SMDC/ARSTRAT ENVIRONMENTAL COMPLIANCE TRAINING Updated 24 February 2011
ENVIRONMENTAL COMPLIANCE Protecting the Environment is not Just a Good Idea It s the Law Numerous and Increasingly gystringent Local, State, Federal, Army and DoD Environmental Laws and Regulations have been Enacted in the Past 40 Years Penalties for Non-Compliance are Severe and can be Levied against both the Installation and those Tenants/Individuals Knowingly Involved The Army is Committed dto Maintaining i i Total lenvironmental Compliance 2
VEHICLE MAINTENANCE A Place Absorbents or Drip Pans Under Leaking Vehicles Clean-up Spills Immediately Collect used Rags in an Approved Dirty-Rags Container Recycle Solvents and Coolants Dispose of Batteries in Accordance with Installation SOPs 3
SUPPLY AND STORAGE Substitute less Hazardous Solvents and Cleaning Solutions when Possible Turn in Excess Paint, Solvents, and Cleaners to the Installation Supply Point Store Hazardous Materials According to Material Safety Data Sheets (MSDSs) and Installation SOPs Keep a Copy of the Applicable MSDSs for each Hazardous Material Label and Date all Supplies and use Older Supplies First to Prevent Exceedance of fshelf lflife Recycle Materials in Accordance with the Installation Recycling Program Ensure a Properly Stocked Spill Kit is Readily Available Order only the Quantity of Hazardous Material Necessary to Meet Specific Mission Requirements Use Hazardous ardo Material Storage Cabinets and Secondary Containment as Required by the Installation 4
REFUELING Report Spills Immediately Place Fuel Cans in a Drip Pan (Not on the Ground) When Refueling Recycle Used or Contaminated POL Products Dispose of Contaminated Soil and Absorbents According to Installation Policy 5
WASTE MANAGEMENT Dispose of Solid and Hazardous Waste According to Installation Policy Label all Waste According to Installation Policy Use Installation Approved Collection Containers Keep All Waste Containers Closed Except When Adding Waste Do Not Mix Wastes (e.g. Waste Oil and Antifreeze) Turn in Wastes in Accordance with Installation Policy (e.g. Quantity and Time Limits) All Personnel Generating Hazardous Waste MUST Receive Proper Training 6
GENERAL Do not Pour any Fluids in Floor Drains Except Water Participate in the Installation Environmental Quality Control Committee (EQCC) Meetings Turn in all Fluorescent Light Bulbs and Batteries to the Installation Conduct Periodic Environmental Awareness Training for all Personnel Ensure Environmental Compliance Duties are Assigned to Personnel within the Unit Post and Understand the Installation s Spill Reporting and Response Procedures Use Sinks for Hand Washing Only and Do Not Wash Parts in Sinks Wash Vehicles and Equipment only in Installation Approved Locations and with Approved Cleaners 7
GENERAL (cont d) Older Facilities may have Asbestos Containing Materials (ACM) such as Floor Tiles, Pipe Insulation, Roofing Materials, etc. Consult Installation prior to Taking an Action that may Disturb Asbestos Consult Installation prior to Operating Generators, Outdoor Painting, and Other Operations Impacting Air Quality Establish an Environmental POC with the Installation Conduct Periodic Inspections According to Installation SOPs 8
REFERENCES FM 3-34.5/MCRP 4-11B (Supersedes FM 3-100.4/MCRP 4-11B), Environmental Considerations in Military Operations, dated 16 February 2010 (https://armypubs.us.army.mil/doctrine/active_fm.html) AR 200-1, Environmental Protection and Enhancement, dated 13 December 2007 (www.apd.army.mil/pdffiles/r200_1.pdf) PAM 200-1, Environmental Protection and Enhancement, dated 17 January 2002 (www.apd.army.mil/pdffiles/p200_1.pdf) Installation Environmental Program Management Guide, dated 2002 (http://aec.army.mil/usaec/publications.html) / ti l) TC 3-34.489, The Solider and the Environment, dated 26 October 2001 (http://armypubs.army.mil/doctrine/tc_1.html) 9
Facility Inspection Over the next several slides we will make a virtual inspection of a facility that in some ways may be similar to yours. Look at the first slide of each pair to identify ygood practices and items that should be improved. After previewing the first slide in each pair, go to the second slide to review the good practices noted in green and the negative findings in red. Try to indentify as many as possible. 10
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Access Door Needs to be Closed (BMP) Proper Decal Posted 12
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Too Many Flammable Lockers Used Oil AST Uncovered??? Good Location for Spill Supplies 14
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No Universal Waste Sign Posted Used Batteries Require Out-of-Service Date Batteries not on Pallet Batteries Stored Outside 16
