United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
EPA -300 -R-00-006
August 2000
&EPA
An Environmental
Management System
Review of the National
Park Service:
Based on the Code of Environmental
Management Principles
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CEMP Evaluation of the National Park Service
EXECUTIVE SUMMARY
In early 1998, the U. S. Environmental Protection Agency (EPA) and the Department of the Interior (DOI)
agreed to work jointly to enhance regulatory compliance assistance across DOI Bureaus and facilities with the
overall goal of raising the level of regulatory awareness and compliance with environmental regulation at all DOI
facilities. While EPA's federal facilities program had previously conducted limited compliance assistance
initiatives with specific environmental programs in other federal agencies, this was the first time that EPA
committed to provide compliance assistance across an entire federal agency. One of the most innovative and far-
reaching efforts that resulted from the EPA/DOI compliance initiative was an analysis of environmental
management systems (EMS) within the National Park Service (NPS). This analysis was conducted by comparing
existing management systems within the NPS against the Code of Environmental Management Principles (CEMP)
for federal agencies.
The CEMP was developed by EPA in coordination with other federal agencies in response to requirements
of Executive Order 12856, "Federal Compliance with Right-to-Know Laws and Pollution Prevention
Requirements." The Executive Order required the federal community to agree to a set of principles that reflect
state of the art environmental management programs. The CEMP is a collection of five broad management
principles and underlying performance objectives that provide a basis for federal agencies to achieve and maintain
effective and responsible environmental management.1 The five principles are:
Management commitment;
Compliance assurance and pollution prevention;
Enabling systems;
Performance and accountability; and
Measurement and improvement.
The analysis of the NPS environmental management system was a broad-based review that examined current and
planned environmental management practices against an accepted systematic framework of principles. While the
body of this document provides substantial information regarding the findings and recommendations of this review,
highlights of those findings and recommendations are presented below.
The analysis and recommendations contained in this document are meant to support and enhance the
current NPS environmental management system. EPA and NPS worked jointly to conduct this review in the hope
that it will provide a basis for continued discussion within NPS regarding the future direction of the NPS
environmental program. This effort has also stimulated dialogue between NPS and EPA field personnel and has
lead to a better understanding of the respective roles of each entity in achieving and maintaining environmental
leadership. Finally, results of CEMP analysis conducted for NPS will assist other federal agencies in recognizing
the benefit of such an assessment across the federal community. EPA would like to express its appreciation to the
NPS for participating in this review.
HIGHLIGHTS
Management Commitment
The NPS CEMP review found that bureau-wide, the NPS mission actively supports environmental
stewardship and sustainability as a founding philosophy of the NPS. The review did reveal, however, that there is
not currently a stand-alone statement that explicitly defined an NPS environmental policy. In addition, existing
environmental guidelines do not emphasize compliance with environmental regulatory requirements. Development
and wide distribution of a distinct environmental policy statement, along with the clear, high-level management
commitment that would necessarily accompany such a statement would emphasize the NPS policy to employees and
information regarding the CEMP can be found in, "Implementation Guide for the Code of
Environmental Management Principles for federal Agencies (CEMP), EPA document number 315-B-97-001.
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CEMP Evaluation of the National Park Service
park users and explicitly demonstrate the goal of the NFS to be a leader in environmental stewardship and
regulatory compliance. Moreover, an explicit and comprehensive policy would clearly signal internal NFS support
for funding and personnel resources necessary to ensure a robust environmental program. Finally, such a policy
would encourage NFS support and outreach components, such as concessioners and interpretive elements, to
incorporate environmental stewardship and compliance into facility-level activities.
Compliance Assistance and Pollution Prevention
Current NFS support programs responsible for ensuring compliance with environmental regulations and
promoting pollution prevention are housed under separate entities within the NFS organization. In addition, while
many parks have programs for support of pollution prevention and recycling efforts, these programs do not fully
exploit reduced compliance liabilities resulting from their efforts. Development and support of comprehensive
regulatory compliance activities would significantly contribute to ensuring both compliance with applicable
environmental regulations and pursuit of pollution prevention opportunities throughout the NFS system. This effort
would integrate all current regulatory components at NFS and it would support and reflect ongoing efforts to
implement environmental auditing procedures at NFS facilities. A comprehensive compliance assurance and
pollution prevention program would also serve as a bureau-wide source for communicating both changing
environmental compliance requirements and innovations in pollution prevention applicable to facility-level
operations.
Enabling Systems
The various support and enabling systems that affect environmental management aspects of the NFS reflect
a separate, media-based approach toward awareness and compliance. Additionally, the principal environmental
review mechanism is the NEPA review process which may not adequately address day-to-day operations of NFS
facilities. Identification of facility level operational training needs and implementation of broad-based training
programs for facility personnel would ensure adequate knowledge and understanding of NFS environmental
priorities as well as external environmental requirements. Further, facility personnel who are not directly
responsible for facility environmental compliance but who may contribute to success of the facility's environmental
program, should have a recognized role in contributing to overall NFS facility-level policies and goals for
environmental excellence.
Performance and Accountability
Responsibility and authority for compliance with environmental requirements at NFS facilities is generally
limited to collateral duties of facility management personnel who are also responsible for a broad range of other
facility operations. This approach limits the ability of those personnel to concentrate on environmental management
and compliance at the facility and restricts the degree of authority and accountability relative to facility
environmental performance. This situation could be significantly enhanced by the establishment of an NFS policy
that secures adequate authority for ensuring facility environmental compliance and gives that authority to the
responsible party at each NFS facility. In addition, development of performance standards and performance
evaluations for those facility personnel responsible for compliance and other environmental priorities should fully
recognize those responsibilities. Additionally, goals for environmental performance that reflect overarching NFS
environmental policies should be developed and included into regional and park operational standards. Finally,
while individual "champions" are important to the success of any environmental program, policies and practices
should be in place to ensure that environmental leadership is standard procedure and lack of a champion does not
preclude sound environmental performance.
Measurement and Improvement
Results of the NFS CEMP review indicate that current systems for evaluation and measurement of
environmental performance at NFS facilities are limited to certain regional efforts and developing audit systems.
Evaluation of program performance is critical to the ultimate success of any environmental program. Support and
further development of planned auditing systems with appropriate mechanisms to collect and analyze audit results
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CEMP Evaluation of the National Park Service
across the bureau will contribute significantly to the success of the NFS environmental program. Evaluation of
audit results including root cause analysis of environmental problems and non-compliance would enable NFS to
develop tools to support regulatory compliance and transfer cost-effective innovations and solutions throughout the
NFS system. Additionally, effective measurement will provide necessary information for budgetary and personnel
decision making to respond to problem areas as well as enhance efforts that meet the policies and goals established
for the NFS environmental management program.
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CEMP Evaluation of the National Park Service
CONTENTS
Executive Summary i
Contents iv
List of Acronyms v
Introduction vi
OEPC Relationship with NFS and Other DOI Bureaus viii
Principal 1: Management Commitment 1-1
Performance Objective 1.1— Obtain Management Support 1-1
Performance Objective 1.2 - Environmental Stewardship and Sustainable Development 1-4
Principle 2: Compliance Assurance and Pollution Prevention 2-1
Performance Objective 2.1 — Compliance Assurance 2-1
Performance Objective 2.2 - Emergency Preparedness 2-3
Principle 3: Enabling Systems 3-1
Performance Objective 3.1 — Training 3-1
Performance Objective 3.2 - Structural Supports 3-2
Performance Objective 3.3 - Information Management, Communication & Documentation 3-4
Principle 4: Performance and Accountability 4-1
Performance Objective 4.1 - Responsibility, Authority, and Accountability 4-1
Performance Objective 4.2 - Performance Standards 4-2
Principle 5: Measurement and Improvement 5-1
Performance Objective 5.1 - Evaluate Performance 5-1
Performance Objective 5.2 — Continuous Improvement 5-4
Matrix of CEMP Findings and Recommendations A -1
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CEMP Evaluation of the National Park Service
LIST OF ACRONYMS
Acronym
BLM
CAP
CEMP
CERCLA
CERL
CFA
DOD
DOE
DOI
EIMS
EMR
EMS
EPA
FRP
GMP
GPRA
HWMPP
1C
IMR
ISWAP
KSA
MOU
MWR
NEPA
NER
NPS
NRDA
NREL
NRI
OEPC
OSHA
P2
P2OA
PHS
PMIS
PWR
QA
RCRA
SER
SPCC
WASO
Definition
Bureau of Land Management
Compliance Assistance Project
Code of Environmental Management Principles
Comprehensive Environmental Response, Compensation, and Liability Act
Construction Engineering Research Laboratory
Civilian Federal Agency
Department of Defense
Department of Energy
Department of the Interior
Environmental Information Management System
Environmental Management Review
Environmental Management System
Environmental Protection Agency
Facility Response Plan
General Management Plans
Government Performance Results Act
Hazardous Waste Management and Pollution Prevention
Incident Command
Inter-Mountain Region
Integrated Solid Waste Alternatives Program
Knowledge, Skills and Abilities
Memorandum of Understanding
Midwest Region
National Environmental Policy Act
Northeast Region
National Park Service
Natural Resource Damage Assessment
National Renewable Energy Laboratory
Natural Resource Initiative
Office of Environmental Policy and Compliance
Occupational Safety and Health Administration
Pollution Prevention
Pollution Prevention Opportunity Assessment
Public Health Service
Project Management Information System
Pacific West Region
Quality Assurance
Resource Conservation and Recovery Act
Southeast Region
Spill Prevention, Control, and Countermeasures
Washington Area Support Office
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CEMP Evaluation of the National Park Service
INTRODUCTION
Background
During discussions held in January of 1998, U. S. Environmental Protection Agency (EPA) and the
Department of the Interior (DOI) agreed to work jointly to enhance compliance assistance across DOI Bureaus and
facilities with the overall goal of raising the level of regulatory awareness and compliance at all DOI facilities.
While EPA's federal facilities program had previously conducted limited compliance assistance initiatives with
specific environmental programs in other federal agencies, this was the first time that EPA pledged to provide
compliance assistance across an entire federal agency. One of the most innovative and far-reaching efforts that
resulted from the EPA/DOI compliance initiative was an analysis of environmental management systems (EMS)
within the National Park Service (NFS), including an analysis of support relationships between NPS field-level
facilities and NPS and DOI Headquarters environmental offices. This analysis was conducted the Code of
Environmental Management Principles (CEMP).
CEMP
In coordination with other federal agencies, EPA developed the Code of Environmental Management
Principles for federal agencies (CEMP) in response to requirements of Executive Order 12856. The CEMP is a
collection of five broad management principles and underlying performance objectives that provide a basis for
federal agencies to achieve and maintain effective and responsible environmental management. The five principles
are:
• • Management commitment;
Compliance assurance and pollution prevention;
Enabling systems;
Performance and accountability; and
Measurement and improvement.
The five principles and accompanying objectives provide federal agencies with guidance to ensure environmental
performance that is cost-effective, integrated, and sustainable.
Scope of the Assessment
The scope of the CEMP assessment was defined by: (1) assessed organization; (2) assessment period; and
(3) assessment criteria. Additional information on each is presented below.
Assessed Organization: The assessed organization was the NPS. Formal and informal aspects of
the NPS environmental management system (EMS) were reviewed at the field, regional and
headquarters levels. The review also addressed portions of the "parent" DOI organization which
directly influence NPS environmental management activities. In this regard, the DOI Office of
Environmental Policy and Compliance (OEPC) and additional DOI-level units were included in
the review.
Assessment Period: The assessment period for the CEMP review began in July 1998 and was
completed in December 1998. During the assessment period, several changes to the NPS EMS
were either underway or planned; the review documented those changes to the EMS as well.
Consequently, the final document presents information collected during the assessment period
about the existing EMS, as well as information on changes underway or planned.
• • Assessment Criteria: The assessment criteria for the NPS CEMP review were the performance
objectives supporting each of the CEMP principles. Details on the performance objectives were
extracted from the CEMP Implementation Guide prepared by EPA in 1997. Specifically, both the
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text of the CEMP Implementation Guide and the Guide's Self-Assessment Matrix were used as a
reference for the assessment study and results.
Assessment Approach
The first stage of the assessment focused on gathering DOI and NFS organizational baseline information
with an emphasis on how the two organizations administered environmental management responsibility internally.
