Audit & Compliance Inspections

Fort Novosel units and organizations will experience inspections annually by Post Safety, the Fire Department, and the Post Environmental Office (DPW-ENRD). The information below pertains only to inspections involving or performed by DPW-ENRD.

General Background

Compliance inspections and audits are tools used to assess how well we are meeting all of our environmental requirements. We have both internal and external methods which assess our compliance. Although these inspections may reveal violations, they are tools for improving and for facilitating corrective action. In the case of internal inspections or audits, any vulnerabilities or inspections can be caught and fixed before state or federal regulators find these vulnerable areas and bring enforcement action or monetary penalties against an installation.

State and federal regulators (external inspectors) are the organizations that administer enforcement action or monetary penalties for violations. They often give little or no advance notice of inspections or sites they wish to visit. Accordingly, the installation ultimately must be ready at all times. Internal assessment methods are designed to strengthen our environmental compliance posture and ensure we are in compliance with all applicable laws and regulations when state and federal inspectors arrive unannounced.

A Notice of Violation (NOV) is a commonly issued enforcement action. It may be issued to a facility or installation with or without a fine, and catches the attention of everyone in the chain of command including the installation's commanding officer, and the regional or mission oversight activity such as the installation's major command. Individual units, organizations, supervisors, or individuals are usually not liable for violations unless there is evidence that negligence or blatant disregard for the law occurred. However, violations that could or should have been addressed by supervisors or individuals can often mar one's performance appraisal or future job promotions.

Training is required by multiple regulations, and training records are usually the first areas of compliance checked during inspections. Training records need to be current, and show that appropriate personnel have been trained. This area must have real command or supervisory emphasis and focus.  Additionally, regulators and inspectors almost always go back and check previous violators/violations to determine progress and/or compliance. A system must be established for tracking and accounting for corrective actions of previous violations.

Fort Novosel's internal and external methods of assessing environmental performance are described below in more detail.

Internal Methods

Periodic Compliance Inspections

DPW-ENRD inspects all industrial facilities on Fort Novosel on a regular basis. These are "no notice" inspections, which means that advance notice about the inspection is not given so that the inspector may view the unit or organization in its normal operating state. While this may sometimes seem harsh, it better prepares the organization for a state or federal regulatory inspection which also occurs without advance notice. DPW-ENRD utilizes USAACE Form 2717, Environmental Compliance Inspection Checklist, to conduct these inspections..

DPW-ENRD personnel are not employees of the state regulatory agency (Alabama Department of Environmental Management) or the federal agency (Environmental Protection Agency). DPW-ENRD at Fort Novosel is comprised of Department of Army government employees who are in place to assist post organizations, and to serve as the garrison's environmental support office. They are not an enforcement activity, but perform inspections to help elevate issues which may need to be addressed.

Past inspection reports should be on file with the unit or organization, but if they cannot be found, contact DPW-ENRD for an extra copy. Questions about these inspections can be directed to 255-1657.

Environmental Performance Assessment System (EPAS) / Installation Corrective Action Plan (ICAP)

Once a year, the entire staff of DPW-ENRD will complete a comprehensive assessment of many environmental programs and sites. These include maintenance and industrial activities, and other behind-the-scenes programs and requirements. Any weaknesses, vulnerabilities, or violations of federal, state, DoD, or Army regulations are documented, and corrective action for these findings must occur. Findings and corrective actions are discussed with the specific unit or organization before the installation chain of command is briefed.

This annual internal assessment is directed for Army installations so that the posts can review their overall compliance situation in between the years that the external Environmental Performance and Assessment System (EPAS) inspections occur . EPAS is a comprehensive inspection which occurs about every 3 years, lasts about a week, and is performed by a team of Army personnel who do not work on the installation. EPAS is sometimes considered an "external" inspection because it is conducted by personnel who do not work at the installation. However, it can also be considered an internal inspection because its purpose is for this Army team to identify potential violations and allow us to correct them before the regulatory agencies catch them and initiate enforcement action or fines. 

External Methods

External inspections or audits are generally conducted annually by state or federal regulatory agencies. The federal agency is the Environmental Protection Agency, and the state agency is the Alabama Department of Environmental Management (ADEM). These agencies are allowed by law to visit us without prior notice, and they almost always operate in this manner.

Although they arrive unannounced for inspections, they generally report first to DPW-ENRD to check in, and to discuss what they wish to see. DPW-ENRD then escorts them for the remainder of their visit, and will check in with the necessary supervisors at each work location upon arrival at the site. When the inspector arrives at your location, the organization should immediately locate their Environmental Officer or other knowledgeable employee to also accompany or escort the agency inspector while on-site at the work location. It is also the responsibility of those at the work site to notify their work leader, supervisor, or chain-of-command.

If a finding is noted at a site, the inspector will generally let you know onsite. The inspector has the power to make it an official finding, or may choose to use it as a warning or teaching example. Although it is not guaranteed, there are times that a finding is not counted if it is corrected on the spot while the inspector is there. If the inspector desires, he or she may hold an exit briefing to discuss the findings with DPW-ENRD and the representatives from the inspected organizations. A written report may be left behind or it may be mailed to the installation a short time later.

DPW-ENRD can provide information regarding past inspections, findings, or lessons learned upon request.


Please see the Environmental Documents page for program-specific environmental documents and work instructions.