lead asbestos mgmt plan - ems manual

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PUEBLO CHEMICAL DEPOT LEAD MANAGEMENT PLAN

Prepared by

Pueblo Chemical Depot Environmental Management Office

December 2011

Prepared by: Keith L. Phillips

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TABLE OF CONTENTS Section Page TABLE OF CONTENTS ............................................................................................................................................ 1

DEFINITIONS 2

CHAPTER 4 12

WORK PERMIT SYSTEM ...................................................................................................................................... 12

5.2 CERTIFICATION TRAINING .......................................................................................................................... 13

SAFE WORK PRACTICES ..................................................................................................................................... 14

CHAPTER 7 15

WASTE DISPOSAL .................................................................................................................................................. 15

8.2 MEDICAL RECORDS .................................................................................................................................... 16 8.4 OPERATION AND MAINTENANCE RECORDS................................................................................................. 16 8.5 OTHER FORMS ............................................................................................................................................ 17

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DEFINITIONS

Abatement – A comprehensive process of permanently eliminating exposure or potential exposure to lead-based paint and lead dust through removal, replacement, encapsulation or enclosure.

Action Level - Employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30 micrograms per cubic meter of air (30 ug/m3) calculated as an 8-hour time-weighted average (TWA).

Encapsulation – Coating or sealing the lead-based paint with a durable coating that is applied as a liquid to the painted surface to prevent or control chalking or flaking.

Enclosure – Enclosing the painted surface with a durable substance such as drywall, paneling, metal, siding, plaster, or some other construction material to permanently seal the existing surface.

Hazardous Waste - For waste in lead abatement jobs, hazardous waste is any waste that contains more than 5 parts per million (ppm) leachable lead as determined by the Toxicity Characteristic Leaching Procedure TCLP test, or waste that is corrosive, ignitable or reactive and is not otherwise excluded from regulation

Lead – Includes metallic lead and all inorganic and organic compounds

Lead-Based Paint – 1). Paint already applied (in situ). Paint or other surface coatings that contain lead in excess of 1.0 milligram per square centimeter (mg/cm2) when using the X-ray Fluorescence Analyzer or 0.5% by weight (or 5,000 ppm) when using Atomic Absorption Spectroscopic analysis. 2). Paint in liquid form. Paint that contains more than 0.06% (600 ppm) lead by weight in the total non-volatile content of the liquid paint. (Consumer Product Safety Commission).

Lead Hazard – Any condition that causes exposure to lead that would result in adverse human health effects and that comes from a) lead-contaminated dust b) bare, lead-contaminated soil or c) lead-contaminated paint that is deteriorated or present on accessible, friction or impact surfaces that would result in adverse human health effects.

Lead-Contaminated Dust – Surface dust in residential dwellings that contains an area or mass concentration of lead in excess of a) Floor: >100 micrograms per square foot (ug/ft2), b) Window Sill: >500 ug/ft2, or c) Window Well: >800 ug/ft2

Removal – Separating the paint from the substrate and disposing of the removed paint.

Replacement – Removing both the paint and the substrate and disposing of both. The removed components are then replaced to complete the abatement.

Response Action – Any action taken to abate lead-based paint that has been damaged and presents a risk to occupants. Accomplishment of this action must be by EPA-certified abatement workers.

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ACRONYMS/ABBREVIATIONS

CDPHE Colorado Department of Public Health and Environment

CFR Code of Federal Regulations

CMA Chemical Materials Agency

CMA Competent Medical Authority

DA Department of the Army

D&D Demolition and Decontamination

DOT Department of Transportation

DPW Directorate of Public Works

DTC Document Tracking Center

EMO Environmental Management Office

EPA Environmental Protection Agency

FIR Facility Inspection Report

IH Industrial Hygienist

LBP Lead-Based Paint

LMP Lead Management Program

LPM Lead Program Manager

mg/cm2 milligrams per square centimeter

mg/L milligrams per liter

NEPA National Environmental Protection Act

NIOSH National Institute of Occupational Safety and Health

OSHA Occupational Safety and Health Administration

PAO Public Affairs Office

PCD Pueblo Chemical Depot

PEL Permissible Exposure Limit

PPE Personal Protective Equipment

ppm parts per million

RCRA Resource Conservation and Recovery Act

REC Record of Environmental Consideration

TCLP Toxicity Characteristic Leaching Procedure

TWA Time-weighted Average

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ug/ft2 micrograms per square foot

ug/m3 micrograms per cubic meter

USACE U.S. Army Corps of Engineers

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CHAPTER 1 INTRODUCTION

Lead is a common element that was used in the past as an additive to paint. It has also been used for the production of munitions and pipe conduits, as well as for many other applications. Approximately three-quarters of buildings, facilities, and housing constructed prior to 1978 contain some lead-based paint (LBP). Today the use of lead is limited due to associated health and environmental problems. At Pueblo Chemical Depot (PCD), lead is primarily found in interior and exterior paint applied to buildings and structures. In addition, lead is found at gun and artillery ranges where lead munitions were used.

Lead-based paint, if properly managed and maintained, poses little risk. If allowed to deteriorate, lead from paint can be a health hazard. LBP presents a hazard when it becomes airborne and/or finely divided. Inhalation is the primary exposure route for lead. Inhalation of dust and fumes and ingestion due to hand-to-mouth contact with lead-contaminated food, cigarettes, clothing, or other objects are the main routes of worker exposure to lead. Another concern is soil that surrounds homes and other buildings due to contamination from LBP that has chipped off over many years.

1.1 Goals The Lead Management Program (LMP) is designed to protect the health and safety of all persons who may come into contact with on-site lead and to comply with regulations set forth by the U.S. Army, U.S. Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and all appropriate state and local regulatory agencies.

The overall goals of the LMP are as follows:

• Identify lead hazards including LBP, firing ranges, and other lead contamination.

• Ensure the proper control and cleanup of any previously released lead contamination.

• Maintain existing LBP that is in good condition.

• Prevent exposure of personnel and the environment to harmful levels of lead from paint and other sources.

• Ensure compliance with applicable policies, rules, regulations and laws.

• Ensure that potentially exposed personnel are adequately trained. This LMP does not address in detail lead contamination in drinking water; such contamination is regulated under federal EPA guideline 40 Code of Federal Regulations (CFR) Part 141. The LMP will be updated as needed in order to incorporate changes in local, state, and Federal regulations, policies, and procedures.

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1.2 Regulatory Drivers Key regulations and Army policies that are pertinent to the Lead Management Program are summarized below:

1.2.1 Occupational Safety and Health Administration (OSHA)

• 29 CFR 1910.134. Respiratory Protection • 29 CFR 1910.1025. Lead (General Industry Standard for Lead)

Identifies a Permissible Exposure Limit (PEL) of 50 micrograms of lead per cubic meter of air (ug/m3) averaged over an 8 hour period and an action level of 30 ug/m3, time weighted average (TWA), based on an 8 hour work-day.

• 29 CFR 1910.1200. Hazard Communication. • 29 CFR 1926.20. General Safety and Health Provisions. • 29 CFR 1926.62. Lead (Construction Industry Standard for Lead).

Establishes the same exposure limits as the General Industry Standard.

1.2.2 Environmental Protection Agency (EPA)

• 40 CFR 261. Identification and Listing of Hazardous Waste • 40 CFR 262. Standards Applicable to Generators of Hazardous Waste • 40 CFR 263. Standards Applicable to Transporters of Hazardous Waste • 40 CFR 745. Lead-Based Paint Poisoning Prevention in Certain Residential Structures

1.2.3 Department of Transportation Regulations (DOT)

• 49 CFR 171-173. Transportation Requirements, Packaging, Labeling, Marking and Placarding

1.2.4 United States Department of the Army

• Army Regulation 200-1. Environmental Protection and Enhancement • Army Public Works Technical Bulletin 420-70-2. Installation Lead Hazard Management

1.2.5 State of Colorado

• Colorado Department of Public Health and Environment, Regulation No. 19, Lead-Based Paint Abatement

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CHAPTER 2 LEAD MANAGEMENT TEAM

The Lead Program Manager (LPM) oversees the LMP. Additional subject-matter experts who can provide assistance as necessary include the Safety Office, the CMA Legal Representative, the Training Office, the Directorate of Public Works (DPW), and the Public Affairs Office (PAO). The LPM will brief the Installation Commander on an as-needed basis.

2.1 Installation Commander The Installation Commander is responsible for the overall management of the Program. The Installation Commander will:

• Establish a LMP in support of the Department of the Army (DA), Chemical Materials Agency (CMA), EPA, Colorado Department of Public Health and Environment (CDPHE) and PCD lead management policies.

• Designate an LPM.

2.2 Lead Program Manager The LPM will perform the following activities:

• Ensure that the Lead Management Plan is available, by request, for inspection by employees, regulatory agencies, contractors and off-site neighbors.

• Ensure that all lead abatement activities comply with applicable EPA, OSHA, state, and local laws and regulations.

• Ensure that required notifications are submitted to the pertinent local, state, and Federal regulatory agencies.

• Maintain records pertaining to lead for 30 years after the removal of the last lead material or until facilities are permanently transferred to private use.

• Visit work sites when repair, maintenance, or lead removal operations are taking place in order to verify LMP requirements.

2.3 Environmental Management Office (EMO) EMO will perform the following activities:

• Ensure that the LMP is developed and maintained in compliance with Federal, state and local regulations.

• Execute the LMP in accordance with Installation Commander’s guidance.

• Program and budget for adequate resources to execute effective management programs.

• Update the LMP as necessary.

• Inform facility occupants of building inspections, response actions and post-response activities.

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• Provide technical oversight for contracted projects involving lead operations, maintenance and abatement.

• Ensure that lead-related activities and waste disposal are carried out in accordance with the provisions of all applicable state, local, and federal regulations.

• Coordinate abatement activities with subject matter experts as appropriate.

2.4 Risk Management Directorate (Safety Office) The Safety Office will:

• Assist in all safety matters related to lead management.

• Provide expertise in complying with lead safety-related Federal, state, and local requirements.

• Provide technical assistance on lead materials management and abatement projects.

• Receive and investigate employee/occupant complaints of unsafe working or living conditions.

• Coordinate abatement activities with subject matter experts as appropriate.

2.5 CMA Legal Representative The CMA Legal Representative will provide legal assistance on any liability or regulatory compliance issues related to lead or lead abatement projects.

2.6 Operations Division (Training Office) The Training Office will:

• Provide worker education/training for individuals identified as lead workers

• Program and budget adequate resources to accomplish lead training.

2.7 Directorate of Public Works (DPW)

• Determine whether lead material may be disturbed before beginning any maintenance, repair, or construction work.

• Budget for lead abatement contractor support services.

• Inform the Industrial Hygienist of any operations or situations that could expose depot employees, residents, or workers to lead concentrations above the action level.

• Ensure that all lead abatement activities comply with applicable EPA, OSHA, state, and local laws and regulations.

• Ensure that required notifications are submitted to the pertinent local, state, and Federal regulatory agencies.

• Budget for training, equipment, and personnel needed for those removal actions accomplished with government personnel.

• Maintain real estate records pertaining to rentals and leases in federal housing.