The assessment also included a review of administrative relationships between EPA, NFS and DOI. Collection of
this information provided a common understanding of existing management systems. For example, the EPA,
DOI/OEPC, and the NFS each have a regional management structure but the geographical territory associated with
each region is different. A summary of collected baseline information is included in the final assessment
document.
The approach of phase two of the assessment focused on field and regional level aspects of environmental
management at NFS. EPA, DOI/OEPC, and NPS were informed of assessment progress through monthly reports,
meetings, and through informal discussions.
The assessment team collected information through interviews, record reviews, and by direct observations.
Further information on each aspect is presented below:
Interviews: Over 75 interviews were conducted. Initial interviews, addressing all five principles,
were broad in scope and lengthy (up to 2 hours). Towards the end of the assessment period,
shorter interviews were used to fill information gaps or test initial conclusions on
recommendations related to the principles. Nearly all interviews were structured to ensure
specific objectives were met; however, there was no standard set of questions asked of all
interviewees. Each interview was designed for specific information sought. In conducting
interviews, the assessment team shared information about the CEMP as background and assured
interviewees that their specific comments would remain confidential.
Record Reviews: Over 85 individual EMS-related records were reviewed. These documents
included guides, manuals, policy statements, and training documents.
Direct Observations: A direct observation was defined as first hand information collected by the
assessment team which was not derived from an interview or record review. Examples are:
Internal meetings where the assessment team observed information being shared; and
Observations on the availability of selected EMS related records. For example, in
requesting information about records, observations were made on whether the records
were available, understood, and/or used.
Only corroborated information is reported as findings in the document. For example, information based
upon a single interview was not, for the purposes of the assessment, considered sufficiently reliable. To be reported
as a finding, single interview information had to be supported by documentation or direct observation.
Findings
A set of recommendations was developed for each of the CEMP performance objectives as suggested areas
for future improvement. The findings were designed to encourage further NPS review of the applicability of the
CEMP in supporting the overall success of the NPS environmental management, system. While the main body of
the assessment focuses on NPS , an additional section presents EMS related findings on the relationship between
DOI and NPS.
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CEMP Evaluation of the National Park Service
OEPC RELATIONSHIP WITH NFS AND OTHER DOI BUREAUS
The Office of Environmental Policy and Compliance (OEPC), within the Office of Policy, Management
and Budget, provides national and regional leadership, bureau coordination, and program evaluation in
environmental management for DOI. The operations of this office were evaluated as part of the CEMP study of the
NPS. It should be noted, this evaluation focused on OEPC relationships with the NPS. It was not a comprehensive
review of OEPC environmental management systems or the office's relationship with other bureaus.
Existing Environmental Management Activities
Management Commitment
OEPC's role is to provide assistance and coordination on environmental policy and program
implementation for inter-bureau, inter-agency, and other external activities. OEPC does not have responsibility for
management or direct oversight of bureau environmental programs. OEPC develops departmental environmental
policies and guidance. These policies are subject to approval by bureaus and offices. Environmental policies that
have been promulgated include: Departmental Manual Part 515, Chapters 2 and 3, which address environmental
auditing and recycling programs; Part 516, which addresses NEPA compliance; Part 518, Chapters 1 and 2, which
address waste management; Part 602, which addresses pre-acquisition site assessment.
With the exception of the central hazmat fund, OEPC has no responsibility for management or review of
NPS or other bureau environmental budgets.
Compliance Assurance and Pollution Prevention
A baseline of DOI environmental compliance has not been completed. Regulatory notices and guidance
are developed on an as-needed basis by OEPC and are disseminated to NPS and other bureaus in two ways: 1) to
Regional Environmental Officers for distribution to NPS and other bureau and office regional contacts; and 2) to
bureau and office headquarters for distribution to regions and field units. There is no mechanism to track or assure
distribution of this information to the field level once it leaves OEPC.
Criteria for NEPA documentation review at the departmental level have been developed. Internal and
external NEPA documentation describing significant impacts are subject to OEPC review. A majority of bureau
environmental impact statements are tracked by OEPC.
A departmental system is in place to address emergency response and is coordinated with the NPS and
other bureaus and offices.
Enabling Systems
OEPC does not have resources or agency-wide initiatives for training. Environmental training
responsibility is predominantly delegated to the bureaus and offices; occasional inter-bureau training may be
provided at the headquarters or regional level.
OEPC has a web site and electronic bulletin board. The web site currently provides limited environmental
compliance data. The site contains linkages to the Construction Engineering Research Laboratory (CERL) TEAM
Guide, Green Seal environmentally preferable product reports, damage assessment training modules, tools and
regulations. With the assistance of one of the Bureaus, OEPC conducts periodic nationwide environmental
conferences to assist Bureaus in addressing a wide variety of environmental issues. There is no linkage to relevant
environmental compliance policies. OEPC is currently benchmarking it's site against those of other civilian federal
agencies.
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CEMP Evaluation of the National Park Service
Performance and Accountability
OEPC has no line authority for environmental compliance of the NFS or other bureaus. Office
performance measures relate to success in coordinating and facilitating bureau programs and inter-agency
partnerships. OEPC staff performance goals are not based on individual bureau performance.
Measurement and Improvement
DOI has developed policy mandating environmental audits of all facilities by September 2002. Transmittal
of bureau audit results to OEPC is not required by the policy; however, OEPC has developed an audit summary
report. The report format was revised based on comments from the bureaus.
Calls for other environmental data are made by OEPC to complete mandated summary reports (e.g., USTs,
CERCLA sites). The completeness and/or timeliness of this data is at the discretion of the bureaus and offices.
Recommended Next Steps
A number of opportunities were identified where OEPC has the opportunity to enhance the environmental
performance of individual bureaus and DOI as a whole. These improvements can be made within the existing
OEPC mission framework of providing national leadership, bureau coordination, and program evaluation. In
particular, enhancements can be taken in five specific areas:
Policy;
Guidance;
Strategic tool development and deployment;
Information management; and
Quality assurance.
Policy
OEPC should develop minimum standards for all environmental program areas. These minimums should
be clearly identified, and have specific emphasis on departmental applicability. They should not simply restate
laws, regulations, and Executive Orders.
Policy developed by OEPC is subject to review and approval by each of the bureaus. This consensus
building process often leads to a "watering down" of policy requirements. OEPC should issue interpretive guidance
(which is not subject to the same level of bureau approval) to augment and re-strengthen the policy. OEPC should
also develop strong strategic plans with bureau-level goals and measurement requirements which are tied to
compliance requirements (e.g., EO 12856 pollution prevention goals).
Guidance
Guidance to bureaus is generally useful for any environmental management topic, but is especially
important where:
Consistency is essential (e.g., roll-up reporting of environmental audit findings);
There are common bureau needs (e.g., affirmative procurement procedures and reporting);
Bureaus do not have sufficient resources or determination; and
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CEMP Evaluation of the National Park Service
Timeliness is important.
OEPC should look use these criteria to identify opportunities to develop environmental program guidance that will
be most beneficial to the bureaus.
Strategic Tools
Efficiency and economy of scale can be realized by department-level tools benefitting most bureaus.
Examples may include model plans, budget models, training curriculum and tools, fact sheets (e.g., new issues,
lessons learned), and resource guides.
Information Systems
OEPC should work to become a value-added environmental point of contact for internal and external (e.g.,
EPA) communications and a preferred resource and information center within the department. The provision of the
CERL Team Guide and Green Seal environmentally preferable products reports on the DOI web site are good
examples of environmental information OEPC can provide to assist bureaus in maintaining environmental
compliance. Other useful information may include regulations, relevant departmental manual chapters, interpretive
guidance and strategic tools.
Quality Assurance
OEPC should conduct routine and as-needed program evaluations and audits. These may be CEMP- or
NEPA-related, or address other key factors. These evaluations can serve to assess the quality of bureau programs
and be used by OEPC for targeting root causes such as resources and commitment. This information can be used in
the strategic planning of OEPC programs and/or provide guidance and direction to the Secretary (e.g., budget
requirements).
Implementation
OEPC can take several steps to help enhance the departmental environmental management program:
Seek opportunities to develop an integrated staff with bureaus through details or special
assignments;
Host key leadership-focused intra-departmental initiatives (e.g., the active role OEPC has taken in
the development of the federal strategic plan for EO 13101);
Create Centers of Excellence at selected bureaus to recognize and encourage superior
performance (e.g., BLM for military munitions);
Promote OEPC capabilities and successes internally and externally; and
demonstrate the economic, efficiency and quality benefits from OEPC involvement.
Organization of the Document
The remainder of this document summarizes the results of the CEMP assessment of the NPS EMS. It is
organized according to the five CEMP principles.
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CEMP Evaluation of the National Park Service
PRINCIPAL 1: MANAGEMENT COMMITMENT
Performance Objective 1.1 — Obtain Management Support
Sub-Objective 1.1.1: Policy Development — The agency establishes an environmental policy followed by an
environmental program that complements its overall mission strategy.
There is no stand-alone environmental policy for the NFS. The document, NFS Management Policies,
which is only revised on a ten-year cycle, serves as a Service-wide or Level 1 policy document. However, the need
for environmental compliance is only implied in the foreward of the document. In addition, a number of
subsections mandate compliance with specific federal laws and regulations, such as:
• • Chapter 2 - Park System Planning addresses National Environmental Policy Act (NEPA).
Chapter 4 - Natural Resource Management mandates compliance with the Clean Water Act and
Clean Air Act and associated federal, state and local regulations.
Chapter 9, Park Facilities addresses compliance with all applicable laws and regulations
associated with solid and hazardous waste, hazardous materials management and site restoration.
Special Directives and Staff Directives are considered Level 2 internal working policy. They are prepared
and updated as necessary and provide more detail than the NFS Management Policies. The Special and Staff
Directives are being replaced by Directors Orders as part of an overall revision to the NFS Directives System.
Level 2 policy has been issued to address waste management, underground storage tank management, integrated
solid waste management, pesticide use and other environmental programs.
Level 3 NFS Guidelines provide guidance on the implementation of Level 1 and Level 2 policy. Some
policy is included in theses guidance documents. NFS guidance with environmental compliance aspects include:
NFS 12 ~ NEPA Compliance Guideline, NFS 50 - Loss Control Management (hazardous materials management,
respiratory protection and hazard communication programs, and others), NFS 77 - Natural Resources, and NFS 83
- Public Health (water and wastewater treatment system management).
Under Development and Planned
The entire NFS policy system is being revised. This provides an opportunity to address environmental
aspects more directly. There has been a broad call for input from NFS stakeholders on ways of strengthening policy
language relative to environmental programs.
Several NFS program offices are in the process of updating or developing new Level 2 policy with stronger
environmental language. Both the Concessions and Public Health policies are being revised. The Hazmat policy is
also under review and an Oil and Hazardous Materials Spill Response policy has been drafted.
Other efforts may result in environmental policy. For example, the Environmental Leadership program
currently under development includes environmental principles, which, if approved, could become policy. In
addition, a proposed Natural Resources Initiative (NRI) includes Principal 9 that states "The NFS will comply with
all environmental laws and apply the highest standards of environmental stewardship to its operations." The
Environmental Leadership program and other initiatives with environmental aspects have growing key stakeholder
involvement. An Environmental Leadership senior stakeholder meeting was held on January 6 and 7, 1999 and
included discussions on NFS environmental policy goals.
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CEMP Evaluation of the National Park Service
The NFS plans to share the messages from initiatives such as the Environmental Leadership program and
NRI internally by integrating it in management training and other "normal" channels, as well as externally to
concessioners and other stakeholders through training, conferences, and public information mechanisms.
Recommended Next Steps
The following are recommended next steps to more fully address Sub-Objective 1.1.1.
Develop a comprehensive environmental policy. To be most effective, this policy should
stand-alone and cross program lines. This policy should fully address traditional compliance
aspects, but also consider pollution prevention and "beyond compliance" aspects, such as
sustainability, which are key to the mission of the NFS. This policy should include and address
independent efforts currently underway. It should be developed with wide internal and external
participation at all levels to build consensus and assure completeness. The policy should establish
goals for key environmental indicators so that performance can be tied to policy requirements.
