TSP Number 052-E-2100 Enforce applicable environmental protection laws and regulations

1. TSP Number 052-E-2100Enforce applicable environmental protection laws and regulations July 2008

2. Terminal Learning Objective • ACTION: Enforce applicable environmental protection laws and regulations. • CONDITION: As a small unit leader given a mission, environmental references and a unit environmental officer, with the responsibility to enforce compliance with applicable environmental legal requirements within the area of responsibility (AOR). • STANDARD: Enforce environmental legal requirements within the AOR by assistingSoldiers in identifying specific environmental duties during mission activities and reporting problems to the chain of command with appropriate COAs.

3. Safety, Risk andEnvironmental Concerns • Safety Requirements: None • Risk Assessment Level: Low • Environmental Considerations: Training entirely of an administrative nature, with little or no environmental impact

4. References • TM 38-410 Storage and Handling of Hazardous Material • FM 3-100.4 Environmental Considerations in Military Operations • TC 3-34.489 The Soldier and the Environment • FM 5-19 Composite Risk Management • AR 200-1 Environmental Protection & Enhancement • The Army Strategy for the Environment • 29 CFR Labor (Occupational Safety and Health Act) • 40 CFR Protection of the Environment • 49 CFR Transportation

5. Learning Objective #1 • Identify applicable environmental laws and regulations

6. Hierarchy of Laws & Regulations • Federal/DoD/Army • Host Nation • State • Local/Installation

7. Federal Laws • National Environmental Policy Act (NEPA-1969) • Resource Conservation Recovery Act (RCRA) • Clean Water Act • Clean Air Act • National Historic Preservation Act • Endangered Species Act • Noise Control Act

8. Federal Environmental Laws • National Environmental Protection Act –NEPA • Any federal action requires that the proponent conduct an analysis to see if there are impacts to the environment. • Often considered an “umbrella” law because it encompasses the other environmental laws. • Soldiers comply with the NEPA by- • By conducting Risk Assessments. • By following environmental SOPs, Laws and Regulations.

9. Federal Environmental Laws Resource Conservation and Recovery Act (RCRA) • Primary HW reference is 40 CFR 260-279 • RCRA regulates the generation, transportation, treatment, storage and disposal of solid and hazardous waste. • Massive and complex regulation • Known as the “Cradle to Grave” Act • Soldiers comply with the RCRA by- • Proper disposal of chemicals, solvents, and HW. • Accumulating HW in approved containers. • Reporting any spills of HW to their chain of command. • Proper bagging, storage and disposal of medical waste.

10. Federal EnvironmentalLaws Clean Water Act (CWA) Soldiers comply with the CWA by- • Disposal of chemicals, solvents, and HW properly. • Washing vehicles in approved wash racks only. • Cleaning up spills in the work area immediately. • Reporting spills to the chain of command.

11. Federal EnvironmentalLaws Clean Air Act (CAA) Soldiers comply with the CAA by- • Checking with range control before using gas or smoke. • Observing local fire and burning restrictions. • Keeping solvent vats closed when not in use. • Maintaining and operating equipment properly to minimize air pollution.

12. Federal EnvironmentalLaws  National Historic PreservationAct (NHPA) Soldiers comply with the NHPA by- • Reporting the discovery of artifacts and sites to the chain of command. • Reporting any damages to historical, cultural and archeological sites. • Leaving sites undisturbed. Don’t take “souvenirs”.

13. Federal EnvironmentalLaws Threatened/Endangered Species http://www.redlist.org  Endangered Species Act (ESA) Soldiers comply with the ESA by- • Recognizing signs and markers for protected areas. • Avoiding habitat areas during all operations. • Following installation regulations. • Obeying range control regulations for cutting brush and trees for camouflage. Greater Spotted Eagle

14. Federal Environmental Laws  Noise Control Act (NCA) Soldiers comply with the NCA by- • Avoiding creating unnecessary noise. • Respecting noise-buffer zones, minimum flight altitudes, no-fly zones, and nighttime curfews designated by the installation.

15. Host Nation Environmental Laws Comply with host nation and international environmental laws: • More or less stringent • Final Governing Standards (FGS) • Basel Convention Signatory • Status of Forces Agreement (SOFA)

16. State Environmental Laws • Comply with state environmental regulations. • Most States have Primacy • State laws can be more stringent than federal laws

17. LocalLaws • Comply with installation/local and unit environmental policies and SOPs. • Regional planning areas, counties, cities/town can have specific additional requirements. • Each installation has an environmental policy issued by the post commander (environmental Management System- eMS or Sustainability Program). • Every unit/organization should have an environmental SOP.