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• Ensure that lead abatement contractors receive a copy of the Lead Management Plan and that they are briefed by the Safety Office, Industrial Hygiene and EMO.

• Coordinate lead abatement or investigations with the LPM and subject matter experts as appropriate.

2.8 Lead Abatement Contractor

• Inspect proposed construction/maintenance project areas to analyze lead hazards and to ascertain the potential for disturbing LBP.

• Ensure projects are accomplished in a safe, efficient manner that complies with regulatory standards and protects workers and building occupants.

• Implement a contractor sponsored respiratory protection program.

• Inspect, on a daily basis, the work site and construction area.

• Ensure that employees use hygiene facilities, practice safe work practices and follow all required documentation procedures.

• Ensure that engineering controls are functioning properly.

• Supervise all required contractor employee exposure monitoring.

• Ensure that access to the project area by unauthorized personnel is controlled, warning signs are in place, and containment barriers are installed and functioning properly.

• Ensure all notifications are made in accordance with appropriate regulatory and plan requirements, and air-monitoring support is available prior to project initiation.

• Oversee the management of all bulk and air samples, provide all sample containers, and ensure all samples are analyzed by an approved laboratory.

• Ensure that personnel are properly identified, trained, equipped, and medically certified.

• Implement a medical surveillance program.

• Coordinate lead abatement or investigations with the LPM.

2.9 Public Affairs Office The Public Affairs Office will:

• Provide information to employees, residents (through the PCD Housing Coordinator), and contractors regarding on-going and planned lead abatement projects

• Provide information to the media, if necessary or appropriate.

2.10 PCD Housing Coordinator The PCD Housing Coordinator will ensure that residents receive information regarding LBP or abatement projects as required in 24 CFR Part 35 and 40 CFR Part 745.

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2.11 Preventive Medicine The Industrial Hygienist (IH) and Competent Medical Authority (CMA) responsibilities are:

• To advise on selection of personal protective equipment for abatement projects and to provide technical assistance.

• To provide medical surveillance and maintain records, as outlined by OSHA and the National Institute of Occupational Safety and Health (NIOSH), to eligible federal or DA civilian employees subject to occupational lead exposure.

• To review sampling results that document exposure or potential exposure to Depot employees.

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CHAPTER 3 NOTIFICATION AND LABELING

The final rule, “Lead; Requirements for Disclosure of Known Lead-Based Paint and/or Lead-Based Paint Hazards in Housing,” (61 FR 9604-9088) requires that persons leasing federally-owned residential housing built prior to 1978 receive a lead hazard information pamphlet. Housing residents must be notified of known LBP and/or lead hazards in accordance with 24 CFR Part 35, 40 CFR Part 745 and AR 420-70.

PCD, when renting or leasing property, must take the following actions:

• Disclose all known lead-based paint hazards, lead material hazards and any available reports on lead to the housing occupants.

• Give renters the EPA pamphlet “Protect Your Family From Lead in Your Home.”

• Include certain warning language in the lease and get signed statements from all parties verifying that all requirements were completed.

• Retain signed acknowledgement for 3 years, as proof of compliance.

PCD will post warning signs in each work area where the PEL is exceeded in accordance with 29 CFR 1910.1025 (m)(2)(i).

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CHAPTER 4 WORK PERMIT SYSTEM

Project planning at PCD will take lead materials management into account. As part of the planning process for Demolition and Decontamination (D&D) projects, PCD will complete a Facility Inspection Report (FIR) to document environmental issues, including lead materials locations. The FIR will be used to plan for lead mitigation.

The Environmental Checklist for Work Orders and Contract Proposals is used to identify projects or actions that require additional environmental analysis or documentation. The checklist identifies lead issues. An environmental impact analysis for lead hazard control and LBP activities will be prepared in order to satisfy the requirements of the National Environmental Protection Act (NEPA). This analysis will be prepared by the proponent and approved by EMO in the form of a Record of Environmental Consideration (REC) or other appropriate NEPA document.

If disturbance of lead is intended or likely, a lead abatement plan will be developed by personnel with EPA-certified lead training. A licensed and qualified contractor will be engaged to perform the abatement. DPW will write the statements of work and contracts for all lead abatement projects.

Contractors are responsible for making appropriate state and Federal notifications for any lead-related demolition, renovation, or abatement work. If work is done by PCD personnel, DPW will make the appropriate notifications before work is started.

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CHAPTER 5 EDUCATION AND TRAINING

Contractors are responsible for providing properly trained workers for PCD projects. Certificates, as proof of training, are required for project records.

5.1 Awareness Training Workers who may be exposed to lead at or above the lead action level, or for whom the possibility of skin or eye irritation exists, are required to complete OSHA Lead Awareness Training. This class consists of an initial 1-hour training program and an annual refresher (29 CFR 1926.62 and 29 CFR 1910.1025). The training program should include the following:

• The physical characteristics of lead.

• Methods of identifying known and suspect LBP in buildings and an overview of known locations of known and suspect LBP.

• Health effects associated with lead exposure.

• Overview of the LMP.

• Types of operations that would result in exposure to lead and methods of minimizing exposure including engineering controls, work practices, and personal protective equipment (PPE).

• The purpose, proper selection, fitting, use and limitations of respirators.

• The purpose and description of the medical surveillance program and the medical removal protection program.

5.2 Certification Training Lead workers may participate in advanced training commensurate with assigned responsibilities. The following courses, presented by CDPHE- accredited training providers,

• Lead Inspector

• Lead Risk Assessor

• Lead Project Designer

• Supervisor of Lead Abatement Projects

• Lead Abatement Worker Annual refresher courses are required to maintain certification for all levels of training.

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CHAPTER 6 SAFE WORK PRACTICES

Mechanical disturbance of lead should be avoided. Activities such as cutting, drilling, grinding, sanding, or hammering may cause significant damage that could lead to airborne releases. Application of excessive heat to lead-containing materials can also be a major source of lead exposure. If removal is necessary, a consultant should be contacted to develop a lead abatement plan in conjunction with the Lead Program Manager. A licensed and qualified contractor will perform the abatement.

Do not kneel on contaminated ground, stir up unnecessary dust, or perform any practice that increases the probability of hand-to-mouth transfer of contaminated materials. Eating, drinking, chewing gum, smoking, or using smokeless tobacco is forbidden while collecting samples or working with lead.

The PCD Respiratory Protection Program (PCD-R 40-20) covers all types of respiratory protection, including lead, if needed.

All contract employees who are engaged in lead abatement and related activities will be governed by their company policies and procedures regarding respirator usage. PCD is not responsible for activities such as fit testing, inspection, and maintenance of contract employees’ respirators.

Before any lead-related activities take place by contract employees at PCD, the contractor will provide a copy of their respirator program and all pertinent information to the PCD Safety Office for review.

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CHAPTER 7 WASTE DISPOSAL

The volume of lead waste will be minimized. Lead waste is considered a hazardous waste under the Resource Conservation and Recovery Act (RCRA) when it contains a lead content greater than 5 milligrams per liter (mg/L)as measured by the Toxicity Characteristic Leaching Procedure (TCLP) (40 CFR Part 261.24).

All hazardous lead waste will be handled, stored, transported, and disposed in a manner that complies with 40 CFR Parts 260-265 and 268. The abatement contractor will be responsible for transporting waste off-site. Storage, transportation, and disposal of hazardous lead waste will be coordinated with the EMO. All DOT requirements for hazardous materials will be followed (49 CFR 172, 173, 178 and 179).

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CHAPTER 8 RECORD KEEPING

The LPM and the DPW will maintain copies of all forms and documentation involving lead through the Document Tracking Center (DTC). The following documents are part of the LMP and will be retained at Pueblo Chemical Depot.

8.1 Shipping Manifests A receipted copy of the “Waste Origin-Waste Disposal” form for the shipment of hazardous lead waste will be maintained, along with other disposal paperwork, by EMO for a period of 2 years. EMO will furnish upon request, and make available for inspection, all records required under 40 CFR 61.150.

8.2 Medical Records Medical exam records will be kept on file for eligible federal or DA civilian employees who are either engaged in lead work or who may have been exposed to lead in excess of the PEL for lead of 50 (50 ug/m3) averaged over an 8-hour work-day. The Competent Medical Authority (CMA) must keep all records of exposure monitoring for airborne lead. These records must include the name and job classification of employees measured, details of the sampling and analytic techniques, the results of this sampling, and the type of respiratory protection being worn by the person sampled. Competent Medical Authority CMA is also required to keep all records of biological monitoring and medical examination results. These must include the names of the employees, the physician's written opinion, and a copy of the results of the examination. All of the above kinds of records must be kept for 40 years, or for at least 20 years after termination of employment, whichever is longer (29 CFR 1910.1025 and 29 CFR 1926.62).

8.3 Training Records For each person requiring training, the Training Office will keep on file the person’s name, job title, date training was completed, type of training, location of the training, and number of hours completed. Training records must be maintained for the duration of employment plus 1 year.

8.4 Operation and Maintenance Records D&D project files are maintained with contract documents by DPW. These files may contain start and completion dates of the work, names and addresses of all contractors involved and their state/EPA accreditation numbers. If lead-containing material is shipped off-site, hazardous waste manifests will be maintained by the EMO.

Building and facility owners shall maintain records of all information concerning the presence, location and quantity of LBP. Such records shall be kept for the duration of ownership and shall be transferred to successive owners. All records should be recorded in the DTC.

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8.5 Other Forms The LPM will maintain records of lead incidents that are not related to contracted Public Works projects. The DPW will maintain records of lead abatement done in conjunction with building, demolition and other contract projects.

Records should be made available upon request to appropriate OSHA representatives in accordance with applicable Federal, state, or local laws. Sampling results and medical records should be made available to appropriate affected employees, former employees, and designated representatives in accordance with Federal, state, or local laws.

Due to potential liability issues and concerns associated with lead, all employee records will be kept on file for the duration of employment plus 30 years.