Educate all employees and park users on the content of and management commitment to a
robust environmental policy. NFS should include environmental policy review in staff and
stakeholder education (e.g., staff Compass training, concessioner training). In addition, NFS can
spread the policy message through periodic management-supported promotions such as
conferences, brochures, contract language, training, and web page posted documents.
Include specific reference to concessioners in environmental leadership policy. The NFS is
currently developing an "umbrella" policy on environmental leadership. The policy will reinforce
the NFS commitment to baseline environmental compliance, pollution prevention, sustainability,
and education. The Directors Order on environmental leadership should include a specific
reference to concessioner compliance with the policy.
Sub-Objective 1.1.2: System Integration — The agency integrates the environmental management system throughout
its operations, including its funding and staffing requirements, and reaches out to other organizations.
Several NFS budget processes have been established to account for environmental aspects. The Annual
Hazardous Waste Management and Pollution Prevention (HWMPP) team project funding review involves project
selection based on four categories:
Waste reduction and management;
Fuel storage;
Contaminated sites; and
Technical support.
Each category has ranking criteria. NPS planned to integrate the existing system into a Project Management
Information System (PMIS) in FY 1999. The annual natural resources program funding allocation process also
employs environmental management criteria.
Environmental due diligence reviews occur for property acquisition. The bureau also formed a
Contaminants Technical Advisory Group that meets quarterly.
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CEMP Evaluation of the National Park Service
Under Development and Planned
Through the EPA/DOI Compliance Assistance Partnership, NPS offered itself as a pilot subject for a
CEMP study to obtain a Service-wide baseline environmental management system assessment and recommendations
on ways to improve these systems. Participation in this study may also improve NPS's working relationship with
EPA.
The Environmental Leadership program is being developed within the NPS to enhance the bureau's
environmental management systems. The program has broad NPS participation. It is intended to link independent
initiatives and move the NPS toward Service-wide environmental goals of environmental compliance, pollution
prevention and sustainability, and internal and external environmental education. Environmental staff and budget
requirements are being addressed as part of Environmental Leadership program development.
Regional environmental support capability is being expanded through the NPS internal audit program.
Regional environmental coordinators have been assigned for the program, park-level points of contacts are to be
established prior to site visits. Responsibility for environmental management and corrective actions identified
during the audits will be specified. The incorporation of environmental audit program data into the budget/funding
allocation process is also planned.
Recommended Next Steps
To integrate environmental management more effectively throughout the organization and meet
Sub-Objective 1.1.2, the following next steps are recommended:
Develop and provide environmental "awareness" training to all levels of management to
foster environmental compliance and sustainability concepts throughout the organization.
Broaden the scope of environmental categories and criteria (e.g., waste and water) in the
budget process so that all project funding requests are addressed in one integrated evaluation of
environmental aspects and priority.
Integrate environmental aspects in the resource allocation and planning process at the park,
region and headquarters level by requiring that environmental performance be specifically
addressed in strategic and general management plans.
Develop policy that recognizes and endorses support for the Service-wide need for funding
and personnel allocated specifically to environmental compliance.
Develop a Concessions Division environmental policy that mandates concessioners comply
with "Concessions Environmental Guidelines" (see Principle 3.2).
Modify concessions contracts and facility operating plans to include performance criteria
related to the Concessions Environmental Program (e.g. requirements for environmental
audits).
Incorporate environmental program needs into Concessions Program budget process. The
NPS Concessions Program should integrate environmental program development/implementation
needs into the budget allocation process for the Division. Elements of this budget process could
include:
Direction of funds from new sources, such as the 20/80% budget process, and
Use of partnership/cost sharing to provide integrated NPS staff/concessioner
environmental services (e.g. environmental auditing and training).
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CEMP Evaluation of the National Park Service
Performance Objective 1.2 — Environmental Stewardship and Sustainable Development
The agency strives to facilitate a culture of environmental stewardship and sustainable development.
Existing
Environmental stewardship and sustainability are founding philosophies of the NFS. The NFS
Management Policies, Level 2 policies, and Level 3 guidelines such as NFS 11— Natural Resources, address
resource stewardship and sustainable design.
The Guiding Principals of Sustainable Design were published by NFS and are considered by some to be
the quintessential work on sustainable design. These guidelines and other sustainable design tools are on the NFS
"Renew" web site. NFS line item budget projects are designed following a sequence recommended in the Draft
NFS 70 ~ Design Process Guideline: The Built Environment. This guideline uses a "design for the environment"
approach that incorporates ecosystem planning, life cycle cost, value analysis, and choosing by advantage methods.
Alternative energy programs are promoted through on-going partnerships with the Department of Energy (DOE).
The NFS has an Environmental Quality Division within the Natural Resource Stewardship and Science
Directorate that is responsible for managing internal and external NEPA reviews, the NFS integrated pest
management program, and internal and external natural resource damage assessment and environmental response.
The NFS also reportedly established a site restoration cost recovery program that includes a potentially responsible
party search manual and a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
manual.
Draft Environmental Leadership training has been developed. The training is geared toward program and
project managers and addresses environmental management, sustainability, and pollution prevention. The
Environmental Leadership senior stakeholder summit conducted in January 1999 also had a strong emphasis on
sustainability.
Regional and park-level efforts have also occurred. Green procurement training has been conducted
(Northeast and National Capital Area). Sustainable Re-Development Addenda have been prepared for selected
general management plans (GMPs) (e.g., Grand Canyon National Park).
Under Development and Planned
A Service-wide NRI is being developed and is supported by the Director. The NRI establishes natural
resource stewardship goals and programs that include resource planning, environmental stewardship, and education.
The ongoing Environmental Leadership program has a strong emphasis on sustainable practices. The
Denver Service Center is planning training telecast via satellite in partnership with academia. The NFS also
participated in the DOI environmental conference in April 1999, which had a focus on sustainability and green
procurement as well as other environmental topics.
The NFS is continuing its partnerships with DOE to conduct energy audits design and install alternative
energy systems. A Memorandum of Understanding (MOU) between the DOE Federal Energy Management
Program and NFS for participation in DOE regional contracts was signed in January 1998. A National Renewable
Energy Laboratory (NREL) MOU focuses on sustainable design for energy systems. Sustainable transportation
system demonstration projects are being conducted or are planned under a Department of Transportation/DOI MOU
signed in November 1997.
Regional sustainability programs are also being launched in the Midwest Region (MWR), Northeast
Region (NER), and Pacific West Region (PWR). Green team surveys and opportunity assessments are being
conducted in the NER and Sustainability Program Opportunity Projects are being conducted in the PWR.
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Recommended Next Steps
To more fully and efficiently address Sub-Objective 1.1.2 and to account for existing and planned
environmental management responsibilities (e.g., compliance) in Service-wide and regional sustainability initiatives,
NFS should implement the following:
Ensure communication and coordination between sustainability coordinators and
compliance coordinators (e.g., HAZMAT, Solid Waste, Fuel Storage Tank Coordinators). In
this way, compliance realities can be better understood and considered in sustainability project
planning and implementation.
Merge/coordinate various environmental initiatives and projects to minimize redundancy
and provide an integrated approach. This approach can provide a focus on sustainable
solutions, but within the context of a "compliance first" strategy. For example, sustainability
assessments could be coordinated with the environmental audit program. Sustainable pollution
prevention solutions could be promoted as the best solution for waste management compliance
issues during compliance assistance projects.
Ensure that sustainability and stewardship initiatives are integrated into the NFS
environmental management system. Build a system that will address all current issues and be
sufficiently flexible to address future needs. For example, the environmental management system
should integrate pollution prevention projects such as point source air permitting and
transportation plans designed to minimize traffic in the park, both which contribute to establishing
a program to sustain regional/park air quality.
Increase awareness of understanding and dealing with environmental impacts (i.e., NEPA).
One means to accomplish this is NEPA training for managers and staff. The Environmental
Quality Division offered this in the past. Training has not been conducted recently due to budget
constraints.
Enhance the enforcement capability and posture for actions damaging NFS resources (e.g.,
illegal dumping). The recent enforcement action conducted at Mojave National Park where a
large illegal dumping action was successfully prosecuted demonstrates that this activity occurs. It
is also a model environmental crimes team approach within the NFS that could be effective at
other locations.
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PRINCIPLE 2: COMPLIANCE ASSURANCE AND POLLUTION PREVENTION
Performance Objective 2.1 — Compliance Assurance
The agency institutes support programs to ensure compliance with environmental regulations and encourages
setting goals beyond compliance.
Two headquarters programs have the most involvement in management of environmental compliance
programs. The Parks and Operations Directorate is responsible for hazardous materials and waste management,
solid waste, water and wastewater treatment, CERCLA, storage tanks and PCB management, energy and water
conservation. The Natural Resources Directorate manages the NFS NEPA and pest management programs. There
are some cross-directorate environmental management programs. An example is the management of air and water
pollution sources in which Park Operations is responsible for park pollution source management, while Natural
Resources is responsible for regional air and water quality. Similarly, affirmative procurement issues effect both the
Administration Directorate (Contracting and Procurement) and the Parks and Operations Directorate.
Environmental compliance guidance is currently distributed via standard means (i.e., a hard copy is sent to
regions for dissemination to parks). Guidance has been promulgated for hazardous waste management, solid waste
management, CERCLA compliance, fuel storage tanks, water and wastewater treatment (Public Health Service),
NEPA, and pesticide management, affirmative procurement (Contracting Officers Technical Memorandum 93-1)
and others. There is no formalized regulatory update process. The NFS relies on information provided by the DOI
OEPC and ad hoc sources for information.
The NFS is participating in a EPA/DOI Environmental Compliance Assistance Partnership. Partnership
projects include the CEMP study. There are also regional EPA/DOI and NFS partnerships (e.g., Inter-Mountain
Region (IMR)/EPA Region 8 Compliance Assistance Projects, OEPC San Francisco/EPA Region 9 Hazardous
Waste Management Training).
A draft Environmental Audit program document and 21 draft Envirocheck Sheets have been developed for
the NFS audit program. Audit program training was also conducted in October 1998. Regional audit initiatives
have also been developed. P2OAs have occurred at 76 locations in the IMR; Compliance Assistance Projects
(CAPs) have been conducted at 12 parks in the Midwest Region (MWR) and National Capital regions. Contracted
audits have been conducted at five locations in the Southeast Region (SER).
Under Development and Planned
The draft Environmental Leadership implementation strategy documents environmental compliance and
beyond compliance sustainable practices as key objectives. Beyond compliance goals are to be integrated into the
NFS strategic plan through the Government Performance Results Act (GPRA) process. A number of ongoing
projects have been incorporated in the draft Implementation Strategy. Other tasks have been identified that address
current deficiencies in the NFS environmental management system.
Twenty-eight Envirofact Sheets are in the final phase of production. They provide background compliance
information and serf-assessment checklists for waste streams, environmental compliance, and management programs
at parks. The Envirofact Sheets were disseminated via the Internet in FY 1999. Additional Envirofact Sheets are
planned as needs are identified.
The National audit program is currently under development. Thirty draft Envirocheck Sheets (i.e.,
environmental audit protocol sections) have been prepared and are undergoing review.
Audits will be conducted by individual regions with oversight and program management by headquarters.
The audit program is being designed to meet the following objectives:
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Establish baseline compliance;
Identify needs for compliance guidance;
Encourage pollution prevention as a management approach;
Elevate issues to upper management;
Encourage serf-audit and reporting; and
Address non-regulated risk.
Following completion of baseline audits, periodic audits of each park-level facility are planned. A system will be
developed to track corrective actions identified during the audit program.
The NFS Concessions program is developing new environmental standards and a self-audit/awards
program. A regional pilot program in hazard analysis is underway in the DVIR. Staff from NFS headquarters and
regions have participated in the EPA/Civilian Federal Agency (CFA) Task Groups and Roundtable and intend to
participate in the future.
Recommended Next Steps
The following steps are recommended to more fully address Objective 2.1:
Establish a reliable regulatory information transfer and updating system to communicate
changing environmental compliance needs to parks.
Develop a multi-media compliance workgroup to ensure that all environmental program areas
are addressed and compliance requirements and goals are evaluated comprehensively. For
example, ensure that air quality and water quality issues are addressed by involving Natural
Resource Air Quality and Water Quality Divisions in program development. This workgroup
should be established at an appropriate level to ensure adequate management support.
