-wide management  procedures and process/equipment-specific SOPs.  PHE also conducted a P2 opportunity assessment to identify realistic, achievable P2 initiatives for the Camp.  A formal Closure Plan was developed for the Camp’s Hazardous Waste Storage Area as part of the HWMP.  PHE also developed an environmental general awareness guide to provide Camp personnel with basic compliance information and best management procedures.

As part of a follow-on delivery order, PHE conducted a Sanitary Survey and prepared a Water System Vulnerability Assessment (WSVA), Emergency Response Plan, and Drinking Water Management Action Plan (MAP) for the Camp.  PHE conducted an onsite assessment of the water sources, facilities, equipment, and operation and maintenance procedures of the Camp’s water treatment and distribution systems to evaluate the adequacy of these for producing and distributing safe drinking water.  As part of the Sanitary Survey, PHE identified known or suspected on-base and off-base sources of groundwater and/or soil contamination and used GPS to map distances between these contamination sources and the Camp’s production wells.  Such contamination sources included a large uncontrolled municipal waste dump, an illicitly used POL dumping site, and the Camp’s USTs that are of undetermined age and construction.  Also as part of the Sanitary Survey, PHE conducted a Cross Connection and Backflow Prevention Survey of the Camp.

Cross Connection and Backflow Prevention Study, Marine Air Ground Task Force Training Command (MAGTFC) Twentynine Palms, CA 

PHE conducted a base-wide Cross-Connection/Backflow Prevention (CCBFP) Survey of more than 1,200 buildings and structures to ensure compliance with California regulations, Marine Corps policy, and Uniform and California plumbing codes.  As part of this project, PHE developed a relational database to inventory backflow prevention devices and document survey findings, including cross-connections and backflow prevention devices that were damaged, missing, or not appropriate for their given use.  PHE prepared a comprehensive survey report with detailed cost estimates to correct deficiencies. 

Also under this delivery order, PHE prepared a CCBFP Management Plan to formalize management procedures at the Combat Center to ensure compliance with applicable regulatory requirements.  Under the same task order, PHE also prepared a Lead Sampling Plan to document sampling, notification, and recordkeeping procedures for sampling and schools and Child Development Centers.

Air Emissions Inventory and Ozone Depleting Substances Survey and Phase-Out Plan,
Naval Support Activity, Bahrain

During a two-week site visit conducted in January 2015, PHE surveyed all existing stationary air emissions sources at Naval Support Activity Bahrain.  Interviews were conducted with Base personnel to identify sources of air pollutant emissions and to collect data necessary to estimate potential and actual emissions.  Information was collected on the following types of air emissions sources present on the Camp:

  • Pesticide Application
  • Welding
  • Woodworking 
  • Boilers
  • Internal Combustion Engines
  • Fuel loading, Dispensing, and Storage
  • Aircraft Operations
  • Painting
  • Miscellaneous Chemical Usage

PHE performed calculations using emissions factors published by the United States Environmental Protection Agency (USEPA) in AP-42, Compilation of Air Pollutant Emission Factors.  Criteria pollutants, hazardous air pollutants, and greenhouse gases were all evaluated as part of the Air Emissions Inventory (AEI).  Air emissions calculations were performed using mass balance calculations, available emissions test results conducted on the emissions source unit or a similar unit, and/or by applying best engineering judgment.  In order to manage the data and perform the calculations, PHE entered the equipment and 2014 operations/usage data into a master inventory spreadsheet and emissions calculation spreadsheets using Microsoft Excel.

Also under this task order, PHE conducted a base-wide survey of refrigerant containing equipment and developed an ODS Phase‑Out Plan.  PHE identified more than 1,400 pieces of refrigerant‑containing equipment and conducted interviews to document related procedures such as purchasing, installation, service, and removal of refrigerant-containing equipment.  PHE developed management recommendations to improve the ODS management program and ensure compliance with ODS phase-out deadlines.

Sustainability Program Support, EMS Services, and Outreach, MCB Camp Lejeune, NC

PHE has supported MCB Camp Lejeune (MCIEAST – MCB CAMLEJ) and MCAS New River through four consecutive, annual delivery orders, providing sustainability program implementation, environmental management system (EMS) maintenance, and community outreach and awareness support.  