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U.S. ARMY CHEMICAL MATERIALS AGENCY PUEBLO CHEMICAL DEPOT LEAD MANAGEMENT PLAN

December 2011

Approval Page

Prepared by: Keith L Phillips Date Environmental Engineer, EMO Reviewed by: Date Director, Environmental Management Office Concurrences: Date Safety Officer Date Director, Risk Management Directorate Date Director, Public Works ______________________________________________________ _________________ Date Industrial Hygienist

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______________________________________________________ ________________ Date Chief, Fire Department _____________________________________________________ ________________ Date Competent Medical Authority

APPROVED:

_____________________________________________________ _______________ Date Commanding

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PUEBLO CHEMICAL DEPOT ASBESTOS MANAGEMENT PLAN

Prepared by

Pueblo Chemical Depot Environmental Management Office

December 2011

Prepared by: Keith L. Phillips

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DEPARTMENT OF THE ARMY PUEBLO CHEMICAL DEPOT

45825 HIGHWAY 96 EAST PUEBLO CO

PCD ASBESTOS MANAGEMENT PLAN December 2011

TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................................................ 1

LIST OF TABLES ....................................................................................................................................................... 2

LIST OF FIGURES ..................................................................................................................................................... 2

APPENDIX .................................................................................................................................................................. 2

CHAPTER 1 INTRODUCTION ................................................................................................................................ 3

1.1 PURPOSE .......................................................................................................................... 3 1.2 OVERVIEW ...................................................................................................................... 3 1.3 GOALS .............................................................................................................................. 3 1.4 REGULATORY DRIVERS .............................................................................................. 4

CHAPTER 2 ASBESTOS MANAGEMENT TEAM ............................................................................................... 6

2.1 INSTALLATION COMMANDER ....................................................................................... 6 2.2 ASBESTOS PROGRAM MANAGER ................................................................................. 6 2.3 ENVIRONMENTAL MANAGEMENT OFFICE (EMO) .................................................... 7 2.4 PREVENTIVE MEDICINE .................................................................................................. 7 2.5 PUBLIC AFFAIRS OFFICE (PAO) ..................................................................................... 7 2.6 CMA1 LEGAL REPRESENTATIVE ................................................................................... 8 2.7 RISK MANAGEMENT DIRECTORATE (RMD) ............................................................... 8 RMCD IS RESPONSIBLE FOR THE FOLLOWING: .............................................................. 8 2.9 TRAINING OFFICE ............................................................................................................. 8 2.10 CONTRACTOR .................................................................................................................. 9

CHAPTER 3 IDENTIFICATION OF ACM ........................................................................................................... 12

3.1 PURPOSE ............................................................................................................................ 12 3.2 RENOVATION AND NEW FACILITY CERTIFICATION ............................................. 12 3.3 ABATEMENT ALTERNATIVES ...................................................................................... 12

CHAPTER 4 BUILDING OCCUPANT NOTIFICATION ................................................................................... 13

4.1 SCOPE ................................................................................................................................. 13 4.2 POSTINGS .......................................................................................................................... 13

CHAPTER 6 ............................................................................................................................................................... 14

CHAPTER 5 WORK CONTROL SYSTEM .......................................................................................................... 15

CHAPTER 6 TRAINING ......................................................................................................................................... 16

6.1 ASBESTOS AWARENESS TRAINING ............................................................................ 16 6.2 ADVANCED ASBESTOS TRAINING .............................................................................. 16

CHAPTER 7 RESPIRATORY PROTECTION PROGRAM ............................................................................... 17

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7.1 PURPOSE ............................................................................................................................ 17 7.2 PUEBLO CHEMICAL DEPOT RESPIRATOR PROGRAM ............................................ 17 7.3 CONTRACTOR RESPIRATOR PROGRAM .................................................................... 17 8.1 SURVEILLANCE ............................................................................................................... 18 8.2 AIR QUALITY MONITORING ......................................................................................... 18

CHAPTER 9 CLEANING AND MAINTENANCE ............................................................................................... 19

9.1 INITIAL CLEANING ......................................................................................................... 19 9.2 RECLEANING .................................................................................................................... 19 9.3 KEY POINTS OF ACM MAINTENANCE ........................................................................ 19

CHAPTER 10 EMERGENCY PROCEDURES ..................................................................................................... 20

CHAPTER 11 WASTE DISPOSAL ........................................................................................................................ 21

CHAPTER 12 RECORD KEEPING ....................................................................................................................... 22

12.1 SHIPPING MANIFESTS .................................................................................................. 22 12.2 MEDICAL RECORDS ...................................................................................................... 22 12.3 TRAINING RECORDS ..................................................................................................... 22 12.4 OPERATIONS AND MAINTENANCE RECORDS ....................................................... 22 12.5 OTHER FORMS ................................................................................................................ 22

APPENDIX A ............................................................................................................................................................. 24

DEFINITIONS/ACRONYMS AND ABBREVIATIONS ...................................................................................... 24

ACRONYMS/ABBREVIATIONS ........................................................................................................................... 25

LIST OF TABLES

2-1 Asbestos Management Team Members ...........................................................................11

LIST OF FIGURES

4.1 Asbestos Warning Sign ...................................................................................................14

4.2 Asbestos Warning Label...................................................................................................14

APPENDIX

A Definitions/Acronyms and Abbreviations ........................................................................24

B PCD Building Demolition List .........................................................................................22

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CHAPTER 1

INTRODUCTION

1.1 Purpose This plan provides policies and procedures for maintaining the Asbestos Program for Pueblo Chemical Depot (PCD) and outlines specific organizational responsibilities. This plan is applicable to all military and civilian personnel assigned to the depot, as well as all contractors and visitors.

1.2 Overview Asbestos containing materials (ACM) were once widely used in the construction industry. While the use of ACM in new building systems has ceased for most major applications, the presence of ACM in older buildings is widespread. At PCD, ACM is present in older buildings in the form of pipe insulation, sprayed-on fire proofing, acoustic insulation and transite flooring and walls. In most cases, ACM does not pose a health hazard if left undisturbed. Nevertheless, activities that have the potential to disturb ACM must be carefully managed to prevent fibers from becoming airborne and creating an inhalation hazard.

Department of Defense (DOD) policy with regard to ACM is to manage ACM in a manner protective of human health and the environment, and to comply with all applicable Federal, State and local laws and regulations governing ACM hazards. Therefore, unless it is determined by competent authority that the ACM in the property does pose a threat to human health at the time of transfer, all property containing ACM will be conveyed, leased or otherwise disposed as is.

1.3 Goals The PCD Asbestos Management Program is designed to protect the health and safety of all persons who may come into contact with on-site ACM and to comply with regulations set forth by the U.S. Army, the U.S. Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and all appropriate state and local regulatory agencies.

The overall goals of the PCD Asbestos Program are as follows:

• Identify/locate all ACM not already listed on the Asbestos Survey Report (Pickering Report) dated November 6, 1992.

• Maintain existing ACM that is in good condition.

• Remove significantly damaged ACM.

• Ensure the proper cleanup of any previously released asbestos fibers.

• Prevent the further release of fibers.

• Monitor, over time, the condition of ACM.

• Prevent personnel exposure to harmful asbestos levels

• Ensure compliance with applicable policies, rules, regulations and laws

• Ensure asbestos workers and other potentially exposed employees are adequately trained

1.4 Regulatory Drivers Key regulations and Army policies that are pertinent to the Asbestos Management Plan are summarized below:

1.4.1 Occupational Safety and Health Administration (OSHA) 29 CFR 1926.1101 Construction Standards for Asbestos Applies to individuals involved in construction, renovation, and demolition activities, establishes a Permissible Exposure Limit (PEL) of 0.1 fibers per cubic centimeter of air (f/cc) as an eight-hour time-weighted average (TWA) and an Excursion Level of 1.0 f/cc as averaged over a sampling period of 30 minutes.

Dictates engineering controls and personal protective equipment requirements for individuals involved with asbestos related work and establishes requirements for medical surveillance and recordkeeping.

29 CFR 1910.1001 General Industry Standards for Asbestos Establishes the same PEL and Excursion Limit as outlined in 29 CFR 1926.1101 (Construction Standard). Scope applies to all occupational exposures to asbestos not specified in the Construction Standard.

1.4.2 ENVIRONMENTAL Protection Agency (EPA) 40 CFR 61, Subpart M, National Emission Standard for Hazardous Air Pollutants (NESHAP) Establishes standards for renovation or demolition activities which will impact a combined quantity of asbestos containing material in excess of 260 linear feet, 160 square feet or 35 cubic feet. Standards address notification requirements, work practices, and waste disposal requirements.

40 CFR 763, Subpart G, Worker Protection Rule This regulation applies the OSHA standards to government employees who are not covered by the OSHA Asbestos Standards. This regulation considers the handling and removal of ACM in schools and public buildings.

1.4.3 DEPARTMENT of Transportation Regulations (DOT) 49 CFR 173.216 This regulation establishes labeling, packaging, and transportation requirements for asbestos containing materials.

1.4.4 UNITED States Army (USA) AR 200-1, Chapter 9, Environmental Protection and Enhancement (Asbestos Management) (December 13, 2007) Requires Army installations, activities, and tenants to comply with all legally applicable and appropriate Federal, state, and local laws and regulations. Excludes asbestos from all procurements and uses where asbestos-free substitute materials exist. Establishes and executes Asbestos Management Plans (AMPs). Establishes Asbestos Management Teams (AMTs).

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Program and budget resources to identify, manage, and control exposure to asbestos. Conducts periodic installation surveys to identify the existence, extent, and condition of all asbestos. Conducts asbestos surveys in all housing units and in those buildings that will be renovated, demolished, or transferred from Army use.

AR 420-70 Establishes facility policy for management of hazardous building materials in a manner that is protective of human health and the environment.

Public Works Technical Bulletin 420-70-8 Provides technical information on asbestos management.

1.4.5 State of Colorado Regulation No. 8, The Control of Hazardous Air Pollutants, Part B, The Control of Asbestos (Section V.A) (2008) Establishes accreditation, certification, and training requirements for asbestos contractors, workers, supervisors, inspectors, management planners, and project designers working in public and commercial buildings in the State of Colorado. Establishes permit and notification requirements for asbestos abatement projects.

1.4.6 Environmental Protection Agency (EPA) 40 CFR Part 60, Appendix A METHOD 22 - Visual Determination Of Fugitive Emissions From Material Handling Sources (July 1, 1991). Establishes visual observation of fugitive emissions produced during material processing, handling, and transfer operations where asbestos may be involved. Chapter 2

CHAPTER 2 ASBESTOS MANAGEMENT TEAM

The Asbestos Management Team (AMT) is comprised of the following appointed individuals:

• Chief, Environmental Management Office (EMO)

• Directorate of Public Works (DPW)

• Directorate Risk Management

• Industrial Hygienist

• Competent Medical Authority (CMA2)

• Environmental Protection Specialist The Installation Commander will delegate responsibility to an Asbestos Program Manager (APM). The Public Affairs Office (PAO), the EMO, the Safety Office, Directorate of Public Works, Industrial Hygienist, and the PCD Legal Representative will serve as additional subject matter experts as necessary. The AMT will brief the Installation Commander on an as-needed basis.

2.1 Installation Commander The Installation Commander is responsible for the overall management of the Program. The Installation Commander will:

• Establish and execute an Asbestos Program in support of the Department of the Army (DA), Army Materiel Command (AMC), and Chemical Materials Agency (CMA1) asbestos management policies.

• Program and budget for adequate resources to execute effective management programs.

• Appoint a staff member as Asbestos Program Manager.

2.2 Asbestos Program Manager The Asbestos Program Manager shall perform the following activities:

• Ensure that the Asbestos Program is available for inspection by employees, regulatory agencies, effected employees and off-site neighbors.

• Ensure that all ACM abatement complies with applicable EPA, OSHA, state, and local laws and regulations.

• Support coordination of PCD’s efforts with parties who may be involved in ACM management, e.g. ensure necessary permits are acquired. Ensure regulatory agencies are notified of planned asbestos abatement activities.

• Support the investigation of source(s) of debris found by the custodial or maintenance staff.

• Maintain records of all known ACM remaining within structures and all work related to ACM.

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• Maintain a system to retain all records pertaining to ACM for 30 years after the removal of the last ACM or until facilities are turned over for private use.

• Visit the work site when ACM repair, maintenance, or removal is initiated and periodically thereafter to verify performance according to the requirements of this Asbestos Program.

• Inform the Industrial Hygienist of any operations or situations that could expose Depot employees or residents to asbestos concentrations above the action level.