Include an assessment of the risk of non-compliance in the budget assessment and planning
process and strategic planning process at the park, region and Service level.
Seek and exploit opportunities to make good use of DOI (OEPC), other bureaus and other
agencies for cost-effective solutions to department-wide challenges. These could include:
• Training;
• Policy;
Quality assurance - audits;
Regulatory updating;
Reporting; and
Sharing lessons learned.
Beyond compliance activities
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Performance Objective 2.2 — Emergency Preparedness
The agency develops and implements a program to address contingency planning and emergency response
situations.
The NFS instituted an Incident Command (1C) system that is used for fire and flood management. The
program includes both national and regional incident commanders. Superintendents are provided with 1C training
through the Parks and Education Directorate fire management program.
Other Service-wide programs include a dam, bridge and road safety program managed through the Park
Facility Management Division and a natural resource damage assessment (NRDA) program for oil spill response
and assessment managed through the Environmental Quality Division.
Spill response systems at the park level vary widely. Comprehensive emergency response teams are
established at some parks (e.g., Padre Island). Over 500 park staff have received hazardous waste operation and
emergency response (HAZWOPER) training. Some parks have spill prevention, control, and countermeasures
(SPCC) plans, facility response, OSHA emergency response, and/or Resource Conservation and Recovery Act
(RCRA) contingency plans. However, a comprehensive needs analysis and park emergency planning compliance
assessment has not been completed for the NPS.
Under Development and Planned
SPCC, facility response plans (FRP) and RCRA contingency plan applicability and plan deficiencies for
parks will be assessed through the national audit program. Draft Envirocheck Sheets have been prepared for both
SPCC and RCRA programs.
A hazard analysis pilot is underway at five parks in the IMR. Plan automated response and communication
system software to develop park integrated contingency plans is being develop by the Environmental Quality
Division with the assistance of the University of Virginia.
Spill response management has historically been divided between the Park Facility Management Division
and Environmental Quality Division. Directors Order #79 on emergency response is being prepared to clarify roles
and responsibilities.
Recommended Next Steps
Establish park-level emergency response task forces and procedures to enhance the emergency
response and contingency planning process at Park facilities. Procedures should include the periodic review of park
emergency response and contingency plans to ensure currency and compliance with regulatory requirements.
Ensure adequate facility hazardous waste training for emergency response and preparedness.
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PRINCIPLES: ENABLING SYSTEMS
Performance Objective 3.1 — Training
The agency ensures that personnel are fully trained to carry out the environmental responsibilities of their
positions.
The NFS does not currently have a Service-wide environmental training curriculum. The only consistently
offered training courses are HAZWOPER and integrated pest management. Approximately 10 HAZWOPER
training courses are offered per year. The Public Health Service currently conducts these courses. The course is a
NPS customized program and consists of four hours of HAZCOM training, an eight-hour HAZWOPER refresher
training, 24 hours of HAZWOPER training, and two to four hours of pollution prevention training. The
Environmental Quality Division offers the integrated pest management training to park and regional integrated pest
management coordinators.
Over the last five years, other courses have been offered on a sporadic or one time basis. These have
included training on CERCLA, hazardous waste, underground storage tanks, solid waste, and NEPA compliance.
Regions have offered additional, unique environmental training (e.g., green procurement, hazardous materials
transport, SPCC, etc.). NPS personnel, other bureaus and agencies, NPS contractors, and academic institutions
provide this training.
Bureau of Land Management (BLM) environmental compliance training courses have been made available
to the NPS. These courses include an introduction to environmental compliance and pollution prevention,
emergency response/removal actions and emergency preparedness, environmental site characterization, hazardous
materials recognition for field employees, and CERCLA site assessment.
The NPS has conducted several pilot training courses over the last year. A draft Environmental Leadership
training for managers was piloted in April 1998. In November 1998, a distance learning pilot was conducted on the
NPS Envirofact Sheets through a partnership between the Hazardous Waste Management and Pollution Prevention
Team and Indiana University. The NPS has also begun investigations into distance learning opportunities in
partnership with the USEPA Region 8 and Front Range Community College in Colorado.
Under Development and Planned
The NPS maintenance training program in cooperation with the Hazardous Waste Management and
Pollution Prevention Team, in cooperation with Indiana University is developing a core environmental training
curriculum. This process involves the identification of "essential competencies" for all relevant positions in the
NPS and the development of a plan on what and how to deliver the required training.
In conjunction with the development of the curriculum, the NPS is continuing to investigate training
presentation methods. A distance learning pilot in hazardous waste management is underway. The NPS is also
planning to move forward with the Environmental Leadership training first piloted in April 1998. A pilot of the
complete training course was held in 1999.
Recommended Next Steps
The following are recommended next steps to more fully address Objective 3.1.
Expand environmental training requirements to address training needs beyond
"traditional" environmental career paths. Personnel conducting environmental functions are
in a variety of career tracks, particularly at the park level, where staff often have multiple duties.
For example, environmental compliance jobs such as hazardous materials management at the park
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level may involve the Safety Officer (Rangers), Buildings and Utilities Staff (Maintenance), Fire
Management and Aviation personnel, and Contract and Procurement Staff (Administration).
Develop an integrated training function. This should begin with a training needs assessment
which can reflect various NFS career fields. The integrated training function should address a
variety of environmental management programs including:
Environmental compliance;
Pollution prevention;
Sustainable practices;
Energy;
NEPA;
Integrated pest management;
Natural resources;
Environmental management systems; and
Health and safety.
The NFS environmental training program should extend beyond first line workers to senior staff
and managers and provide the appropriate type and level of training. For example, HAZWOPER
training may not be appropriate for personnel only requiring HAZCOM training or a
comprehensive RCRA course may not appropriate for staff at a park that is defined as a
conditionally exempt small quantity generator under RCRA.
Pursue training partnerships where resources are already available or efficiencies can be
gained. Joint training opportunities should be implemented with other DOI offices and bureaus.
The EPA should be used as a training resource both at headquarters and the regions. Other
government agencies should also be explored such as the Department of Defense (DOD) and
DOE.
Develop a tracking system to verify that training is received and completed, particularly
where there is a regulatory requirement for the training. This program should be developed on a
Service-wide basis to ensure consistency.
Training requirements should be reflected in position descriptions; completion of training
should be recognized in employee evaluations.
Conduct a training needs assessment for concessioners. The information from this needs
assessment should be considered in the training needs assessment and training implementation
plan for the NFS.
Conduct awareness training for concessioners. This training should address general
environmental stewardship, environmental issues of particular importance to concession
operations, and NFS and Concessions Division-specific environmental policy programs and
procedures.
Performance Objective 3.2 — Structural Supports
The agency develops and implements procedures, standards, systems, programs, and objectives that enhance
environmental performance and support positive achievements of organizational environmental and mission goals.
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The NFS has established planning and budget processes that can account for environmental impacts and
guidance documents which can enhance environmental performance. Some organizational goals have been
established.
There is currently no formal process for the review of environmental regulations and the dissemination of
updated information to the field. The Hazardous Waste Management and Pollution Prevention Team subscribes to
the Environmental Reporter published by the Bureau of National Affairs. The Reporter is reviewed and regulatory
updates are disseminated to the field on an ad hoc basis.
A formal NEPA process to evaluate environmental impacts has been developed within the NPS. A NEPA
Guideline, NPS 12 is currently used for all NPS proposed actions. The Environmental Quality Division at
headquarters manages the NEPA program. Procedures have been developed for internal and external NEPA
evaluation, documentation, and review. The NEPA process is addressed in the NPS Management Policies and
Level 2 policies.
The new Service-wide PMIS budget prioritization processes can include environmental ranking criteria. A
priority ranking process is in place for hazardous waste management and pollution prevention-specific program
funding.
Manuals and guidance containing operational procedures related to environmental management have been
prepared and updated. Manuals include an Integrated Solid Waste Alternatives Program (ISWAP) Manual (1996),
Hazardous Waste Handbook (1994), CERCLA Manual (revised in 1998), Fuel Storage Tank Management
Handbook (1996). NPS Guidance include NPS-77, Chapter 2, Integrated Pest Management (revised 1997),
NPS-50, Loss Control (OSHA programs) (1991), NPS-83, Public Health (Water and Wastewater Treatment)
(1993).
A draft Environmental Leadership implementation plan provides an environmental management
system-based three-year strategic plan for the NPS. The plan was developed based on park level, regional,
Washington Area Support Office (WASO) and senior NPS management stakeholder input. General mission and
goals for Environmental Leadership have been established as part of the planning process. A workgroup consisting
of park, regional and WASO representatives from various programs are spearheading the Environmental Leadership
effort.
Although general goals have been establish through the Environmental Leadership and strategic planning
processes, defined, measurable, environmental program goals for most environmental programs at the national level
have not yet been established. The only documented NPS goal is for solid waste reduction and recycling under the
ISWAP. The IMR has established a specific set of environmental performance goals through its Goals 2000
program.
Under Development and Planned
Implementation of various aspects of the Environmental Leadership strategic plan is currently underway.
These include policy development, development and promulgation of several environmental management tools (e.g.,
Envirofact Sheets), and others. Full implementation of the plan was planned for 2000.
The NPS is in the process of reviewing its Level I Management Policies and Level 2 policies to reflect
Environmental Leadership goals and ensure completeness relative to environmental programs. A Level 2 policy on
Environmental Leadership is under development. This policy will be overarching and provide comprehensive
standards and procedures for the majority of environmental management programs within the NPS. These will
include hazardous materials and waste management, affirmative procurement, fuels management, energy and water
efficiency, and others. An environmental audit policy is also planned. This policy may be stand-alone or part of the
Environmental Leadership policy.
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Several other Level 2 policies and guidance are being revised. These include those for the Public Health
Service (NFS water and wastewater treatment), Risk Management (OSHA programs) and NEPA compliance. An
updated HAZWOPER Manual and Lands Acquisition Guidance and Forms are currently being developed.
The Environmental Leadership training which is being developed, will provide awareness training in
environmental management systems, sustainability, contracted relationships, and other environmental management
programs.
Two objectives of Environmental Leadership strategic plan are the linking of action items to GPRA based
Service-wide strategic planning goals and the integration of the plan with other NPS initiatives (Natural Resource
Initiative, DOE/NPS Energy Partnership, Sustainability Initiatives). The later is already underway, the former is
one of the higher priority action items in the Environmental Leadership implementation plan. The encouragement
and promotion of Centers of Environmental Excellence is also planned.
Recommended Next Steps
The following are recommended next steps to more fully address Objective 3.2.
Clearly and explicitly link environmental compliance and sustainability needs and any
results of needs analysis to budget and resource planning and requests.
Ensure that all environmental-related initiatives throughout the organization are integrated
and coordinated to minimize redundancy, share lessons learned, and provide consistency
throughout the organization. This includes national initiatives (e.g., Natural Resources Initiative,
Energy Initiatives, Cultural Resource Program, Training and Development Program, Ranger
Activities) and regional/program initiatives (e.g., regional audit programs, regional sustainability
and pollution prevention programs, Denver Service Center and regional design processes).
Extend the National Environmental Leadership program to the regional and park level.
Establish regional and park Environmental Leadership strategic plans which will complement the
national plan and consider regional/park specific goals and needs.
Establish a process to review and revise existing environmental management structural
supports (i.e., procedures, standards, systems, programs, objectives, and goals) to ensure
performance and currency. For example, if a new Executive Order is promulgated that establishes
new federal agency energy efficiency goals, the bureau should have processes in place to identify
these new requirements and change policy, standards and implementation tools to meet these new
requirements. The NPS must also be able to react to and change procedures if they are determined
to be inefficient or outdated (e.g., technological changes).
The Concessions Division should develop NPS "Level 3" guidelines that outline operational
requirements for concessioners to comply with federal, state, and local regulations, and DOI
and NPS policy (at a minimum).
Performance Objective 3.3 — Information Management, Communication & Documentation
The agency develops and implements systems that encourage efficient management of environmentally related
information, communication, and documentation.
The Hazardous Waste Management and Pollution Prevention Team manages an Environmental
Information Management System (EIMS) to track their environmental project status. The bureau also maintains a
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tracking system for internal and external NEPA actions. The Team maintains a full time consultant on-site at
headquarters as an environmental information advisor.
