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