2.3 Environmental Management Office (EMO) The Environmental Management Office shall perform the following activities:

• Ensure that an Asbestos Program has been developed and is maintained. Update this program when conditions at PCD change.

• Ensure ACM survey results, plans, and records are recorded in the document tracking center.

• Provide technical oversight for activities involving asbestos operations, maintenance, abatement, and disposal.

• Ensure that the activities of any person who performs asbestos related work, or who develops and implements response actions (including this program) are carried out in accordance with the provisions of all applicable state, local, and federal regulations.

• Coordinate abatement activities with the National Environmental Protection Act (NEPA) Coordinator as appropriate.

2.4 Preventive Medicine The IH and Competent Medical Authority (CMA2) responsibilities are:

• To advise on selection of personal protective equipment for abatement projects and provides technical assistance.

• To receive and investigate asbestos related employee/occupant complaints of unsafe working or living conditions. Provide appropriate asbestos surveillance examinations for eligible federal or DA civilians in accordance with DA, OSHA, and consensus standards.

• Sampling results that document exposure or potential exposure to Depot employees must be reviewed by the Depot Industrial Hygienist. The IH will make the appropriate documentation of such sampling results.

2.5 Public Affairs Office (PAO) The Public Affairs Office is responsible for:

• Informing personnel, including contractors and lessees, about asbestos abatement projects. Notification of affected personnel must be done well in advance of the commencement of asbestos abatement projects.

2.6 CMA1 Legal Representative The CMA1 Legal Representative will be consulted on any liability or regulatory compliance issues relating to asbestos abatement projects.

2.7 Risk Management Directorate (RMD) RMCD is responsible for the following:

• Inform the CMA2 and IH of any operation that could expose employees to asbestos above the action level.

• Assist in all safety matters related to asbestos management.

• Provide expertise in complying with asbestos safety-related federal, state, and local requirements. Receive and investigate asbestos related employee/occupant complaints of unsafe working or living conditions.

2.8 Directorate of Public Works (DPW) is responsible for the following:

• Inform facility occupants of building inspections, response actions, and post-response activities including periodic surveillance and activities that are planned or are in progress.

• Investigate source(s) of debris found by the custodial or maintenance staff.

• Budgeting for asbestos abatement contractor support services.

• Ensure that all contractors and building maintenance workers who may come in contact with friable ACM are informed of the Asbestos Program.

• Ensure that asbestos abatement contractors receive a copy of the Asbestos Management Plan and are briefed by Safety, Industrial Hygiene, and Environmental.

• Ensure contractors/agencies inform EMO of projects for coordination and compliance.

• Supply EMO with records of ACM activities and update these records as changes occur.

• Ensure that EPA is notified when more than 160 linear feet, or 260 square feet, or 35 cubic feet of ACM will be disturbed as a result of renovation or demolition.

• Coordinate PCD’s efforts with parties who may be involved in ACM management, e.g., obtain necessary permits. Inform regulatory agencies of planned asbestos abatement activities.

• Inform the Industrial Hygienist of any operations or situations that could expose PCD employees or residents to asbestos concentrations above the action level.

2.9 Training Office The Training Office is responsible for:

• Programming, budgeting adequate resources, and maintaining records for asbestos training.

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2.10 Contractor

2.10.1 Responsibilities Contractors perform most asbestos-related activities at PCD. The contractor will ensure that a competent person is designated as an Asbestos Control Team Supervisor for each ACM maintenance project. This person will:

• Adhere to the provisions of 29 CFR 1926.1101.

• Inspect proposed construction/maintenance project areas as necessary to ascertain the potential for disturbing ACM.

• Supervise the performance of asbestos-related operations and maintenance activities to ensure projects are accomplished in a safe, efficient manner that complies with regulatory standards and protects workers and building occupants.

• Implement the contract company sponsored respiratory protection program.

• Inspect, on a daily basis, the work site and construction area.

• Ensure that employees use the hygiene facilities and observe the required documentation procedures.

• Ensure that engineering controls are functioning properly.

• Supervise all required contractor employee exposure monitoring.

• Ensure that access to the project area by unauthorized personnel is controlled, warning signs are in place, and containment barriers are installed and functioning properly.

• Ensure that employees maintain and utilize personal protective equipment in accordance with appropriate regulatory and program requirements during all asbestos related actions.

• Ensure all notifications are made in accordance with appropriate regulatory and plan requirements, and air-monitoring support is available prior to the initiation of asbestos projects.

• Oversee the management of any sampling activity, provide sample containers and ensure all samples are analyzed by an approved laboratory.

• Ensure that assigned personnel are properly identified, trained, equipped, and medically certified.

• Implement a medical surveillance program.

2.10.2 Exceptions

• Unless all employees are equipped with supplied air respirators, the contractor must conduct daily monitoring that is representative of the exposure of each employee working within a regulated area.

• If statistically reliable measurements from daily monitoring within the regulated area indicate that employee exposure is below the action level, no further monitoring of these employees is required.

• Exceptions must be approved by the Environmental Management and Safety Offices.

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TABLE 2-1 ASBESTOS MANAGEMENT TEAM

Appointed Members

Chief, Environmental Management Office 549-4201

Directorate, Public Works 549-4145

Directorate Fire and Emergency Services 549-4688

Directorate, Risk Management 549-4982

Industrial Hygienist 549-4186

Competent Medical Authority 549-4176

Environmental Protection Specialist 549-4201

Other Members

Asbestos Program Manager 549-4201

Public Affairs Officer 549-4135

Safety Representative 549-4533

CMA1 Legal Representative (410) 436-4652

CHAPTER 3 IDENTIFICATION OF ACM

3.1 Purpose The identification and documentation of ACM at Pueblo Chemical Depot facilities is critical to gaining a comprehensive understanding of the scope and magnitude of the ACM issue. This function includes ensuring that new structures and renovations to existing structures do not use or introduce more ACM at PCD.

The primary document used to identify asbestos at PCD is the asbestos survey contained in the Pickering Report. For each project, the Pickering report information is verified prior to beginning work. Verification consists of site visits and inspections by certified asbestos inspectors. Records of inspections are maintained with project/contract documents. When ACM is located that is not identified in the Pickering Report, an addendum will be added to the Pickering Report and filed for future information.

Demolition projects are the major source of ACM disturbance at PCD. A list of potential Demolition and Decontamination (D&D) locations is included in Appendix B of this document.

3.2 Renovation and New Facility Certification Design personnel will ensure that the Scope of Work for all construction projects includes a requirement that an architect or project engineer responsible for the construction will sign a statement that no ACM was specified as a building material in any construction document for the building or, to the best of his or her knowledge, no ACM was used as a building material in the building.

3.3 Abatement Alternatives Asbestos abatement is defined as any activity that reduces the risk of exposure to airborne asbestos fibers. Abatement alternatives will only be selected by a qualified asbestos abatement contractor in consultation with PCD personnel and the Asbestos Management Team.

The presence of ACM does not, in itself, create a condition that requires removal. Alternatives to removal are repair, encapsulation, enclosure and Operations and Maintenance (O&M). Each alternative requires an O&M Program to regularly monitor the condition of the asbestos.

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CHAPTER 4

BUILDING OCCUPANT NOTIFICATION

4.1 Scope OSHA requires building owners to notify all employees, contractors, tenants, and prospective contractors who work within or adjacent to areas containing ACM of the presence, location, and quantities of ACM. This notification to employees includes the following actions by PCD:

• An area that may have airborne asbestos fiber levels exceeding the permissible exposure limit (PEL), as defined by OSHA, is identified with an asbestos warning sign (29 CFR 1926.1011.k.7). The PEL is currently set at 0.1 fibers per cubic centimeter (f/cc) TWA or an excursion level (30 minutes) of 1.0 f/cc.

• Labels must be affixed to installed ACM (29 CFR 1926.1011.k.8)

• All ACM raw materials, waste and debris, or containers in which these substances are stored must be labeled (29 CFR 1910.1001.j.4).

Building occupant notifications summarizing asbestos removal and repair activities and the present policy for managing remaining ACM should be posted.

If an asbestos incident occurs, it is particularly important for management to communicate with affected building occupants and contractors.

4.2 Postings

Labels will be affixed to all products containing asbestos and to all containers containing such products, including waste containers. Where feasible, installed asbestos products shall contain a visible label (29 CFR 1926.1101.k.8). Warning signs that demarcate regulated areas shall be provided and displayed at each regulated area (29 CFR 1926.1101.k.7). Signs shall be posted at such a distance that an employee may read the signs and take necessary protective steps before entering the marked area. Examples of warning signs and warning labels are shown in Figures 4.1 and 4.2.

Figure 4.1. Warning Sign

Figure 4.2. Warning Label

CHAPTER 6

DANGER

CONTAINS ASBESTOS FIBERS

AVOID CREATING DUST

CANCER AND LUNG DISEASE HAZARD

REPORT ANY ACM DAMAGE TO

THE ENVIRONMENTAL MANAGEMENT OFFICE X4201

DANGER

CONTAINS ASBESTOS FIBERS

CANCER AND LUNG DISEASE HAZARD

DO NOT ENTER WITHOUT PROPER TRAINING AND PPE

RESPIRATORS AND PROTECTIVE CLOTHING REQUIRED IN THIS AREA

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CHAPTER 5

WORK CONTROL SYSTEM Project planning at PCD will take asbestos management into account. As part of the planning process for D&D projects, PCD will complete a Facility Inspection Report (FIR) to document environmental issues including asbestos locations. The FIR will be used by the contractor to plan for asbestos mitigation.

The Environmental Checklist for Work Orders and Contract Proposals is used to identify projects or actions that will require additional environmental analysis or documentation. The checklist identifies asbestos issues. If necessary, a Record of Environmental Consideration (REC) will be prepared by the proponent and approved by EMO in order to satisfy the requirements of the NEPA.

If disturbance of ACM is intended or likely, an asbestos abatement plan will be developed under the supervision of the Asbestos Program Manager. A licensed and qualified contractor will then be engaged to perform the abatement.

The Asbestos Program Manager will be notified in advance of all asbestos-related projects. Contractors will provide written notification and appropriate fees to EPA Region VIII and the Colorado Department of Public Health and Environment (CDPHE). Design personnel will ensure all contract specifications include appropriate State and Federal notifications.

CHAPTER 6 TRAINING

Contractors will provide appropriately trained workers for PCD specific projects. Certificates, as proof of training, are required for project records.

6.1 Asbestos Awareness Training PCD employees who may be exposed to asbestos in excess of the PEL shall participate in Asbestos Awareness training. Training should be provided before or during initial assignment and at least annually thereafter. The awareness training will be conducted by an asbestos consultant, PCD Safety Office, or the Training Office. Awareness training should include the following topics:

• Methods of recognizing asbestos

• Health effects associated with asbestos exposure including the relationship between smoking, asbestos exposure, and lung cancer.

• Types of operations that could or would result in exposure to asbestos.

• Appropriate methods of minimizing exposure, including engineering controls, work practices, and personal protective equipment (PPE).

• Purpose, use, fitting instructions and limitations of respirators.