Information management projects considered by the Hazardous Waste Management and Pollution
Prevention team are ranked like all other projects based on established environmental criteria. These projects
include green products databases, web site design, document conversion to web-compatible files for uploading.
DOI and the bureau have a number of electronic environmental information management/ communications
systems. The Park Facility Management Division manages a Green Alert bulletin board on which NPS personnel
can post information on environmental compliance, pollution prevention, and sustainable design and practices. The
IPM program of the Environmental Quality Division has an on-line pesticide application approval and reporting
system. The bureau also maintains a "Renew" web site that provides information on energy and water efficiency
and sustainable design. OEPC maintains a web site that provides some policy and guidance and provides links the
CERL Team Guide for those with password access. Regional web sites also provide information on sustainability
and NEPA program compliance.
In addition to distribution of materials by electronic means, hard copy documents such as manuals and
memorandum are distributed as needed. The typical distribution is to regional support office environmental
program coordinators who distribute the materials to the field.
Under Development and Planned
The PMIS, which is a Service-wide interactive, web-based system is likely to supercede the existing EIMS.
However, it is anticipated that the functionality (e.g., environmental ranking criteria) of the existing system will be
maintained.
The CERL Team Guide is planned to be used to update federal regulatory requirements. The NPS is
developing a Service-wide audit reporting and tracking system to support the national audit program currently under
development.
The Hazardous Waste Management and Pollution Prevention team is planning to offer Envirofact Sheets,
guidance documents and other environmental management tools on the web. As part of the Environmental
Leadership implementation plan, this web site may be integrated with other NPS environmental management web
sites such as the Renew energy and sustainable design site.
Recommended Next Steps
The following next steps are recommended to improve the existing, underway and planned information
management, communication and documentation systems at the NPS.
Develop an integrated environmental information strategy. Such a strategy should include the
following:
Assessment of critical information needs;
Inventory of existing information sources;
Strategy that integrates existing tools (national and regional, internal and external),
considers emerging technologies and has an architecture that will provide for expansion;
and
Implementation program to address information gaps by priority.
The NPS should establish or rely upon a periodic organization-wide update (e.g., newsletter) to
provide a reliable communication mechanism for routine but important information.
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Develop and implement guidance on centralized filing and recordkeeping systems at the
regional and park level for all environmental records and documents. Such an approach will
help assure compliance with regulatory reporting and recordkeeping requirements and facilitate
park/region internal reporting. It can also be helpful in identifying environmental management
deficiencies on an ongoing basis and at the time of audits, and will provide a consistent program
which environmental program managers and superintendents will understand even if transferred
from one location to another.
The Concessions Division should develop electronic (Internet) and other systems to
effectively transmit environmental program information and data to concessioners (e.g.
policy and procedures, environmental audit data).
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PRINCIPLE 4: PERFORMANCE AND ACCOUNTABILITY
Performance Objective 4.1 — Responsibility, Authority, and Accountability
The agency ensures that personnel are assigned the necessary authority, accountability, and responsibilities to
address environmental performance, and that employee input is solicited.
Park superintendents and regional directors maintain line responsibility for park and regional activities,
respectively.
Regional environmental program coordinators have been identified in each region. These coordinators
address Hazmat, CERCLA, underground storage tanks, and solid waste programs. Staff range from a single
coordinator in a region, to coordinators for each of the programs. NEPA environmental compliance coordinators
are also present in each region. These staff have no line authority. Their role is primarily advisory; they also assist
in the annual environmental budget prioritization process.
Regional environmental audit coordinators have been designated to conduct the NFS internal audit
program in their regions. This is not a new position, but an additional duty for the existing regional environmental
program coordinators.
Park level environmental coordinators have been established in less than 15 percent of the parks.
Environmental program management responsibility at the park resides with the superintendent. Maintenance staff,
the park safety officer, or others conduct day-to-day operations, often as a collateral duty.
Under Development and Planned
The NER is developing an accountability management system for its park superintendents. The system
includes a best practice measurement criteria on Environmental Leadership which states that the park must, "meet or
exceeds all environmental laws, and fosters sustainability in all aspects of park operations."
Under the Service-wide environmental audit program, NPS plans to develop park-level audit points of
contact. These individuals may be responsible for coordinating the audit and follow-up actions. A Service-wide
environmental coordinator position has also been proposed. This coordinator would help implement the NPS
Environmental Leadership strategy currently under development. The coordinator would be responsible for
overseeing multi-directorate environmental management activities including some with regulatory compliance
aspects (e.g., hazardous waste management, affirmative procurement). Direct line responsibility for compliance
would still reside with the Director, Regional Directors, and Superintendents.
The Environmental Leadership training which was piloted in April 1998 provides awareness of
management responsibility for environmental compliance programs.
Recommended Next Steps
The following next steps are recommended to more fully address Objective 4.1.
Assign responsibility and authority to manage environmental programs and ensure
environmental compliance at each park. These individuals should be responsible for managing
environmental information systems and assuring environmental training and facility management
requirements are met at the park level. They should be responsible for all overseeing all aspects
of environmental management so that environmental compliance can be addressed through an
integrated approach. They should be answerable to the superintendent on park environmental
performance. The time commitment for this position should be commensurate with the
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complexity of the park and associated environmental programs/issues. The position may be
accomplished as one of several assigned duties at a smaller park. At a larger park, the duties may
be full-time.
Establish environmental coordinators in each region. These individuals would serve as a
single environmental management point of contact for oversight and coordination of regional
environmental programs and a technical support clearinghouse to the parks. Responsibilities
would include environmental information dissemination, coordinated reporting and budget
requests, and integration of tasks with multi-program implications (e.g., green procurement that
involves facility management (requisition) and administration (contracting and procurement).
Efforts of individual regional program coordinators would not necessarily be eliminated, but could
be facilitated and coordinated. The coordinator would be accountable for ensuring parks and
headquarters have the information necessary to be environmentally compliant.
Establish a policy on environmental accountability and include this in the Service-wide
environmental policy (see Objective 1.1). This policy could serve to standardize expectations
across the bureau. The policy should establish environmental compliance as a minimum
requirement for parks, not as a best management practice.
Provide a Service-wide environmental coordinator with the authority to resolve conflicting
spheres of authority and designate line responsibility where not established (e.g., emergency
response, water and air pollution control). This position should not be expected to have full
responsibility for overall bureau environmental performance.
Performance Objective 4.2 — Performance Standards
The agency ensures that employee performance standards, efficiency ratings, or other accountability measures, are
clearly defined to include environmental issues as appropriate, and that exceptional performance is recognized and
rewarded.
The DOI and the NFS have award programs for exceptional environmental achievement. DOI and NFS
environmental achievement awards may be given to specific individuals, project teams, or external stakeholders
(organizations and contractors). DOI and NFS also established awards for natural resource stewardship
(Departmental Conservation Award and Directors Award for Natural Resource Management).
Environmental criteria have been incorporated into performance standards for most regional environmental
program coordinators and for a number of NFS headquarters staff (6 to 8 full-time equivalents). These individuals
reside primarily in the Hazardous Waste Management and Pollution Prevention Team and Environmental Quality
Division. The performance criteria for these personnel are for duties in an advisory capacity, which are not based
on park/region/bureau performance.
Environmental performance is infrequently used as a performance measure for park staff. Only a small
number of park have staff accountable for environmental programs (safety officers or environmental protection
specialists).
Under Development and Planned
The development of standardized Environmental Leadership language is planned for position descriptions
and performance standards as part of the Service-wide Environmental Leadership program.
Incentive programs (monetary rewards and publicity) are planned to promote Centers of Environmental
Excellence in the NFS. It is anticipated that monetary rewards will help offset some of the cost associated with
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providing assistance outside standard job requirements. The existing NFS environmental awards program is
planned to be expanded to include all career fields and programs. Monetary awards and protocols for regional and
park Environmental Leadership rewards are planned.
Recommended Next Steps
The following next steps are recommended to enhance the performance standards and reward programs at
the NFS:
Measure personnel performance in light of the environmental responsibilities that have
been assigned.
Develop organizational environmental compliance goals. Use this information to develop and
customize regional and park level goals.
Ensure that park-level personnel with environmental management and/or compliance
responsibilities have those responsibilities included in their performance standards. Link
individual environmental compliance and management performance standards with organizational
goals. Also ensure that personnel environmental performance goals are linked specifically to
compliance as well as other sustainable practice measures.
Ensure that performance criteria are formally incorporated into the managerial and
employee performance evaluation process. Performance goals and standards are not effective
unless they are instituted. Make sure that environmental criteria are adequately weighted based on
the level of accountability and responsibility. Provide means to penalize poor performance as well
as reward good performance.
Institutionalize environmental compliance into the NFS by fostering the development of
environmental compliance as a professional and valued career path in the NPS. In addition, make
environmental management experience a required Knowledge Skills and Abilities (KSA) for NPS
Managers. This will 1) institutionalize an understanding of environmental management
importance and issues in senior management (having experienced it first-hand) and 2) generate a
pool of professionals to do the environmental management work by creating the market.
Promote the DOI and NPS environmental achievement awards so that they become valued
rewards within the department/bureau and also with other Agencies. As a bureau that has a
mission responsibility of environmental stewardship, an environmental achievement award should
be highly valued. Recognition by the Director and public promotion of the program and recipients
should be considered as well as monetary compensation.
Develop an environmental recognition program for concessioners that have demonstrated
consistent environmental compliance and implemented "beyond compliance," pollution
prevention, and sustainable operations.
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PRINCIPLE 5: MEASUREMENT AND IMPROVEMENT
Performance Objective 5.1 — Evaluate Performance
Sub-Objective 5.1.1: Gather and Analyze Data — The agency institutes a systematic program to periodically obtain
information on environmental operations and evaluate environmental performance against legal requirements and
stated objectives, and develops procedures to process the resulting information.
For the past few years, selected NFS regions have developed and implemented systems to collect
environmental performance data. These have included:
Environmental audits in the SER where a contractor has completed five audits to date.
CAPs in the MWR, where 14 of 56 park units have been addressed and in the NER, where 3 of 96
park units have been addressed. CAPs are traditional environmental compliance audits with an
emphasis on pollution prevention as a preferred approach for follow-up actions. The MWR also
includes safety and health issues in the CAP scope.
Pollution prevention opportunity assessments (P2OAs) conducted in the IMR. Since 1995, 79 of
81 park units have been addressed.
RCRA Subtitle C compliance audits completed by the Alaska Department of Environmental
Conservation. These audits are funded by EPA through the EPA/DOI partnership. Of the 13
planned, two have been completed.
In 1998 the NFS initiated a national environmental auditing program in response to DOI Departmental
Manual 515, Chapter 2. Initial steps taken to establish the new program included assignment of a national program
manager and regional program managers. A national program orientation and planning meeting was held (10/98)
with all regions participating. Substantial regional input was incorporated into the national program.
The US Public Health Service (PHS) conducts sanitation orientated evaluations of park-units independent
of the audit program. These address water and wastewater treatment systems and food services.
Under Development and Planned
The NPS plans to strengthen the national auditing program to ensure consistency in evaluation, follow-up,
and information management, including reporting. To do this, the following are expected:
Development and dissemination, internally and externally, of an audit program guide that will
document key aspects of the national program, including expectations for regional program
implementation.
Development and implementation of an auditor training program. Currently envisioned as week
of hands-on auditing instruction and a periodic refresher course.
Development and dissemination of NPS audit tools, including: compliance-focused checklists
emphasizing pollution prevention and sustainable practices, NPS functional summaries, reporting
formats, and compliance assistance tools such as fact sheets. In the initiation phase, the national
program is expected to provide regional program staff with these tools. The tools will specify
minimum national program requirements. Regional audit program staff will be allowed to
customize the tools to address unique regional needs or priorities, as long as national program
needs are met.
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CEMP Evaluation of the National Park Service
Development and deployment of an audit information management and reporting system. Data on
audit findings and corrective action status will be maintained in a regional/national database to
facilitate efficient periodic and ad-hoc analyses and reporting. The database is expected to be
used to evaluate environmental performance and identify areas requiring additional attention.