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Covered POL shed Good Location for Fire Extinguisher Batteries stored outside Excess fuel cans Batteries on pallet 18
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Covered POL shed ASTs Closed 20
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Covered POL shed No Smoking Sign ASTs Closed 22
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Covered POL shed No Smoking Sign ASTs Closed No Used Antifreeze Label Obsolete, Metal Fuel Cans Used Oil Label Faded 24
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Covered POL Shed AST Lid Open Open Container Oil Filters Leaking? Bad Location to Store Fuel Cans 26
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Excellent Storage of Batteries No Universal Waste Sign Posted 28
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Vehicle Leak Identified but not Repaired Drip Pan Moved, No Longer Under Leak, Damaged Pan Use of Drip Pan 30
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Inadequate Drip Pan (Paint Tray) Cigarette Butt (No Smoking Policy, Fire Hazard) Full of Water (Oily Water?) 32
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Leaking Vehicle Leak Identified During Weekly Facility Inspection? No Drip Pan Being Used 34
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Chronic Leaks Not Contained in Drip Pans Stained; Leak Fluids go Straight to Storm Drain 36
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Connex Being Used as HM Building. Is this an Installation approved storage method? No HM Inventory Posted No Secondary Containment Leaking Container? 38
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Connex Being Used as HM Building Rusted Containers Improper Stacking of Drums 40
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Good Location for Right-To- Know Center & MSDS Binder Spill Procedures Posted Overall Good Housekeeping Good Location for Spill Products Proper Storage Locker Signage Proper Storage of Cylinders 42
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Leaks Around Crusher Excellent Container Labeling 44
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Rusted, Damaged Container; Leaking? No Flammable Sign on HM Building Mount Fire Extinguisher Fuel Cans in Uncovered Fire Extinguisher Storage Area 46
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Flammable Decal Used Oil AST Uncovered Improper Storage of Cylinders 48
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Fire Extinguisher i Available Faded Decal, Missing Placard Excellent Container Labeling Good Location of Spill Supplies ASTs Uncovered 50
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Spill Procedures Posted Inside HM Building 52
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Cluttered, Can t Access Flammable Locker Excess HM Spill Procedures & HM Inventory Not Posted Poor Storage Area for Fuel Cans 54
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Neat Storage Inside Locker Proper Label Improper Label, AST Left Open Used Oil is not Combustible 56
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Half of Secondary Containment Pallets NOT Effective No Secondary Containment 58
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Excess HM, Old HM, Containers Rusting Cans Stacked Too High 60
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No Excess HM Neat HM Storage Area Unlabeled Container 62
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Excessive Container Deterioration 64
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Improper Label; Type Waste? 66
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Washrack Being Used as Equipment Storage Area 68
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Generator, Other Equipment Stored in Wash Rack Fuel Cans Being Stored in Wash Rack Spill Supplies Available Batteries Stored Directly Over Wash Rack Drain 70
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Fuel Cans & Supplies Stored in Wash Rack Open Container (Used Oil) HM Locker Stored in Wash Rack 72
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Generators & HM Stored in Wash Rack Leaking Container & Generator Stained Pad 74
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No Label, Contents? Leaking Container, Contaminating Soil 76
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Cylinders Chained Incompatible Storage of O2 & Acetylene Cylinders 78
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Spill not cleaned up immediately 80
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Evidence of a Spill Clean up Solid Waste Onsite Storage of Overpack Drum Containing??? 82
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CARC Paint left outside 84
Contact Information Call Leah Bishop, SMDC/ARSTRAT DCSEN if you have any questions at 256-955-2188 85