• Medical surveillance program requirements

• The requirements for posting signs and affixing labels

• The names, addresses and phone numbers of organizations that provide smoking cessation programs

6.2 Advanced Asbestos Training Asbestos workers may participate in advanced training commensurate with assigned responsibilities. The following courses, presented by CDPHE-approved training providers, are recommended:

• Supervisor/Contractor Course (40 hours).

• Asbestos Inspector Course (24 hours).

• Management Planner Course (16 hours).

• Project Designer Course (40 hours).

• Air Monitoring Specialist Course (24 hours).

• NIOSH 582 Course (40 hours).

• Annual refresher courses are required to maintain certification for all levels of training.

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CHAPTER 7 RESPIRATORY PROTECTION PROGRAM

7.1 Purpose Exposure to airborne asbestos can be minimized though the use of proper respiratory protection. As airborne fiber concentrations increase the protection factor must also increase. This is accomplished by a change in respirator class from half-face piece to full-face piece to supplied air. Single-use, disposable respirators are not used per 29 CFR §1926.1101 (h).

7.2 Pueblo Chemical Depot Respirator Program The PCD Respiratory Protection Program (PCD-R 40-20) covers all types of respiratory protection, including asbestos, if needed.

7.3 Contractor Respirator Program All contract employees who are engaged in asbestos-related activities will be governed by their company policies and procedures regarding use of respirators. PCD is not responsible for activities such as fit testing, inspection, and maintenance of contract employees’ respirators.

Before any asbestos activities take place by contract employees at PCD, the contractor will provide a copy of their respirator program and all pertinent information to the Safety Office for review. PCD’s Safety Office will review and evaluate the contractor’s respirator program to ensure compliance with all applicable laws and regulations.

If the Safety Office finds that a contractor’s respirator program does not comply with all requirements at PCD, modifications will be made before the initiation of any asbestos-related activities.

CHAPTER 8 PERIODIC SURVEILLANCE

8.1 Surveillance If the building occupant or other party discovers that the condition of any ACM has deteriorated, the Asbestos Program Manager will be notified as soon as possible. CDPHE Certified personnel will then investigate to determine whether remedial action is required to prevent a health hazard.

The individual conducting the inspection must:

• Visually inspect all areas identified as ACM or assumed ACM.

• Inform the AMT when damage to ACM is observed and/or when debris is cleaned up.

• Record the date of the surveillance, his or her name, and any changes in the condition of the materials.

8.2 Air Quality Monitoring Contractors will provide an air quality monitoring professional to perform air quality monitoring. A sampling strategy will be developed by the professional and approved by the Asbestos Program Manager before air sampling begins. Air monitoring will be accomplished in accordance with 29 CFR 1926.1101. Air samples will be analyzed by a laboratory that has current accreditation by the American Industrial Hygiene Association (AIHA), that maintains acceptable performance in the National Institute for Occupational Safety and Health (NIOSH) Proficiency Analytical Testing (PAT) program, and that is certified by the National Voluntary Laboratory Accreditation Program (NVLAP). Air monitoring performed by contractors shall comply with State of Colorado and applicable federal requirements.

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CHAPTER 9 CLEANING AND MAINTENANCE

9.1 Initial Cleaning Contract personnel specifically trained in asbestos maintenance or an asbestos abatement contractor will conduct an initial cleaning immediately after a response action is completed. The purpose of initial cleaning is to remove airborne asbestos fibers that may have been deposited on surfaces. If an area containing ACM is uncovered during renovation, an asbestos abatement contractor should remove the materials immediately.

All areas of friable ACM and damaged, or significantly damaged, thermal system insulation that contains asbestos must undergo an initial cleaning. Newly exposed areas of ACM uncovered during renovation work must also undergo initial cleaning. In order to prevent further fiber release, cleaning must be performed using techniques that will not release fibers into the air or damage the ACM.

9.2 Recleaning Contract personnel specifically trained in asbestos maintenance or an asbestos abatement contractor will conduct recleaning operations. Recleaning consists of periodic or routine cleaning. It uses the same procedures as the initial cleaning and is implemented either on a regular schedule or when needed. The frequency of recleaning depends on the extent of the ACM within the facility and the level of contamination.

9.3 Key Points of ACM Maintenance Access to pipe fittings or sections of pipe may be necessary from time to time. When such work is necessary, maintenance personnel must contact the Asbestos Program Manager so that the work can be coordinated with an asbestos removal contractor. When removing insulation to gain access, care must be taken to avoid release of asbestos fibers. Any individual performing such activities must, at a minimum, comply with the recommended practices for small-scale, short-term projects contained in 29 CFR 1926.1101 and 40 CFR 61 subpart M.

Mechanical disturbance of ACM should be avoided because activities such as cutting, drilling, grinding, sanding, or hammering may cause significant damage and lead to airborne fiber release. When stripping flooring, follow the guidelines in 29 CFR 1926.1101 (l) (3). If asbestos removal is necessary, a consultant should be contacted to develop an asbestos abatement plan in conjunction with the Asbestos Program Manager. A licensed and qualified contractor will perform the abatement.

CHAPTER 10 EMERGENCY PROCEDURES

In the event of accidental damage to ACM due to roof leaks, broken water lines, improper maintenance, fire, or any other cause, qualified maintenance personnel should perform the following activities:

• Stop work and notify the Asbestos Program Manager, the Public Works Office, and the Safety Office immediately.

• Spill response actions will be conducted in accordance with the Installation Spill Control Plan (ISCP).

• Evacuate all persons from the affected area.

• Shut down the HVAC system servicing the affected area, and seal all vents in the area of the release.

• Isolate the area by closing and locking doors and windows and sealing them with polyethylene sheeting and duct tape. Use appropriate asbestos warning signs on the barriers.

• A trigger area of at least 80 linear meters (260 linear feet) on pipes or at least 15 square meters (160 square feet) on other facility components

Personnel that may have been exposed (potentially or actually to asbestos above OSHA PEL limits) will need to report to the PCD Occupational Health Clinic and complete required medical questionnaires, such as DD Form 2493–1 (Asbestos Exposure, Part I–Initial Medical) and/or DD Form 2493-2 (Asbestos Exposure, Part II-Periodic Medical Questionnaire). It is also recommended that these personnel complete a CA-2, Notice of Occupational Disease, through the US Department of Labor for claims and compensation of future health issues caused by such exposure.

• In the event of a medical emergency, call 911 (from a cell phone call 549-4911). The PCD Fire Department will respond. The Operations Center and the Fire Department will co-ordinate emergency response and medical assistance.

• For extensive clean-up operations, consult a certified asbestos abatement contractor.

NOTE! 3 square feet was quoted form Public Schools requirement

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CHAPTER 11 WASTE DISPOSAL

The Colorado Department of Public Health and Environment has in-state authority to regulate asbestos under the Clean Air Act and the Resource Conservation and the Recovery Act (RCRA). The Hazardous Materials and Waste Management Division and the Air Pollution Control Division share regulatory responsibility for asbestos. The Air Pollution Control Division regulates inspection and assessment activities as well as asbestos abatement. The Hazardous Materials and Waste Management Division regulates the proper disposal of asbestos waste in Colorado.

All asbestos waste will be disposed in a manner that complies with Colorado Regulation #8-Part B, 40 CFR 61 Subpart M, DOD 4160.21-M, and AR 200-1. The abatement contractor will handle disposal from abatement activities and will be responsible for transporting the ACM waste offsite on a daily basis.

Non-friable asbestos that is damaged, to the extent that it can be crumbled or reduced to a powder by hand pressure when dry, must be handled and packaged like friable asbestos waste. Resilient floor tile, adhesive sheet vinyl flooring, roof felts, asphalt tiles, transite roofing shingles, transite siding, and asbestos insulated pipe are considered non-friable forms of asbestos unless they are or will be damaged during demolition or renovation.

Waste ACM must be placed in air-tight and leak-proof containers to ensure that no visible emissions occur during handling. Typically, the material is placed into 6-mil-thick plastic bags. Sharp objects should be placed in puncture-proof containers. Double bagging of waste is recommended to ensure safe handling. Each waste ACM container must have a warning label as outlined in Chapter 4 of this document (Figure 4.2). For transportation, label containers with the name of the waste generator and the location of the waste generation. Waste ACM containers should be stored in a secured area. EMO waste management personnel will sign manifests for waste disposal.

CHAPTER 12 RECORD KEEPING

The Asbestos Program Manager will maintain copies of all forms and documentation involving asbestos. The following documents are part of the Asbestos Program and will be retained at Pueblo Chemical Depot.

12.1 Shipping Manifests A receipted copy of the “Waste Origin-Waste Disposal” form for the shipment of ACM will be maintained, along with other disposal paperwork, in the Document Tracking Center (DTC) for a minimum period of 2 years. The DTC will furnish upon request, and make available for inspection, all records required under 40 CFR 61.150.

12.2 Medical Records Medical exam records (as required in accordance with 29 CFR 1910.1001 and 29 CFR 1926.1101 or other applicable OSHA regulations) will be kept on file by the CMA2 for all employees who are engaged in asbestos work or who may have been exposed to asbestos fibers in excess of 0.1 f/cc TWA or an excursion level of 30 minutes at 1.0 f/cc. All records of measurements taken to monitor employee exposure to asbestos must be maintained for the duration of employment plus 30 years.

12.3 Training Records For each person requiring asbestos training, the Training Office will keep on file the person’s name, job title, date training was completed, type of training, location of the training, and number of hours completed. Training records must be maintained for the duration of employment plus 1 year.

12.4 Operations and Maintenance Records All records should be copied to the PCD document tracking center for archiving.

D&D project files are maintained with contract documents at the DPW. These files may contain start and completion dates of the work, names and addresses of all contractors involved, their state/EPA accreditation numbers, and, if ACM is removed, the name and location of the ACM storage or disposal site. A written description of preventive measures and response actions including the methods, the location where the preventive measure was taken and reasons for selecting the measure or action will also be maintained.

Building and facility owners shall maintain records of all information required pursuant to 29 CFR 1910.1001 concerning the presence, location and quantity of ACM and Presumed ACM (PACM) in the building/facility. Such records shall be kept in the DTC for the duration of ownership and shall be transferred to successive owners.

12.5 Other Forms The DTC will maintain records of all asbestos incidents and activities. The DPW will maintain records of asbestos abatement done in conjunction with building demolition and other contract projects.

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Records should be made available upon request to appropriate OSHA representatives in accordance with 29 CFR 1910.1001 and 29 CFR 1926.1101 or other applicable federal, state, or local laws. Sampling results and medical records should be made available to appropriate affected employees, former employees, and designated representatives in accordance with 29 CFR 1910.1001 and 29 CFR 1926.1101 or other applicable federal, state, or local laws.

Due to potential liability issues and concerns associated with asbestos, all employee records (training and medical) will be kept on file for duration of employment plus 30 years.

APPENDIX A DEFINITIONS/ACRONYMS AND ABBREVIATIONS

Abatement – The act of removing, encapsulating, enclosing, or repairing asbestos containing materials.

Asbestos – The asbestiform varieties of serpentinite (Chrysotile), riebeckite (crocidolite), cummintonite-grunerite, anthophyllite, and actinolite-tremolite, and any of these minerals that has been chemically treated and/or altered.

Asbestos Containing Material – Any material containing greater than (>) 1 percent asbestos.