Development and implementation of a NFS audit protocol that is unique to NFS facilities and
operations. The protocol will be designed for an internal audit function and wide-ranging staff
experience and expertise.
Development of audit criteria for evaluating management support for environmental programs at
the park-unit level.
Development and implementation of an audit data utilization plan. Audit data will be used in
management-level decision-making on topics including: project funding, training, policy, staff
performance evaluations, and environmental management program planning.
The NER and the PWR plan to develop supplemental audit criteria. In the regard, the NER is developing
"green" audit criteria and the PWR is developing "sustainability" audit criteria. These criteria may be addressed
during regional audits or by a separate evaluation process.
Recommended Next Steps
The following are recommended next steps to more fully address Sub-Objective 5.1.1.
Develop and implement a quality assurance (QA) function for the audit program. At a
minimum, the QA function should be designed to ensure national consistency in auditing and
evaluate the effectiveness of the audit program. Suggested quality indicators include: (1) number
and severity of audit findings; (2) number and timeliness of corrective actions; and (3) quantities
of pollution prevented. Quality indicators should be linked to audit program performance
objectives.
Ensure that root cause analysis is included in park-level audits. Root cause issues should be
addressed as both audit findings and as the basis of corrective actions. Root cause analysis should
be linked to EMS issues already planned to be addressed in audit criteria and account for portions
of the CEMP relevant to park-units.
Ensure that all audit functions remain independent and objective. To be independent,
auditors must be organizationally separate from the facilities and operations audited. To be
objective, auditors must not have an actual or perceived conflict of interest; must not suffer
negative consequences or enjoy rewards resulting from audits; and must not have a general bias
that affects their work. To do this, NFS may find it necessary to implement organizational
changes, such as creating an independent audit group.
Ensure that audit data and information is widely used in NFS facility and organization
management. Audit information should be heavily weighted and integrated into project
planning, budgeting, and performance evaluation decisions. Audit information should routinely
be considered by senior management as a reliable indicator of environmental performance at the
park level and higher.
Ensure that facility-level concession operations are included in the service-wide
environmental auditing program currently being implemented and that environmental
performance results should be tied to contract evaluation.
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CEMP Evaluation of the National Park Service
Sub-Objective: 5.1.2: Institute Benchmarking — The agency institutes a formal program to compare its
environmental operations with other organizations and management standards, where appropriate.
Formal and documented benchmarking activity comparing the NFS environmental organization against
others and standards has not occurred. To a large extent, NFS environmental staff consider their organization and
activities unique, and therefore incomparable.
During the interview portion of this review, various NFS staff indicated that they were leaders in
environmental management simply because, "they were the Park Service." Thus, there appears to be a perception
that NFS environmental management is a de facto standard for other organizations, and therefore it is not necessary
to benchmark against other organizations.
A few NFS staff expressed some interest in understanding how their EMS and compliance record
compared with other civilian federal agencies; however, evidence of a widespread NFS commitment to a
comprehensive inter-organizational understanding was absent. Such an absence seemed incongruous with the
recently launched Environmental Leadership program. However, "Leadership" in this case, seems to refer to the
development of leadership internal to the NFS, not of the NFS compared to other organizations. This approach
overlooks the potential benefit of learning from others.
Informal benchmarking activities have included:
Occasional NFS staff participation in EPA Regional and headquarters roundtable discussions;
Staff participation in the DOI environmental and energy task groups;
Staff participation in internal (NFS and DOI) environmental meetings as presenters or attendees;
and
Staff participation in external interest groups and professional associations, especially related to
sustainability.
It is entirely possible that NFS is an EMS leader in some areas, however, benchmark data to demonstrate such
leadership was not available.
Under Development and Planned
Formal EMS benchmarking activities were neither under development nor planned.
Recommended Next Steps
Benchmarking offers an attractive path to NFS EMS performance improvement through adoption of
practices already proven to be effective by other organizations. To do this the NFS should take the following steps:
• • Identify specific management areas most likely to benefit from benchmarking. These
include key EMS elements defined by the CEMP (e.g., auditing, training, and others) and key
NFS functional or organizational characteristics (e.g., civilian federal agency, natural or cultural
resource management, or eco-tourism). These may be public or private.
Participate in or conduct periodic documented benchmark studies. Use the resulting
information to advance development of a refined EMS.
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CEMP Evaluation of the National Park Service
Explore a formal EMS protegee relationship with a more advanced organization in each of
the targeted areas identified in the previous step. One organization is not likely to be a perfect
mentor in all relevant areas so several may be necessary.
Maintain a constant level of benchmark activity with other DOI bureaus and offices. Given
many similarities among these organizations, the participants (NFS and other DOI units) should
reap significant short-term benefits. This activity will likely result in a more cohesive and cost-
effective DOI-wide EMS.
Explore the possibility of mentoring another organization. By serving as a mentor, the NFS
should be motivated to maintain a more advanced EMS. The mentored organization may be
public or private. A regional or state park organization may be a good candidate.
Support and encourage active staff participation in relevant professional organizations and
conferences. This should be considered an essential activity for key staff career advancement.
Performance Objective 5.2 — Continuous Improvement
The agency implements an approach toward continuous improvement that includes preventive and corrective
actions as well as searching out new opportunities for programmatic improvements.
Suggestions for environmental management improvement within NFS are generally encouraged. Some
specific mechanisms include:
Annual regional NFS environmental coordinators meetings. At past meetings a list of action items
for improvement was developed and included in staff objectives.
The Green Alert BBS is an internal electronic communication system to share information on
environmental experiences. The BBS also has been used to solicit input on environmental issues
and to post notices on issues of broad interest.
The MWR newsletter "CAP Tion" focuses on sharing information on audits (i.e., CAPs) lessons
learned, compliance issues, and pollution prevention.
Informal networks of focused interest groups. Some examples include the sustainability task
group, and groups on solid waste management. Additionally, when groups assemble for regional
training, (e.g., HAZWOPER) there is often informal discussion about ideas for environmental
program improvement.
The PWR assembles a meeting of zone coordinators annually where EMS issues are raised.
Environmental projects are considered and discussed at annual budget meetings. These typically
focus on facility (e.g., building) improvements.
It is clear that NFS staff eagerly seek information on EMS improvements in multiple ways; however,
operating procedures for environmental management are evaluated by NFS regions and headquarters on an
as-needed, rather than periodic, basis. In addition, "sustainability champions" actively seek lessons learned from
other agencies, the commercial sector, and international organizations. In general, the onus for continuous
improvement efforts appears to lie with committed individuals. An organization-wide continuous improvement
mechanism addressing the NFS EMS was not apparent.
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CEMP Evaluation of the National Park Service
Under Development and Planned
The environmental audit program is expected to be used extensively to identify opportunities for
improvement.
The audit tools "EnviroCheck Sheets" will provide information on lessons learned to educate both
auditors and staff at audited entities during site visits.
Regional based audit programs will allow internal comparisons and sharing of best management
practices.
Root-cause analysis will be included in audit findings to identify underlying needs which, if
addressed, will prevent future occurrences.
Audit data will be extrapolated to identify national or regional needs so they can be addressed
earlier.
The Draft Environmental Leadership program training is expected to include lessons learned in
key environmental management system areas. Examples include procurement, training, response,
and waste management.
Recommended Next Steps
The following steps are recommended to the NFS to establish and maintain a continuous improvement
process.
Seek ways to integrate compliance issues into other environmental or green initiatives. All
related initiatives must acknowledge the importance of regulatory compliance.
Conduct periodic review of operating procedures. Most aspects of NFS operations are
addressable by an EMS. Consequently, all NFS operational procedures should be reviewed
periodically for current EMS issues. This includes, for example, internal operations, concessioner
and other contracted relationships, and visitor programs. Ensure that identified improvements are
incorporated into the next planning cycle.
Formalize an organization-wide EMS improvement suggestion system. The system should be
open to staff, concessioners, visitors or others. Ensure that suggestions are considered by
management with sufficient knowledge of EMS objectives and with authority to implement.
Consider implementing a reward system for "best" suggestions.
Employ results of environmental audit program and related root cause analyses to identify
opportunities for EMS improvement (not just compliance) and periodically assess the
effectiveness of corrective actions.
Establish partnerships with "Best in Class" organizations to jump start ideas for EMS
improvement. These leading organizations can be identified from benchmarking activities. See
related recommendations in 5.1.2 on mentor and protegee relationships.
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CEMP Evaluation of the National Park Service
MATRIX OF CEMP FINDINGS AND RECOMMENDATIONS
A-l
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CEMP Study of the National Park Service
Principle 1: Management Commitment
Performance Objective: 1.1 Obtain Management Support
Sub-Objective: 7.7.7 Policy Development - The agency establishes an environmental policy followed by an environmental program that
complements its overall mission strategy.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Current policy (1988) addresses
environmental aspects (e.g.
recycling, waste management)
as part of overall Management
Policies. Compliance addressed
in :
• CH 2: NEPA
• CH 4: Air and Water
• CH 9: Water, Wastewater,
Hazmat, Toxic Waste, and
Solid Waste.
Overall "compliance" is
implicit.
2. Special Directives and Staff
Directives (considered internal
working policy) address waste
management, USTs, ISWAPS,
pesticide use, and other
environmental programs.
Entire policy system is under revision at this time.
1. Existing Management Policies are under
review (~10 year cycle), providing
opportunities to address environmental
aspects more directly. Broad call for
involvement.
2. Various efforts addressing environmental
policy:
• Proposed EL initiative includes
environmental principles which, if
approved, could become policy.
• Proposed NR initiative addresses
environmental compliance in Principle
No. 9. "The NPS will comply with all
environmental laws and apply the highest
standards of environmental stewardship to
its operations."
(EL , NR, and other initiatives with environmental
aspects have growing key stakeholder
involvement.)
• Concessions Operations is revising
environmental policy applicable to
contracted services.
• Hazmat policy collection under review.
Share results of
initiatives (e.g. EL and
NR) internally and
externally (e.g.
concessions) through
management training
(e.g. EL) and "normal"
channels.
Obtain additional input
on NPS policy goals
through EL initiative
senior stakeholder
meeting.
1. Develop a comprehensive
environmental policy. In doing
this:
• Account for: (1) traditional
(e.g. compliance); (2) planned
(e.g. sustainability); and (3)
independent efforts underway.
• Prepare draft and final policy
with wide internal and external
participation.
• Use policy development as a
consensus building exercise for
key stakeholders at all levels.
• Set goals for key environmental
indicators.
2. Include environmental policy in
staff and stakeholder education
(e.g Compass I, II). Make sure
message gets out through
periodic and management
supported promotion (e.g.
brochure, contract language,
awareness training, web page,
posted document).
3. Include specific reference to
concessioners in environmental
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CEMP Study of the National Park Service
Principle 1: Management Commitment
Performance Objective: 1.1 Obtain Management Support
Sub-Objective: 1.1.2 System Integration - The agency integrates the environmental management system throughout its operations, including
its funding and staffing requirements, and reaches out to other organizations.
EXISTING
UNDER
DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Annual HWMPP team project review
funding occurs with selection based on
relevance to four categories: Waste
Reduction and Management; Fuel Storage;
Contaminated Sites; and Technical Support.
Each category has ranking criteria; system
to be integrated into a Project Management
Information System (PMIS).
2. Environmental due diligence reviews occur
with property transfer.
3. Annual report to DOI on project status and
resources for site restoration. Included in
DOI FY Accountability Report.
4. Concessions Operations has an
environmental coordinator on staff.
NPS Comments/Additions
1. Annual natural resources funding allocation
process.
2. Contaminants Technical Advisory Group
quarterly meetings.
Regional support capability
is being made more broad
(e.g. multimedia) through
internal audit program.
1. Through the proposed
environmental audit
program:
• A park-level POC is to
be established in
advance of the site visit;
and
• Responsibility for
environmental
management and
specific corrective
actions will be specified.
2. Incorporate environmental
audit program data into
budget/funding decisions.
1. Develop and provide "awareness"
level training to all levels of
management (different than
environmental training in 3.1).
2. Broaden scope of environmental
criteria (e.g. waste and water) to
review all project funding requests
in one integrated environmental
aspects evaluation.
3. Acknowledge Service-wide need
for funding and personnel
allocated specifically to
environmental compliance.