The PHE Team developed a joint Camp Lejeune/New River Strategic Sustainability Performance Plan (SSPP) to meet requirements of EOs 13514 and 13423, Federal regulations, and DoD policy and guidance.  The SSPP addressed all sustainable practice areas identified in DoD’s SSPP, including greenhouse gas reduction, energy and water conservation, stormwater best management practices (BMPs) and Low Impact Development (LID), material and waste management, sustainable (green) procurement, and high performance Leadership in Energy and Environmental Design (LEED) buildings.  The initial SSPP included an update to Camp Lejeune’s EMS Manual and a Green Procurement Program Opportunities Assessment.  PHE updated the SSPP and performance metric measurement tools in 2014, and prepared a related Executive Overview and Environmental Program outreach publications. 

Annual EMS support has included development of objectives and targets, practice/aspect inventory updates, facilitation to annual EMS Working Group meetings, and annual refresher training and provision of EMS Lead Auditor Training in 2014.  Also in 2014, PHE supported development of Camp Lejeune’s Environmental Awareness booklet, a professional publication designed to present the environmental program to a wide-ranging public audience.  Further outreach support has included close coordination with the Public Works Department Energy Program manager in developing and supporting Annual Earth Day and Energy Action Month activities, preparing environmental posters and publications, and base stormwater program support.

Municipal Separate Storm Sewer System (MS4) Program Plan,
USCG Training Center Yorktown, VA

PHE scientists and engineers have been providing stormwater management program support services to Federal, state, and municipal clients nationwide for over 20 years.  PHE recently (Jan 2015) developed a Municipal Separate Storm Sewer System Program Plan for the USCG Training Center (TRACEN) Yorktown, VA.  The plan was prepared in accordance with TRACEN’s recently updated Virginia Pollutant Discharge Elimination System (VPDES) General Permit, the Chesapeake Bay Preservation Act (Title 10.1 Conservation, Chapter 21 [10.1-2100 thru 10.1-2116] of the Code of Virginia), and Virginia Erosion and Sediment Control Regulations (Title 9, Agency 25, Chapter 840 of the Virginia Administrative Code (VAC) [9VAC25-840]). 

The update included calculations of pollutant loadings and required reductions to Chesapeake Bay total maximum daily loads, as well as revisions and updates to each of the six minimum control measures (MCMs), as appropriate.  PHE conducted a thorough review of the execution and adequacy of the best management practices (BMPs) and measureable goals that had already been established under each MCM.  Goals were updated, revised, and added as necessary to further promote the protection of water quality at TRACEN.  The updated plan also provided recommendations for non-structural BMPs that should be considered for implementation, such as innovative site planning, impervious area reduction, site grading, and protection of natural depression areas, and temporary ponding on site.

PHE staff also inspected TRACEN facilities, including the stormwater conveyance system, drains, and outfalls and assessed and documented activities, operations, and processes with the potential to affect stormwater quality.  PHE staff met with key onsite personnel, reviewed program documents and records to evaluate the effectiveness of the existing program and make recommendations for improving the existing program.  All identified stormwater management program deficiencies and any potential or existing illicit discharges were documented in a POA&M Report that provided a description of the deficiency, applicable regulatory or SWMP citation, with recommended corrective actions and estimated costs to correct.

Department of Veterans Affairs, Environmental Compliance Audits

PHE conducted third party multimedia environmental compliance audits at Department of Veterans Affairs Medical Centers (VAMCs) throughout the U.S. and Puerto Rico, for Veterans Integrated Service Networks (VISNs) 5, 8, 11, 19, 20, 21, and 22.  The audits were conducted in conjunction with the VAMCs' Green Environmental Management System (GEMS) Program and addressed environmental compliance issues relating to a wide range of environmental aspects and regulatory areas, including, but not limited to: air emissions, waste management, wastewater discharges, fuel storage, historic preservation, EMS and other programmatic components, pesticide use, and asbestos and lead-based paint management. The Environmental Assessment and Management (TEAM) Guide, along with state-specific TEAM Guide supplements, were used as protocols to perform the audit.  

Audit teams visited the medical centers to conduct thorough inspections, presented findings during audit out-briefs, and developed comprehensive audit findings reports that documented areas of non-compliance, with applicable regulatory citations, and recommended corrective actions.  All findings were also recorded in the CP-Track software developed by the U.S. Army Corps of Engineers Construction Engineering Research Laboratory, for use by the Veterans Health Administration.