Competent Person – One who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure per 29 CFR 1926.1101 (b), 29 CFR 1926.23 (f).

Demolition – The wrecking or taking out of any load-supporting structural member of a facility, together with any related handling operations or the intentional burning of any facility.

Encapsulation – The treatment of asbestos containing material with a material that surrounds or embeds asbestos fibers in an adhesive matrix to prevent the release of fibers.

Enclosure – An airtight, impermeable barrier around an asbestos containing material to prevent the release of fibers.

Friable – The ability of a material, when dry, to be crumbled, pulverized, or reduced to powder by hand pressure.

Removal – All operations, including demolition operations, where asbestos containing material is taken out or stripped from structures or substrates.

Renovation – Altering a facility or one or more facility components in any way, including the stripping or removal of asbestos containing material, from a facility component.

Repair – Overhauling, rebuilding, reconstruction or reconditioning of structures or substrates including encapsulation or other repair of asbestos containing material attached to structures or substrates.

Surfacing Material – Material such as acoustical plaster on ceilings and fireproofing materials on structural members that is sprayed on, troweled on or otherwise applied to surfaces for acoustical, fireproofing, or other purposes.

Suspect Material – A material which, based on its age, use, appearance, and texture, is suspected to contain asbestos.

Thermal System Insulation – Material applied to pipes, fittings, boilers, breeching, tanks, ducts or other interior structural components to prevent heat loss, heat gain, water condensation, or for other purposes.

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ACRONYMS/ABBREVIATIONS

ACM – Asbestos Containing Material

AHERA – Asbestos Hazard Emergency Response Act

AIHA – American Industrial Hygiene Association

AMC – Army Materiel Command

AMT – Asbestos Management Team

AMP – Asbestos Management Plan

APM – Asbestos Program Manager

BRAC – Base Realignment and Closure

CDPHE – Colorado Department of Public Health and Environment

CMA1 – Chemical Materials Agency

CMA2 – Competent Medical Authority

D&D – Demolition and Decontamination

DA – Department of the Army

DOD – Department of Defense

DOT – Department of Transportation

DPW – Directorate of Public Works

DTC – Document Tracking Center

EMO – Environmental Management Office

EPA – Environmental Protection Agency

f/cc – fibers/cubic centimeter

HEPA – High Efficiency Particulate Air

IH – Industrial Hygienist

ISCP – Installation Spill Control Plan

NEPA – National Environmental Protection Act

NESHAP – National Emission Standard for Hazardous Air Pollutants

NIOSH – National Institute for Occupational Safety and Health

NVLAP – National Voluntary Laboratory Accreditation Program

O&M – Operations and Maintenance

OSHA – Occupational Safety and Health Administration

PACM – Presumed Asbestos Containing Material

PAO – Public Affairs Office

PAT – Proficiency Analytical Testing

PCD – Pueblo Chemical Depot

PEL – Permissible Exposure Limit

PH – Public Health

PPE – Personal Protective Equipment

PUDADA – Pueblo Depot Activity Development Authority

RCRA – Resource Conservation and the Recovery Act

REC – Record of Environmental Consideration

RMD – Risk Management Directorate

TI – Thermal Insulation

TWA – Time Weighted Average

USACE – U. S. Army Corps of Engineers

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APPENDIX B PCD BUILDING DEMOLITION LIST

U.S. ARMY CHEMICAL MATERIALS AGENCY

PUEBLO CHEMICAL DEPOT ASBESTOS MANAGEMENT PLAN

December 2011

Approval Page

Prepared by: Keith L. Phillips Date Environmental Management Office Reviewed by: Kathryn R. Cain Date Chief, Environmental Management Office Concurrences: Randy Wojtala Date Safety Officer Patricia J. Steranka Date Director, Risk Management Directorate Eddie Dunn Date Director, Directorate of Public Works

_____________________________________________________ __________________ Wesley Huntley Date Chief, Fire Department ______________________________________________________ ________________ John Woodard Date Industrial Hygienist ______________________________________________________ ________________ Dr. Robert W. Weien Date Competent Medical Authority APPROVED:

_____________________________________________________ _______________ TIMOTHY M. GREENHAW Date LTC, CM Commanding

UNCONTROLED IF PRINTED PCD EMS Manual

1-1 Prepared by: Keith L. Phillips

December 2011

Pueblo Chemical Depot

EEMMSS MMaannuuaall

August 2009



Table of Contents

1. Introduction to the Pueblo Chemical Depot (PCD) EMS Manual ........................................................................... 1-3

1.1 Purpose of the EMS Manual ...................................................................................................................................... 1-3

1.2 EMS Manual Maintenance ........................................................................................................................................ 1-3

1.3 EMS Implementation at PCD .................................................................................................................................... 1-3

1.4 EMS Glossary ............................................................................................................................................................ 1-4

1.5 EMS Acronyms .......................................................................................................................................................... 1-9

2. PCD Scope and Characteristics .................................................................................................................................. 2-1

2.1 PCD Background & Mission ..................................................................................................................................... 2-1

2.2 PCD Facility Description .......................................................................................................................................... 2-2

2.3 PCD Significant Environmental Aspects ................................................................................................................. 2-4

3. PCD Environmental Policy ......................................................................................................................................... 3-1

4. EMS Procedures ........................................................................................................................................................... 4-4

4.1 Identifying Significant Environmental Aspects ........................................................................................................ 4-6

4.2 PCD EMS Audit Program ....................................................................................................................................... 4-15

4.3 PCD EMS Procedure for Internal and External Communications.......................................................................... 4-31

4.4 PCD EMS Procedure for Document Control and Documentation .......................................................................... 4-34

4.5 PCD EMS Procedure for Environmental Management Programs and Operational Controls ............................... 4-36

4.6 PCD EMS Procedure for Addressing Emergency Preparedness and Response ..................................................... 4-41

4.7 PCD EMS Procedure for Legal and Other Requirements ....................................................................................... 4-43

4.8 PCD EMS Procedure for Monitoring and Measurement ........................................................................................ 4-45

4.9 PCD EMS Procedure for EMS Management Review .............................................................................................. 4-47

4.10 PCD EMS Procedure for Nonconformity, Corrective and Preventive action ......................................................... 4-49

4.11 PCD E MS Procedure for Setting Objectives and Targets ...................................................................................... 4-51

4.12 PCD EMS Procedure for the Control of Records ................................................................................................... 4-54

4.13 PCD EMS Procedure for Competency Training ..................................................................................................... 4-56

5. EMS Records ................................................................................................................................................................ 5-1



1. Introduction to the Pueblo Chemical Depot (PCD) EMS Manual The original requirement for an Environmental Management System (EMS) was issued by Executive Order (EO) 13148, “Greening the Government through Leadership in Environmental Management.” Army Memorandum, ACSIM, DAIM-ZA, 10 July 2003, SAB requires EMS implementation via International Organization for Standardization (ISO) 14001. The Pueblo Chemical Depot (PCD) Policy Statement Number 20, 17 September, 2011, defines PCD’s environmental goals and mission. This manual defines PCD’s implementation, roles, responsibilities, and procedures for defining and maintaining the PCD EMS.

1.1 Purpose of the EMS Manual This Environmental Management System Manual serves as a repository for documentation related to the Pueblo Chemical Depot (PCD) Environmental Management System (EMS) and includes:

a. EMS Procedures that describe how to carry out key tasks within the EMS such as training, tracking legal and other requirements, or managing records.

b. Programs & Controls that operate under the EMS, such as programs for achieving EMS objectives and targets or for carrying out EMS audits.

c. EMS Records that confirm the completion of specific EMS activities such as the identification of environmental aspects, the conduct of EMS training, or that management reviews were completed.

d. Definitions and References that provide additional information useful to individuals reviewing or learning about the EMS.

1.2 EMS Manual Maintenance

a. This EMS Manual is maintained by: PCD EMS Manager or someone designated by him. b. The formal version of this EMS Manual is located in the Environmental Management Office,

PCD. c. This EMS Manual was last updated on: June 2010 d. In addition to the tables created to identify significant aspects and objectives and targets, the

EMS Manual contains the EMS Audit Program, the EMS Procedures, EMS records, and other descriptive information useful to anyone being introduced to the EMS or to those responsible for the EMS.

1.3 EMS Implementation at PCD The Pueblo Chemical Depot (PCD) has implemented an Environmental Management System (EMS) to ensure it fulfills the commitments to its Environmental Policy. The scope of the PCD EMS includes the following facilities and organizations within the Pueblo Chemical Depot (PCD. The EMS is modeled on the specifications found in the international standard for environmental management in organizations, ISO-14001:2004. Specific benefits provided to PCD from implementing a formal management discipline include:



a. The systematic approach to managing PCD’s potential impacts on the environment. b. Enabling PCD environmental concerns to be managed to accord with mission goals. c. Providing documentation of existing processes so that results can be repeated. Institutional

knowledge is captured so it is not subject to personnel flux. d. Providing a structured approach to identify potential impacts that could otherwise result in

costs, embarrassments, and threats to mission. e. Having the potential to provide employees with a sense of empowerment that can translate to

enhanced performance on the job. f. Providing the site with a means to track and measure environmental and operational

performance by instituting metrics. g. Providing greater discipline and assurance in tracking and analyzing environmental

requirements thus ensuring a higher level of compliance. h. Allowing PCD to use a risk management approach ensuring the site focuses and allocates its

resources to those that have the greatest probability and worst potential consequences. i. Providing for greater sharing of knowledge and responsibilities across all levels and

functions. j. Supporting reporting under Government Performance Results Act (GPRA).

1.4 EMS Glossary Adequacy: Refers to the sufficiency of the resources for the EMS.

Auditor Training: Training provided to those individuals that will fulfill the role of internal EMS auditors at PCD. This includes basic EMS training, familiarization with the organization's own EMS, as well as training on how to prepare, conduct and conclude the internal audit, including writing the audit report and overseeing the completion of corrective actions on the audit findings.

Competence Training: Training provided to personnel that are associated with significant environmental aspects. Such training is indicated when the individual is not considered competent on the basis of previous training, education, or experience to address the responsibilities he/she has been charged with relative to the significant environmental aspect in question.

Compliance Audit: A periodic audit of compliance with regulatory and other requirements that are imposed on the organization. Findings are expressed as non-compliances. The search for root causes in a typical compliance audit may not be as intense as it should be during an EMS audit.

Continual Improvement: Process of enhancing the EMS to achieve improvements in overall environmental performance in line with the organization’s environmental policy. (Note: Continual implies that there will be periods where improvement will be flat.) Correction: The totality of immediate and long-term steps taken to mitigate the consequences of a nonconformity (e.g., cleanup of spilled hazardous material; remediation of groundwater; natural habitat restoration). The correction does not by itself remove the underlying cause of the nonconformity.

Corrective Action: Action to address the underlying cause of an actual event that has been identified as a non-conformity through an audit.

EMO Program Manager: An individual in the Environmental Management Office (EMO) appointed to manage specific environmental programs and/or plans for media protection and resource conservation such as air, groundwater, surface water, soil, cultural resources, and pollution prevention.

Effectiveness: Refers to the accomplishment of the objectives and targets set for the EMS.