18. Installation environmental Management System (eMS) or Sustainability Program • Recycling/Salvage • Conservation • Waste Minimization • eMS or Sustainability Training • Alternative transportation • Alternative energy sources • Sustainability

19. Army Guidance • The Army environmental regulation. • AR 200-1 (13 Dec 2007)

20. Army Environmental Strategy“Sustain the Mission – Secure the Future” • Foster a Sustainable Ethic • Strengthen Army Operations • Meet Test, Training and Mission requirements • Minimize Impacts and Total Ownership Costs • Enhance Well-Being • Drive Innovation

21. Operational Guidance • Comply with Operations Orders (OPORDs), or Operations Plans (OPLANs) • Joint: Annex L • Army: Annex L • MACOM: FRAGO • Follow the Overseas Environmental Baseline Guidance Document (OEBGD) • Use FM 3-100.4 Environmental Considerations in Military Operations for practical guidance

22. Learning Objective #2 • Identify the responsibilities for managing a unit environmental program

23. -Comply with environmental legal requirements. • -Instill an environmental ethic • -Incorporate environmental responsibilities and risk management into unit SOPs/OPORDs • -Integrate environmental considerations into all unit operations • -Ensure personnel receive required environmental training • -Appoint and train environmental officers at appropriate organizational levels. • -Report noncompliance and spills • -Support installation eMS/Sustainabililty Program Army Regulation 200-1 Environmental Quality Environmental Protection and Enhancement Headquarters Department of the Army Washington, DC 13 Dec 2007 UNCLASSIFIED Army Environmental ProgramCommander’s Responsibilities

24. Environmental Officer • Appointment Orders • Training • Runs the Unit Environmental Program • Coordination in planning and risk assessments

25. Team Training • Ensure that key personnel/teams are trained • This training should include: • Spill prevention/response • Hazardous waste operations and emergency response • Personal Protective Equipment and first aid for exposure • Environmental compliance officer training • Specific environmental laws, regulations, and treaties • HM/HW handling, storage, transport • MSDS recognition and use • Field sanitation • Satellite Accumulation Points • Cultural, historic, religious sites; endangered species • Pollution Prevention

26. Personnel Requirements • Training for personnel -Handlers -Accumulation site managers -Packagers/Shippers -Spill or clean up teams • Some of this training will require update/ refresher training. • Certification must be kept on file. • Personal Protective Equipment (PPE) -Available for personnel -Training on PPE use and maintenance

27. Unit Environmental Program • An Environmental Officer/Alternate • Required references • Awareness Training • Unit SOP which includes an environmental section • Trained Environmental Teams • Spill Kits • Personal Protective Equipment • Unit Self Assessment • Environmental files and records

28. Environmental Training Sources • Installation Environmental Training Courses • Environmental Officer • Spill Team Training • Field Sanitation • Resident Training Courses • Army Logistics Management College, Fort Lee • Defense Logistics Agency, Fort Belvoir • Corps of Engineers Professional Development Center, Huntsville • Online Courses • Environmental Officer Course, MANSCEN Blackboard • Army e-Learning Skillsoft website • USAES-DEI website Product Catalog • Army Correspondence Course Program (ACCP). • TRADOC Critical Common Tasks (5 Environmental Tasks)

29. SPILL DRILL This is the basic SPILL DRILLbut every unit should have a tailored plan depending on the hazards found in the unit.

30. Learning Objective #3Unit Self Assessment • Demonstrate use of the Environmental Checklists in Appendix A, Table A-1 of TC 3-34.489 The Soldier and the Environment to conduct a unit self assessment.

31. Vehicle Maintenance • Maintain vehicles and equipment in accordance with (IAW) TM specifications • Clean up spills immediately • Collect used rags in a dirty rags container • Collect used dry-sweep compound for reuse • Recycle solvents and coolants • Return damaged parts and assemblies to the supply facility for rebuilding or recycling • Place drip pans, diapers, or absorbents under vehicles • Locate waste accumulation containers close to the source of the waste products • Label and date waste accumulation containers

32. Weapons Maintenance • Dispose of contaminated patches and cleaning equipment properly • Reuse cleaning equipment and lubricant containers when possible • Purchase lubricants in bulk, and refill smaller containers • Recycle cleaning solvents • Keep the lids on solvent vats closed when not in use

33. CBRN Maintenance • Keep a copy of the applicable MSDS for each HM on hand in a binder • Collect HM (used filters, decontamination materials, and cleaning solutions at the point of generation, and dispose of them properly • Mark and turn in damaged equipment • Reuse mask carriers and cleaning equipment • Store STB containers in separate locations that are dry and well ventilated • Dispose of HW and batteries according to the unit SOP • Turn in excess repair parts so that other units can use them • Dispose of out-of-date, chemical-agent kits properly as HW

34. Supply, Storage, Transportation • Substitute less hazardous solvents and cleaning solutions where permitted (use “green” cleaning supplies) • Select items that have less packaging to dispose of • Take leftover items (such as paint or excess parts) to the installation reissue center • Store materials according to MSDS guidelines • Keep a copy of the applicable MSDS for each HM on hand in a binder • Label and date new supplies • Place new supplies to the back of the storage area (First In – First Out) • Avoid stockpiling or keeping items around “just in case they are needed • Keep recycling containers free of trash and garbage • Turn in excess or damaged repair parts and tools as stated in the unit maintenance or supply SOP • Turn in excess paint, solvents, cleaners, and supplies to the installation supply point • Implement a shelf life watch program