4. Develop a Concessions Division
environmental policy that
mandates concessioners comply
with "Concessions Environmental
Guidelines" (see Principle 3.2).
5. Modify concessions contracts and
facility operating plans to include
performance criteria.
6. Incorporate environmental
program needs into Concessions
Program budget process.
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CEMP Study of the National Park Service
Principle 1: Management Commitment
Performance Objective: 1.2 Environmental Stewardship and Sustainable Development - The agency strives to facilitate a culture of
environmental stewardship and sustainable development.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Stewardship and sustainability are
founding philosophies of the NFS.
2. Sustainable Design Guidelines and web
site.
3. A few regions (e.g. NER, NCR) offer
training in green procurement and
sustainable design.
4. Sustainable Re-Development Addendum's
to selected GMPs (e.g. GCNP).
5. Management Policies and internal
direction (e.g. Natural Resources,
Concessions Operations) include
sustainable design.
6. Draft Environmental Leadership Towards
Sustainability training.
7. Design for Environment concepts
incorporated into building design.
8. NPS experts participate in external
projects (Easter Island, Australia).
9. NPS cost recovery program (PRP search
manual, CERCLA manual).
1. Training telecast via satellite
on sustainability in
partnership with academia
(Denver Service Center).
2. Annual DOI environmental
meeting participation with
focus on sustainability (and
other environmental topics).
3. DOE-sponsored
sustainability initiative with
DOI-focused on
transportation
4. NR initiative.
5. NER/PWR sustainability
initiatives.
1. Assistant Secretary
directed EL initiative
focused on sustainability.
2. National Renewable
Energy Laboratory
(NREL) Memo of
Understanding focused on
sustainability.
1. Account for existing and planned
environmental management
responsibility (e.g. compliance) in
sustainability initiatives.
• Link sustainability coordinators
with compliance coordinators to
facilitate harmony.
• Merge and coordinate various
environmental initiatives (e.g. DOI,
DOE-NREL, EPA, NPS)
1. Ensure integration of sustainability
and stewardship initiatives in NPS
environmental management system.
Build a system that will address all
current issues and be sufficiently
flexible to address future needs.
2. Link and increase awareness of
understanding and dealing with
environmental impacts (e.g. NEPA).
3. Enhance enforcement capability (i.e.,
additional resources) and posture for
actions damaging NPS resources
(e.g., illegal dumping).
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CEMP Study of the National Park Service
Principle 2: Compliance Assurance and Pollution Prevention
Performance Objective: 2.1 Compliance Assurance - The agency institutes support programs to ensure compliance ~with environmental
regulations and encourages setting goals beyond compliance.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT STEPS
1. Compliance guidance distributed via
standard means for: hazwaste, solid
waste, CERCLA, tanks, water and
wastewater treatment, NEPA,
pesticide management.
2. Participate in EPA/DOI partnership.
3. Other regional (e.g. IMR) EPA/DOI
partnerships exist; EMR's being
implemented at several parks.
4. Rely on DOI/OEPC and ad-hoc
sources for regulatory updating.
5. P2/sustainability is a preferred
enviromental management approach.
6. Two HQ groups focused on
compliance: park operations and
education - hazmat, hazwaste;
natural resources - NEPA, air, water,
pesticides.
7. Regional Initiatives: P2OAs in IMR
(76); Compliance Assistance Projects
(CAPs) in the MWR and NER (12);
and contracted audits in the SER(5).
8. Draft Envirocheck Sheets and
training for 21 audit criteria areas.
1. Twenty nine EnviroFacts on
waste streams, compliance,
and environmental
management programs for
parks; to be disseminated on
the Internet.
2. National Environmental Audit
Program:
• Baseline compliance;
• Identify needs for compliance
guidance;
• Encourage P2 as an
approach;
• Elevate issues to upper
management;
• Encourage self audit and
reporting; and
• Addresses non-regulated
risks.
1. Participate in EPA/CFA Task
Group.
2. Regional pilot program in
hazard analysis (IMR).
1. Periodic audits of each park-
level facility.
2. Track corrective actions via
new information system
(Environmental Audit
Program).
3. Establish standard records
management system.
4. Establish "beyond
compliance" goals and assure
completion.
5. Additional EnviroFacts and
Envirocheck Sheets.
6. Concessionaire self-audit
program.
1. Establish a reliable regulatory
updating system to communicate
changing needs to parks.
2. Develop multimedia compliance
workgroup to ensure all
environmental program areas are
addressed and program
environmental compliance
requirements and program and goals
can be evaluated comprehensively.
3. Include compliance liability risk
assessment as a park-level
management decision tool.
4. Seek opportunities with DOI (OEPC)
for cost-effective solutions to
Department-wide challenges.
• Lessons learned.
• Cost sharing solutions benefiting
other bureaus and offices. For
example:
* training
* policy
* QA - audits
* regulatory updating
* reporting
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CEMP Study of the National Park Service
Principle 2: Compliance Assurance and Pollution Prevention
Performance Objective: 2.2 Emergency Preparedness - The agency develops and implements a program to address contingency planning
and emergency response situations.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT STEPS
1. Regulatory programs include:
• SPCC Plans
• Facility Response Plans
1. Dam, Bridge, and Road Safety
program
2. NRDA component (e.g. oil spill)
3. Incident Command (1C) system;
national and regional incident
commanders; superintendent 1C
training via Parks and Education
Fire Management Program
4. Preventive Maintenance and
Rehabilitation programs
5. >500 HAZWOPER trained staff
nationally.
6. Fully established emergency
response teams at some parks
(e.g. Padre Island).
1. Hazard Analysis Pilot at five
parks in IMR.
2. Plan Automated Response
and Communications System
(PARCS) software to
develop integrated
contingency plans.
3. Directors Order #79 on
emergency response clarifies
roles and responsibilities.
1. SPCC FRP and RCRA
contingency requirements for
parks to be screened in NPS
environmental audit program.
1. Establish park-level ER task forces and
procedure for periodic park-level
emergency planning task force review.
2. Identify non-regulated, but
unacceptable, risk areas (e.g., known
PCB contamination below action levels,
non-NPS transport incidents on NPS
property) and include in preparedness
programs.
3. Seek advanced prevention programs for
remote or highly sensitive areas.
4. Implement Integrated Medical
Monitoring program (e.g. RPP gaps).
5. Provide awareness to parks on
emergency response team support
requirements (training, H&S Plan,
equipment, etc.).
6. Confirm programs for:
• EAPs (OSHA)
• RCRA Contingency Plans (EPA)
• "One" Plan Utilization
7. Expand superintendent 1C training
beyond parks by including fire
management requirements.
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CEMP Study of the National Park Service
Principle 2: Compliance Assurance and Pollution Prevention
Performance Objective: 2.3 Pollution Prevention and Resource Conservation - The agency develops a program to address pollution
prevention and resource conservation issues.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. National evaluation of recycling in NFS
conducted in 1993. Waste stream analysis
conducted in 10 parks in 1995.
2. National Integrated SW Management
program established: policy, guidance,
training; waste reduction/recycling goals.
3. Most parks have established SW recycling
programs; feasibility studies conducted for
composting at larger parks.
4. P2 is a preferred management approach.
5. P2 assessments in the IMR (76);
sustainability assessments in regions (e.g.
PWR).
6. LCC and material reuse is promoted
through NFS Sustainable Design Guidelines.
Some regional sustainability guidelines
(MWR, NER).
7. Energy conservation projects/audits
completed through NPS/FEMP and
university (JMU) partnerships.
8. Green product cost differential
underwriting program through HQ.
1. Green product selection
database pilot in IM region.
2. Green procurement, waste
reduction, recycling
EnviroFacts.
3. Full scale alternative energy
projects (PV, geothermal)
via NPS/FEMP partnership.
4. Concessionaire polices being
developed which encourage
waste reduction and green
procurement.
5. Environmental Leadership
training includes modules on
waste management with P2
focus and contracted
relationships with focus on
EPP principals.
6. Chemical substitution fact
sheets (IM region).
1. Green procurement pilot
for concessionaire
operations at Yellowstone.
2. Green procurement, water
conservation, energy
conservation, and solid
waste management
screening during
environmental auditing. P2
opportunities to be
addressed in audits.
3. NPS/University/FEMP
partnership energy audits
(6+ parks).
4. Standard contract language
encouraging green
procurement.
NPS Comments/Additions
1. Employ P2 strategies as a
means of reducing
potential compliance
liabilities (e.g., toxics use
reduction/ elimination)
1. Update waste stream analyses for
NPS to determine current
recycling/reuse opportunities and to
track ISWAP success.
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Principle 2: Compliance Assurance and Pollution Prevention (Continued)
Performance Objective: 2.3 Pollution Prevention and Resource Conservation - The agency develops a program to address pollution
prevention and resource conservation issues.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
NFS Additions/Comments
1. Developed SOP for solid waste stream
characterization.
1. Implement pollution
prevention and waste
reduction programs at
parks based on
environmental audit
program recommendations.
2. Integrate EPP purchasing
into NPS procurement
procedures (national
program and in parks).
3. Conduct P2 opportunity
assessments (PPOA) in all
NPS regions or include
PPOA in audit program
protocol.
4. Develop and implement
Service-wide green
procurement programs.
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CEMP Study of the National Park Service
Principle 3: Enabling Systems
Performance Objective: 3.1 Training - The agency ensures that personnel are fully trained to carry out the environmental responsibilities of
their positions.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Environmental awareness training
has occurred sporadically on: USTs,
hazmat, and solid waste
management; and periodically
(10x+/yr) for HAZWOPER (PHS).
2. Customized HAZWOPER training
available (~10 per yr.) to cover:
• HAZCOM (4 hr)
• HAZWOPER Refresher (8 hr)
• HAZWOPER (24 hr)
• P2 (2-4 hr)
1. BLM environmental compliance
training program is available to
NFS.
2. Distance learning pilot (via IU) on
EnviroFacts occurred 11/98.
3. Draft environmental leadership
training piloted (4/98).
4. Courses in solid waste, CERCLA,
hazwaste and fuel storage tanks, and
NEPA offered over last five years.
5. Annual pesticide management
training.
6. Regions have additional unique
1. Distance learning program
pilot in hazardous waste
management.
2. Environmental Leadership
Towards Sustainability
training pilot for
management.
1. Explore effectiveness of
distance learning for
environmental requirements.
2. Environmental training core
curriculum analysis.
1. Update training needs assessment by
NPS career path and environmental
management program; address full
dissemination of training beyond
first line workers.
2. Implement joint training
opportunities with other DOI
bureaus and offices.
3. Pursue EPA as a training resource
(regions/HQ).
4. Pursue other government training
source opportunities (e.g.
DOD/COE).
5. Form an integrated training function
addressing:
• Health and Safety
• Natural Resources
• Energy
• Sustainability
• Environmental Compliance and
Beyond
• P2
• EMS
6. Develop means of verifying that
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Principle 3: Enabling Systems (Continued)
Performance Objective: 3.1 Training - The agency ensures that personnel are fully trained to carry out the environmental responsibilities of
their positions.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
7. Conduct a training needs
assessment for concessioners.
8. Conduct awareness training for
concessioners.
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CEMP Study of the National Park Service
Principle 3: Enabling Systems
Performance Objective: 3.2 Structural Supports - The agency develops and implements procedures, standards, systems, programs, and
objectives that enhance environmental performance and support positive achievements of organizational environmental and mission goals.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Internal and External NEPA
program through EQD.
Guidelines established.
2. New NFS-wide PMIS budget
prioritization processes can
include environmental ranking
criteria. A priority ranking
process is in place for HWMPP
specific program funding.
3. Manuals and guidance containing
operational procedures have been
prepared or updated: (e.g. Solid
Waste (ISWAP) ('96), Hazwaste
Handbook ('94); CERCLA
Manual (rev. '98); Tank Manual
('96); Pesticides ('97); Loss
Control (OSHA programs) ('91);
Public Health ('93)).
4. Draft EL strategy provides EMS-
based plan for NFS. 1,2,3-yr plans
and estimated funds. Developed
based on stakeholder input.
Active ELI workgroup.
1. Level I and II policy review for
environmental programs
completeness and to reflect ELI
goals. Part of ongoing Directives
Management Program revisions
and 10-yr Level I Management
Policies review.