Environmental Impact: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from the facility’s aspects. (Note: A potential environmental impact is equivalent to the concept of risk, in safety, which assigns a probability and consequence to the possible negative event that may result from a hazard.) Environmental Aspect: An element of an activity that can interact with the environment. (Note: The environmental aspect of an activity is that part of the activity that creates the possibility for an environmental impact. As such, it is equivalent to the concept of hazard, in safety, which is also defined as the mere possibility of a negative event.) Environmental Management Programs: Are a management tool used to document the tasks, responsibilities, and other operational details that are implemented to achieve the objectives and targets that are set for the significant aspect. They include timelines, resources, and responsibilities for achieving

those objectives and targets and are amended as necessary with changing environmental, organizational, and legal requirements, as well as aspects and operations within the organization.

EMPs incorporate a number of other EMS components including:

The significant environmental aspect that is being addressed; The objective(s) and target(s) that were set for the significant aspect; The program indicators to be used to measure progress in achieving the objectives and

targets; The factors that gave rise to the significance of the aspect; The programmatic tasks needed to achieve the objectives and targets; The roles and responsibilities of individuals responsible for the tasks; Declarations of employee competency; Specification of records to be produced by executing the management plan; Reference to other documents used with the management plan; and Operational controls that are implemented to ensure that the objectives and targets will be

achieved as planned. Environmental Management System Manager: An individual appointed by top management to serve as management representative and coordinator ensuring that the EMS is established, implemented and maintained in accordance with the requirements of the ISO 14001:2004, and also report to top management on the performance of the EMS for review, including recommendations for improvement.

Environmental Objective: Overall environmental goal, arising from the environmental policy that an organization sets for itself to achieve, and which is quantified where practicable.

Environmental Performance: Measurable results of the EMS, related to an organization’s control of its environmental aspects, based on its environmental policy and objectives and targets.

Environmental Policy: Statement by the organization of its intentions and principles in relation to its overall environmental performance that also provides a framework for action and for setting of its objectives and targets.

Environmental Program Indicator: A specific datum selected, such as volume of a chemical used, which will provide measurable information regarding progress toward meeting a specific environmental objective and target.



Environmental Target: Detailed performance requirement, quantified where practicable, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.

Executive Overview Course: A briefing provided to the relevant officer staff and other top management at PCD on the EMS. This briefing familiarizes these individuals with general EMS concepts and with selected elements of the EMS that they ought to be familiar with. Most specifically, it lays out their roles and responsibilities with respect to the EMS, including their roles in establishing the PCD Environmental Policy and in conducting the periodic Management Reviews.

External communication: Communication to parties or organizations external to PCD’s physical site boundaries or its functions and activities.

External interested party: Individual or group concerned with or affected by the environmental performance of PCD. General Environmental Awareness Training: Training that is provided to all personnel irrespective of whether they are associated with significant environmental aspects.

Implementation Training: Training provided, if needed, to those responsible for implementing or supporting the EMS. This course instructs attendees on the basic principles of the EMS, provides sample procedures that can be adapted by the organization, suggests the use of certain templates that simplify implementation, and discusses the resources and organizational support required for the EMS development and implementation effort.

Incident or Emergency: Constitutes more than a mere nonconformity in the EMS. Any event that invokes the ISCP. For purposes of the EMS, nonconformities that do not invoke the ISCP will be corrected through the provisions of the PCD “Non-conformance and Corrective and Preventive Action Procedure.” Responses to emergencies such as fires, floods, and earthquakes are managed through the National Incident Management System (NIMS), Incident Command System (ICS). If the emergency is severe or long lasting, the PCD Emergency Operations Center (EOC) may be activated.

Inputs, Products, and Services: Term used to encompass the everyday activities of an installation. Includes, but is not limited to training on ranges; munitions testing; construction and renovation of real property; manufacturing activities; commercial services such as dry cleaning, photo processing, etc.; wash rack operations; grounds maintenance; vehicle maintenance; etc. (In this procedure the term Inputs will be used in place of the full term Inputs, products and services and is synonymous to the term “activities” found in the ISO-14001:2004 standard)

Installation Spill Contingency Plan (ISPC): A plan implemented immediately whenever there is a potential or an actual event such as fire explosion or release of oil or hazardous substances/waste. The ISCP meets the requirements of 40 CFR 264 (RCRA).

Installation Sustainability Team (IST): Team of facility personnel representing various installation activities and tenants selected by their organizational leader to serve as representatives for the various functional areas on the installation. The team’s responsibilities are to gather, organize, and disseminate information; help to develop EMS procedures; advise, coordinate, facilitate, and monitor EMS implementation; and assist the EMS Program Manager with EMS-related matters.

Interested Party: Individual or group concerned with, or affected by the environmental performance of an organization.



Internal Communication: Communication within PCD that is intended for personnel to further the EMS goals.

Internal EMS Audit: A periodic audit of the EMS to verify that it is properly implemented and that it continues to conform to planned arrangements for environmental management. It is an audit of the system and findings are expressed as non-conformities. Audit conclusions are based on the findings and focus on the root causes that led to the non-conformities. It is appropriate to seek the root causes of known compliance findings during an EMS audit, since these may reflect EMS deficiencies.

Legal Requirements: EMS legal and other requirements encompass all the constraints imposed on PCD to control its environmental aspects and operations. These constraints include federal, state, and local laws and regulations, environmental permits, registrations, executive orders, and consent decrees. In addition, internal organizational procedural requirements pertaining to environmental aspects such as military (e.g., Department of Defense [DoD] and Department of Army [DA]) instructions, directives, manuals, and policy decisions also apply. These internal requirements take on the same importance as legal requirements and are expected to receive the same degree of commitment to compliance.

Non-compliance: Failure to meet regulatory or other requirements that have been imposed on the organization. Non-conformity: Any deviations from established procedures, programs and other elements of the EMS. They may include non-compliance with regulations, but not all instances of non-compliance are necessarily non-conformities of the EMS.

Operational Controls (OCs): Mechanisms (technological or administrative) used to maintain a desired level of environmental performance. OCs are applied to PCD Inputs to prevent the environmental aspect they exhibit from occurring. Shop Environmental Instructions will be develop to inform personnel of environmental responsibilities. Examples of OCs include those built into technology (e.g., motion sensors, sleep mode for electronics, etc.), those requiring operator intervention (e.g., selecting duplex printing, electronic documents, etc.), and those that are incorporated in standard operating procedures (SOPs) (e.g., procedure for storage and disposal of hazardous waste).

Each significant environmental aspect shall be reviewed in conjunction with its inputs to determine whether OCs (either technological or administrative) are needed for those inputs.

In doing the review, special attention shall be given to those characteristics of Inputs that necessitate OCs.

Where applicable, documentation on the OCs will specify the operating criteria (including maintenance) and the actions to be taken when they are interrupted, or when they might otherwise fail.

When necessary, OCs will also be applied to the identifiable significant environmental aspects of goods and services that are received from external sources and used at PCD. When appropriate, OCs that need to be implemented by the external source shall be duly communicated to those sources. (Refer to EMS Communications Procedure, if applicable)

Operations managers are responsible to ensure that OCs are implemented for those inputs that are within their purview and that contain significant environmental aspects. OCs will be integrated into Shop Environmental Instructions (SEIs) as those are developed and implemented across operations at PCD.

Personnel: All persons working at PCD, including contractors that are on PCD for greater than 6 months.



Preventive Action: Action to prevent potential problems before they occur at other areas or functions of the organization that may have similar vulnerabilities to that which caused the original non-conformity. . Preventive action can be focused on identifying negative trends and addressing them before they become significant.

Record: A document stating results achieved or providing evidence of inputs performed (ISO 14001:2004 definition). A record is a permanent document that typically is not revised. Records will include:

Information on compliance with applicable legal requirements and other requirements to which the organization subscribes,

Details of nonconformities and corrective and preventive actions, Results of environmental management system audits and management reviews, information

on environmental attributes of products (e.g. chemical composition and properties), Evidence of fulfillment of objectives/targets, Information on participation in training, Permits, licenses or other forms of legal authorization, Results of inspection and calibration activity, and Results of operational controls (maintenance, design, manufacture).

Relevant Communications: Verbal or written inquiries deemed appropriate for response based on installation policy and concern for confidentiality.

Root Cause Analysis: Root cause analysis is the method used to identify immediate, underlying and root causes of an incident. The analysis of the root causes aims to find the proper corrective and preventive actions to apply to remove those causes and thereby prevent both a recurrence of the incident and its potential future occurrence in other parts of the organization. Significant Environmental Aspect: An environmental aspect that has, or can have, a significant environmental or mission impact (i.e., one that can potentially cause a significant environmental or operational impact).

Spill Prevention, Control and Countermeasures Plan (SPCCP): The plan are required by Section 311(j) of the Clean Water Act to establish procedures and guidance for the prevention, detection, and response to releases, accidents, and spills involving oils or hazardous substances at Pueblo Chemical Depot. Suitability: Refers to whether the EMS continues to accord with the nature of the organization.

Suppliers and contractors: Organizations or individuals that provide supplies, materials, services and other tangible goods to PCD.

Top management: For purposes of this procedure, top management will include, at a minimum, the Depot Commander or Deputy Commander and other members of the Command Staff.

Verification: A follow-up visit by the audit team to ascertain that corrections, and corrective and preventive actions have been appropriately completed. The decision to do this is based upon the frequency, severity, and/or risk of continued nonconformity, as well as on whether the finding was either a major or critical audit finding.



1.5 EMS Acronyms AAR after-action review ABC activity-based costing ACSIM Assistant Chief of Staff for Installation Management AEDB-EQ Army Environmental Database - Environmental Quality ANSI American National Standards Institute AR Army Regulation ARIM Army Reserves Installation Management ARNG Army National Guard ARTEP Army Readiness Training Evaluation Programs BACM best available control measures BACT best available control technology BADT best available demonstrated technology BMP best management practice CAA Clean Air Act CAAA Clean Air Act amendments CAIRA Chemical accident/incident response and assistance CAR corrective action report CDPHE Colorado Department of Health and the Environment CBT computer-based training CDR commander CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFCs chlorofluorocarbon CFR Code of Federal Regulations CFT cross-functional team CONUS Continental United States COTS commercial off-the-shelf CWA Clean Water Act DDMS Digital Document Management System DENIX Defense Environmental Network Information Exchange DFE Design for the environment DoD Department of Defense DPW directorate of public works DSERTS Defense Site Environmental Restoration Tracking System DTC Document Tracking Center EAP environmental action plan ECOs environmental compliance officers EMO Environmental Management Office EMP environmental management programs EMS environmental management system EMSMR environmental management system management representative EMSR Environmental Management System Representative ENFs enforcement actions EO Executive Order EPA U.S. Environmental Protection Agency