35. Supply, Storage, Transportation (continued) • Purchase cleaning solvents and lubricants in bulk, and refill smaller containers as needed • Recycle materials as required by the installation recycling program • Reuse containers when possible • Dispose of solid waste and HW according to local policy • Purchase cleaning solvents and lubricants in bulk, and refill smaller containers as needed • Transport paint, solvents, cleaners, and other HW and HM safely as required by existing requirements. Ensure that there are proper placards and that appropriate spill-containment equipment is with the vehicle

36. Refueling Operations • Report spills immediately • Ensure that a properly stocked spill kit and PPE are readily available • Place the refueling nozzle in a drip pan, not on the ground • Place drip pans, diapers, or absorbent material (such as floor sweep) under vehicles when refueling • Place fuel cans in a drip pan for refueling or storage • Ensure that each refueling vehicle has at least two fire extinguishers • Ensure that potable water is available for emergency eye washing • Reuse overpack drums to transfer contaminated soil • Recycle used or contaminated POL products • Dispose of contaminated soil and absorbents according to installation policy

37. Field Sanitation/Mess • Enforce the use of field latrines instead of expedients such as “catholes” • Collect litter and solid waste at the source (mess site, aid station, or issue point) • Segregate the wastes • Store perishable items (such as food) properly to reduce spoilage • Reuse waste accumulation containers • Ensure that waste accumulation containers have lids that keep out weather and pests

38. Maneuver Damage Control • Identify environmental risks before going to the field as part of Composite Risk Management • Brief personnel on maneuver damage considerations and minimization measures • Develop a plan to minimize or eliminate environmental risks • Identify areas that contain threatened or endangered species • Observe convoy restrictions • Cross streams and ditches only at approved crossing points • Drive carefully in forested areas to avoid damaging vegetation • Drive only on approved road or trails • Avoid unnecessary noise by not revving engines • Use camouflage netting instead of live vegetation • Reuse wire, barrier materials, and sandbags • Recycle materials at collection points

39. Weapons/Demo Training • Check with range control for artillery noise-buffer zones near the installation • Check with airfield operations concerning no-fly zones • Adhere to nighttime-gunnery curfews • Keep demolitions below the maximum permissible weight specified by range control • Avoid excessive vehicle noise when homes are located near range roads • Use the forest and the terrain as buffers between noisy training and noise-sensitive areas • Aim firearms away from noise-sensitive areas • Avoid detonating large charges when the wind is blowing from the demolition grounds towards noise-sensitive sites or when temperature inversions are likely to be present • Avoid making noise in the habitat of endangered species • Respect noise-buffer zones and altitude restrictions in forest-service land or other areas of exceptional quiet • Police up all brass and packaging material

40. Wash Racks • Ensure the oil/water separator works properly. If it does not, report it. • Ensure trash is properly disposed of • Use only approved detergents • Ensure police of the wash rack area when unit is done washing.

41. Satellite Accumulation Point • Containers cannot be larger than 55 gallons or 1 quart for acute HW. • Containers are located near the HW point of origin. • Containers controlled by generator. • Containers must be clearly marked. • Containers must be dated once first drop of waste is put in the container. • Full containers must be turned in within 72 hours (includes non-business days).

42. Recycling Program • Ensure Soldiers know what gets recycled. • Ensure dumpsters are checked for violations. • Identify a unit recycling POC.

43. Solid Waste Program • Proper police of area of responsibility • Keep lids on dumpsters, trash receptacles • Don’t mix wastes • Police up brass/packaging at ranges. Ensure proper turn-in of brass.

44. Spill Prevention • Ensure the unit has a current Spill Plan. • Have an inventory of unit liquids and their location. • Know where PPE and Spill Kits are located. • Know who to notify in the event of spills.

45. Hazardous Material • Any material, including waste, that may pose an unreasonable risk to health, safety, property, or the environment

46. Common Hazardous Material • Alcohol • Antifreeze • Batteries • Paint • Solvent • Cleaning supplies • Fuel • Super Tropical Bleach • Field sanitation kits • Fuel antifreeze

47. General Rules for Managing HM • Use non-hazardous substitutes when possible. • Have an MSDS for every HM. • Do not mix different HM together. • Do not stockpile HM. • Consolidate storage of HM. • Inspect HM storage areas weekly. • Prevent spills. • Ensure availability of PPE. • Follow first in, first out rule. • Implement shelf life program. • Maintain an inventory list.

48. General Rules for Managing HM (continued) • Ensure labels are legible. • Ensure lids are tight, containers are marked, labeled and visible to the observer. • Provide secondary containment. • Store flammable and reactive materials in accordance with regulations away from the property line. • Secure containers.

49. Waste Determination There are three ways a waste can be regulated as hazardous: • Meets the definition of one or more of the hazardous waste characteristics. The four characteristics are ignitable, corrosive, reactive and toxic. • Is listed by EPA as a hazardous waste in 40 CFR 261. • Prior knowledge, e.g. testing

50. Expires By Law Discarded Unusable Mixtures Contamination HM Transformation to HW