2. Revised PHS (water and
wastewater treatment), risk
management, and NEPA
guidelines.
3. Updated HAZWOPER training
manual.
4. ELI training which will provide
awareness training in EMS,
sustainability, contracted
relationships, and others.
5. Natural Resources Initiative
establishes goal for
environmental stewardship
through environmental
compliance.
6. Revised lands acquisition
guidance and forms.
1. Integrate GPRA and EL to
establish measurable goals tied to
NPS strategic plan.
2. Implement EL strategic plan.
3. Policy Office review of policies to
address new Directive
Management System
requirements (e.g. policy in level
I and II, implementation
guidance in Level III).
4. EL/NR integration between
DOE/NPS.
5. Encourage development of and
promote existing or new Centers
of Environmental Excellence.
1. Integrate all environmental
related initiatives throughout
organization (e.g. ELI, NRI,
energy, risk management, and
sustainability).
2. Develop Park Strategic
Environmental Management
Plans.
3. Establish internal management
review program and conduct
periodic evaluation (e.g. annual)
to ensure currency.
4. The Concessions Division should
develop "Level 3" guidelines that
outline operational requirements
for concessioners to comply with
federal, state, and local
regulations, and DOI and NPS
policy (at a minimum).
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CEMP Study of the National Park Service
Principle 3: Enabling Systems
Performance Objective: 3.3 Information Management, Communication, Documentation - The agency develops and implements systems that
encourage efficient management of environmentally-related information, communication, and documentation.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. HWPPT manages an
Environmental Information
Management System (MS/Access)
to track their environmental
project status. Parallels
FEDPLAN.
2. NEPA tracking database.
3. Green Alert bulletin board
system.
4. Sustainable design web site.
5. Regional web sites provide
information on sustainability and
NEPA.
6. Resident FTC environmental
information advisor (HWPPT).
7. Information management projects
are ranked for implementation as
are all other projects - based on
environmental criteria (HWPPT)
such as green products database.
8. Hard copy documents distributed
(manuals) as needed.
PMIS (interactive web-based)
likely to supersede EIMS but
maintain functionality.
NFS to use CERL Team Guide
for Federal and state
regulation updating for
Service-wide environmental
audit program. Will link with
NPS audit checksheets.
Developing audit reporting and
tracking system.
1. Web page offering EnviroFacts,
guidance documents, and other
environmental management
tools.
1. Develop integrated environmental
information strategy.
• Inventory critical information
needs.
• Identify universe of existing
information sources.
• Address information gaps by
priority.
1. Establish or rely upon a periodic
organization-wide update (e.g.
newsletter) to provide a reliable
communication mechanism for
routine, but important information.
2. Develop and implement guidance on
centralized filing and
recordkeeping system (region and
park-level).
3. The Concessions Division should
develop electronic (Internet) and
other systems to effectively transmit
environmental program information
and data to concessioners (e.g.
policy and procedures,
environmental audit data).
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CEMP Study of the National Park Service
Principle 4: Performance and Accountability
Performance Objective: 4.1 Responsibility, Authority, and Accountability - The agency ensures that personnel are assigned the necessary
authority, accountability, and responsibilities to address environmental performance, and that employee input is solicited.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Regional environmental
program coordinators identified
(hazmat/waste, CERCLA,
USTs, solid waste); no line
authority.
2. WASO and Regional
environmental audit
coordinators designated.
3. Park-level environmental
coordinators established in
parks (<15%).
4. Park superintendent and
regional directors maintain line
responsibility, authority, and
accountability for park or
region activities.
1. Accountability management
system for superintendents.
Best practice for environmental
leadership "meets or exceeds all
environmental laws..."
2. Environmental Leadership
training providing awareness of
management responsibility for
environmental compliance
programs.
1. Park-level environmental
coordinators/ points of contact at
all parks.
1. Assign responsibility and authority
to a specific individual to ensure
environmental compliance at park-
level.
2. Establish policy on environmental
accountability and include in
Environmental Policy (see 1.1).
3. Review performance in light of
environmental responsibility issues
(see 4.2).
4. Service-wide environmental
Coordinator position.
5. Empower environmental
coordinator position with authority
to resolve conflicting spheres of
authority and designate clear
responsibility where not established
(e.g. emergency response, water
pollution control).
6. Regional environmental coordinator
positions.
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CEMP Study of the National Park Service
Principle 4: Performance and Accountability
Performance Objective: 4.2 Performance Standards - The agency ensures that employee performance standards, efficiency ratings, or other
accountability measures, are clearly defined to include environmental issues as appropriate, and that exceptional performance is recognized
and rewarded.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. DOI and NFS award programs
for exceptional environmental
achievement.
2. In many cases environmental
program coordinator
performance goals are
established by supervisors
which do not have
environmental performance
responsibility or accountability.
3. Environmental performance
standards are not clearly
defined for many environmental
program personnel
(particularly park-level).
4. Environmental criteria are
incorporated into performance
standards for regional support
staff (0.5-2 FTE/ region), HQ
(6-8 FTE) as advisors but
infrequently at the park-level
as managers or environmental
protection specialists.
1. Procedures for the evaluation of
superintendent performance.
2. Incentives to encourage
development of Centers of
Environmental Excellence.
1. Develop environmental compliance
performance goals, then address
P2/sustainability. Use to develop
customized regional or park
standards.
2. Link individual environmental
compliance and management
performance standards with
organizational goals, then address
P2/sustainability.
3. Develop procedures for evaluation
of environmental compliance
performance, then address
P2/sustainability.
4. Develop procedures for rewarding
or penalizing responsible staff based
on environmental compliance
performance, then address
P2/sustainability.
5. Elevate visibility of environmental
achievement awards, particularly
with respect to other agencies, then
address P2/sustainability.
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Principle 4: Performance and Accountability (Continued)
Performance Objective: 4.2 Performance Standards - The agency ensures that employee performance standards, efficiency ratings, or other
accountability measures, are clearly defined to include environmental issues as appropriate, and that exceptional performance is recognized
and rewarded.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
6. Institutionalize environmental
program accountability by
specifying environmental
performance criteria in managerial
and employee performance
evaluations. Recognize importance
of environmental management in
staffing.
• Formalize concept of one lead
point-of-contact responsible for
environmental management at
each park.
• Formalize coordinated and
integrated HQ advisory and
management environmental
function.
• Make environmental management
experience a required KSA for
management.
7. Develop an environmental
recognition program for
concessioners.
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CEMP Study of the National Park Service
Principle 5: Measurement and Improvement
Performance Objective: 5.1 Evaluate Performance
Sub-Objective: 5.7.7 Gather and Analyze Data - The agency institutes a systematic program to periodically obtain information on
environmental operations and evaluate environmental performance against legal requirements and stated objectives, and develops
procedures to process the resulting information.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Regional activities:
• MWR, NER - Compliance
Assistance Projects.
• IMR - Pollution Prevention
Opportunity Assessments.
• SER - Contracted Audits.
• AR - RCRA Compliance
Audits conducted by state.
1. National environmental audit
program manager.
2. Regional and park
environmental staff
participating in audit program
development.
3. PHS park evaluation process
covers water and wastewater
treatment and food service.
1. National environmental audit
program with:
• Audit program guidance
document.
• Auditor training program.
• Audit criteria focusing on
compliance and screening for
P2 and sustainable practices.
• An information management
and reporting system.
• Unique audit protocol.
• Audit criteria for evaluating
park management support for
environmental program.
2. NER "green" audits.
3. PWR sustainability audits.
1. Develop corrective action
tracking and issue forecasting
system.
2. Audit data utilization plan to:
• Identify environmental program
needs (e.g. training, policy).
• Set priority to funding and
project decisions.
• Encourage and reward top
performance.
• Transfer solutions internally
(lessons learned).
1. System for updating audit
criteria.
2. System for addressing state and
local audit criteria.
1. Develop and implement a quality
assurance function to evaluate audit
program performance.
2. Include root cause analysis in audit
program criteria.
3. Create independent audit group.
4. Integrate audit information and
reporting (e.g. corrective actions)
with related systems (e.g. projects
and budget). Make sure audit
program data is used in project and
program decision-making.
5. Ensure that facility-level concession
operations are included in the
environmental auditing program
and that environmental
performance results are tied to
contract evaluation.
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CEMP Study of the National Park Service
Principle 5: Measurement and Improvement
Performance Objective: 5.1 Evaluate Performance
Sub-Objective: 5.1.2 Institute Benchmarking - The agency institutes a formal program to compare its environmental operations ~with other
organizations and management standards, where appropriate.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Some interest in benchmarking.
2. Some participation in EPA
Regional Environmental
Ron nd table.
1. Participate in benchmark studies
for appropriate sectors such as:
• Federal
• Resource Management
• Eco-Tourism
to learn about environmental
practices proven to be effective.
2. Explore establishing an EMS
protege relationship with a more
advanced organization such as
Forest Service.
3. Explore the possibility of mentoring
another organization:
• Federal: land management
• Resource Management: museums,
International World Heritage sites.
• Eco-Tourism: concessionaires,
recreation, tourism, hospitality
• Full participation in EPA
Roundtables
4. Consider benchmarking against
other DOI bureaus.
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CEMP Study of the National Park Service
Principle 5: Measurement and Improvement
Performance Objective: 5.2 Continuous Improvement - The agency implements an approach toward continuous environmental improvement
that includes preventive and corrective actions as well as searching out new opportunities for programmatic improvements.
EXISTING
UNDER DEVELOPMENT
PLANNED
RECOMMENDED NEXT
STEPS
1. Suggestions for environmental
program management
improvement are encouraged
generally and specifically
through:
• Annual regional environmental
coordinators meeting.
• Green Alert BBS.
• Informal networks (e.g.
sustainability taskgroups).
• PWR annual zone coordinators
meeting.
• Contaminants Technical
Advisory Group.
1. Operating environmental
management procedures are
evaluated as needed by region
(e.g. new staff) and at HQ (e.g.
new budgeting system).
2. Sustainability champions
actively seek to borrow lessons
learned from other organizations
(internationally).
Environmental audit program to
eventually address root cause of
current deficiencies and, through
information sharing, prevent
future occurrences.
Draft ELI training includes lessons
learned in key environmental
management issues.
1. Establish partnerships with "Best in
Class" organizations to jump start
ideas for improvement (See
potential mentors 5.1.2).
2. Formalize an environmental
management improvement
suggestion system. Include staff,
concessionaires, and visitors.
3. Explore the possibility of champions
from various initiatives (e.g.
sustainability); adopt and include
environmental compliance as part
of their mission.
4. Employ results of environmental
audit program to identify
opportunities for improvement and
assess effectiveness of corrective
actions.
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CEMP Study of the National Park Service
List of Acronyms
BLM - Bureau of Land Management PFMD - Park Facility Management Division
CAP — Compliance Assistance Project PMIS - Project Management Information System
CFA - Civilian Federal Agency PPOA - Pollution Prevention Opportunity Assessment
COE - Corps of Engineers PWR - Pacific West Region
DfE - Design for Environment RPP - Respiratory Protection Program
DoD - Department of Defense SER - Southeast Region
DOE - Department of Energy SOP - Standard Operating Procedure
DOI - Department of the Interior ST - Underground Storage Tank
EL - Environmental Leadership
EMR - Environmental Management Review
EMS - Environmental Management System
EPA - Environmental Protection Agency
EPP - Environmentally Preferable Products
EQD - Environmental Quality Division
FEMP - Federal Energy Management Program
GCNP - Grand Canyon National Park
GMP - General Management Plans
GPRA - Government Performance Results
HWMPP - Hazardous Waste Management and Pollution Prevention
1C - Incident Command
IMR - Inter-Mountain Region
ISWAP - Integrated Solid Waste Alternatives Program
IU - Indiana University
JMU - James Madison University
KSA - Knowledge, Skills and Abilities
MOU - Memorandum of Understanding
NEPA — National Environmental Policy Act
NER- Northeast Region
NFS - National Park Service Act
NREL - National Renewable Energy Laboratory
NR- Natural Resource
OEPC - Office of Environmental Policy and Compliance
OSHA - Occupational Safety and Health Administration
P2 - Pollution Prevention
PHS - Public Health Service
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