EPAS Environmental Program Assessment System EPCRA Emergency Planning and Community Right-To-Know Act EPI environmental performance indicators EPR Environmental Program Requirements EQCC environmental quality control committee ESA Endangered Species Act FAT facilities, activities and tasks FIFRA Federal Insecticide, Fungicide, and Rodenticide Act FRP Facility response plan FY fiscal year GC Garrison Commander GIS global information system GOCO government-owned, contractor-operated GPS global positioning system HAP hazardous air pollutant HAPPS hazardous air pollution prioritization system HAZMAT hazardous material HAZWOPER Hazardous Waste Operations and Emergency Response HMTA Hazardous Materials Transportation Act HOA homeowners association HW hazardous waste HWDMS hazardous waste data management system ICAPs installation compliance action plans ICS incident control center IESIS Installation Environmental Support Information System IMA Installation Management Agency IMRO installation management regional office IPR in-process review ISO International Organization for Standardization ISR Installation Status Report IT information technology METL mission-essential task list MSDSs material safety data sheets NAAQS national ambient air quality standards NCA Noise Control Act NEPA National Environmental Policy Act NFA no further action NLT no later than NOV notices of violation NOx nitrogen oxides NPDES national pollutant discharge elimination system OB/OD open burn/open detonation OCONUS Outside Continental United States ODCs ozone depleting chemicals OFEE Office of the Federal Environmental Executive P2 Pollution Prevention



PAO public affairs office PAIO Program Analysis and Integration office PCD Pueblo Chemical Depot PL Public Law PM2.5 particulate matter with diameter less than or equal to 2.5 microns POC point of contact POL petroleum, oil, or lubricant POTW publicly owned treatment works RCRA Resource Conservation and Recovery Act RDT&E Research, development, testing, and evaluation REOs regional environmental offices RRC Regional Readiness Commands SCP Spill contingency plan SDWA Safe Drinking Water Act SOP standard operating procedure SOx sulfur oxides SPCC Spill Prevention, Control, and Countermeasures SPCCP Spill Prevention, Control, and Countermeasures Plan SRS Strategic Readiness System SS significance score SVOC, Semi-Volatile Organic Compound TDA Table of Distribution and Allowances TEAM The Environmental Assessment Manual TOE Table of Organization and Equipment TSCA Toxic Substances Control Act USAEC U.S. Army Environmental Center USAES U.S. Army Engineer School USC United States Code UXO Unexploded Ordinance VOC volatile organic compounds WREO Western Regional Environmental Office – US Army


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2. PCD Scope and Characteristics

2.1 PCD Background & Mission The Pueblo Chemical Depot is located in Pueblo County, Colorado, about 100 miles southeast of Denver and 14 miles east of Pueblo; the Arkansas River is approximately one mile south of the activity. The facility encompasses 22,654 acres and is situated on flat to gently sloped prairie. The surrounding lands are mostly undeveloped ranchlands used for grazing, with some light commercial and residential zoned areas to the south. The depot houses a chemical stockpile which comprises about 8 percent of the nation’s original chemical materiel stockpile. This stockpile is scheduled for future destruction under the Department of Defense Assembled Chemical Weapons Alternatives program. The depot’s current mission is the safe and secure storage and monitoring of the chemical stockpile, preparation for destruction of the chemical stockpile and preparation for depot closure. Construction of the depot began in February 1942. The installation was originally named Pueblo Ordnance Depot, and the first carload of ammunition was received in August 1942. Although originally planned for the storage and supply of ammunition, facilities were expanded almost immediately to receive, store, and issue general supplies to support World War II. In 1946, Pueblo Ordnance Depot was assigned the mission of maintaining and overhauling artillery, fire control, and optical equipment. Two years later, ammunition renovation and demilitarization were added to that mission. During the Korean War, shipments of general supplies and ammunition increased, and the depot reached its highest civilian strength of nearly 8,000 employees. Missile maintenance was added to the depot’s mission in the 1950s and in 1962, the depot was renamed Pueblo Army Depot. The missile maintenance mission at Pueblo, with the exception of maintenance of the Pershing missile, was transferred to Letterkenny Army Depot in 1974. In 1976, Pueblo was given depot activity status and assigned to the Tooele Army Depot Complex. In December 1987, the United States and the former Soviet Union entered into the Intermediate-Range Nuclear Forces (INF) Treaty. Pueblo was assigned to disassembly and elimination activities. Pueblo completed its INF and Pershing mission in May 1991. Pueblo Depot Activity was in the forefront of support to Operation Desert Shield and Desert Storm, shipping a large part of contingency stocks in addition to ammunition and supplies to Southwest Asia. The Base Realignment and Closure Commission designated the depot for realignment in 1988. The installation was renamed U.S. Army Pueblo Chemical Depot in 1996.


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2.2 PCD Facility Description

Approximate Total number of employees: 330 Army civilian and military employees

Approximate Total number of buildings or structures:

2,200

Approximate Property acreage: 22,654 acres

Activities that occur outside site boundaries: None

Size of EMS team: Approximately 10, including all the Environmental Management Office personnel and individuals representing various functions and tenant groups at the Depot

EMS Implementation Start Date November 27, 2006

Composition of EMS team: Led by the EMS Manager with representatives from other functions

The scope of the PCD EMS includes the following facilities and organizations within the PCD: Pueblo Chemical Depot (PCD), Pueblo Chemical Agent-Destruction Pilot Plant (PCAPP).

http://pueblo.bechtel.com/


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Establishment of ISO 14001 EMS at Pueblo Chemical Depot


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2.3 PCD Significant Environmental Aspects (See section 4.1 of this manual on the development of the following list and its abbreviations.)


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3. PCD Environmental Policy The PCD Environmental Policy is a declaration of top management’s commitment to the environment and serves as the foundation for the EMS. Everyone in the organization is expected to be familiar with and understand the policy. The policy is considered when setting EMS objectives and targets, and it is understood that the implementation of the EMS serves to make the commitments in the policy operational. The environmental policy statement is, therefore, a vehicle for communicating the organization’s aspirations for environmental protection as well as a functional tool for establishing the operational boundaries of the EMS. The environmental policy aligns with the organization’s core mission and must include commitments to continual improvement, pollution prevention, and regulatory compliance. The environmental policy statement should reflect a management consensus on its contents and aims, and should be formalized through the signature of top management. Red River’s environmental policy is: Pueblo Chemical Depot's environmental policy is an integral part of our mission, and is the core of the Depot's Environmental Management System. This policy states in broad terms the environmental commitments of Pueblo Chemical Depot now and into the future. Pueblo Chemical Depot strives to be one of the national leaders in environmental, energy and natural resource stewardship. Red River's primary focus areas are prevention, compliance, restoration and conservation. The EMS program manager, Environmental Division is responsible for Pueblo Chemical Depot's Environmental Management System. However, environmental stewardship is the responsibility of every member of the work force, as well as its strategic partners and residents. Depot personnel consider many environmental aspects when assessing current and upcoming projects. Personnel consider environmental impacts of operations and activities through setting objectives and targets relevant to environmental aspects, planning, monitoring and revisions to achieve continuous improvement of our Environmental Management System. Pueblo Chemical Depot implements and will continue to implement new and innovative ways to prevent pollution, minimize waste, manage natural resources and to conserve energy. Pueblo Chemical Depot's personnel ensure that all activities comply with relevant environmental legislation, regulations and policies. We will continue to maintain a positive relationship with the local community, regulators and other governmental agencies. PCD’s Environmental Policy is supplemented by specific requirements and provisions in the following additional documents:

AR 200-1 – Army Regulation 200-1 Environmental Protection and Enhancement • Army Regulation 200-2, Environmental Affects of Army Actions • Army Regulation 200-3, National Resources – Land, Forest, and Wildlife Management • Army Regulation 200-4, Cultural Resources Management • Air Pollution Prevention and Control Act (Clean Air Act [CAA] of 1977, as amended 42 United

States Code [USC] § 7401 et seq.) • National Ambient Air Quality Standards, Title 40 Code of Federal Regulations (CFR) Part 50

(CAA § 109). • Colorado Department of Health and the Environment Regulations • Designation, Reportable Quantities, and Notification, 40 CFR 302 (CERCLA § 103) • Emergency Planning and Community Right to Know Act (EPCRA) of 1986 (42 USC § 11001) -

Title III of the Superfund Amendments and Reauthorization Act, (Public law [PL] 99-499, October 17, 1986, as amended by PL 102-389, October 6, 1992)

• Emergency Planning and Notification, 40 CFR 355 (EPCRA § 312)


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• Executive Order 13148 - Greening the Government through Leadership in Environmental Management

• Executive Order 13423 – Strengthening Federal Environmental, Energy, and Transportation Management

• Executive Order 13514 – Federal Leadership in Environmental, Energy, and Economic Performance

• Hazardous Chemical Reporting: Community Right to Know, 40 CFR 370 (EPCRA § 312) • Federal Water Pollution Control Act (Clean Water Act [CWA] of 1972, as amended [33 USC §

1251 et seq.]) • Storm water discharges associated with industrial activity, (40 CFR 122.26 (b)(14)(i)-(xi)) • General Provisions, 40 CFR 401 • Oil Pollution Prevention, 40 CFR 112 (CWA § 311) • Hazardous Materials Transportation Act of 1974, as amended (49 USC § 5100 et seq.) • General Information, Regulations, and Definitions, 49 CFR 171 Hazardous Materials • Information and Training Requirements 49 CFR 172 • General Requirements for Shipments and Packaging 49 CFR 173 • Training, 49 CFR Part 172, Subpart H • National Environmental Policy Act (NEPA) of 1969 (42 USC § 4321 et seq.) • Resource Conservation and Recovery Act (RCRA) of 1976, as amended (42 USC § 6901 et seq.) • Hazardous Waste Management System: General 40 CFR 260 • Identification and Listing of Hazardous Waste, 40 CFR 261 • Standards Applicable to Generators of Hazardous Waste, 40 CFR 262 • Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal

Facilities, 40 CFR 264 • Standards for Management of Used Oil, 40 CFR 279. Near Real Time Monitoring Systems SOP-PU-0000-R-491(and incorporated references) Toxic Chemical Laboratory Analytical Operating Procedures SOP-PU-0000-R-465 (and

incorporated references) PCD Site-Specific Laboratory Quality Control Plan (and incorporated references) PCD Regulation 385-61-2 Chemical Hygiene Plan (and incorporated references) PCD SOP PU-0000-M-486 Chemical Operations (and incorporated references) PCD CAIRA Plan (and incorporated references)

3.1 EMS Implementation The Pueblo Chemical Depot (PCD) has implemented an Environmental Management System (EMS) to ensure it fulfills the commitments to its Environmental Policy. The scope of the PCD EMS includes the following PCD and all tenants The EMS is modeled on the specifications found in the international standard for environmental management in organizations, ISO-14001:2004. Specific benefits provided to PCD from implementing a formal management discipline include:

a. The systematic approach to managing PCD’s potential impacts on the environment. b. Enabling PCD environmental concerns to be managed to accord with mission goals.


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c. Providing documentation of existing processes so that results can be repeated. Institutional knowledge is captured so it is not subject to personnel flux.

d. Providing a structured approach to identify potential impacts that could otherwise result in costs, embarrassments, and threats to mission.

e. Having the potential to provide employees with a sense of empowerment that can translate to enhanced performance on the job.

f. Providing the site with a means to track and measure environmental and operational performance by instituting metrics.

g. Providing greater discipline and assurance in tracking and analyzing environmental requirements thus ensuring a higher level of compliance.

h. Allowing PCD to use a risk management approach ensuring the site focuses and allocates its resources to those that have the greatest probability and worst potential consequences.

i. Providing for greater sharing of knowledge and responsibilities across all levels and functions.

j. Supporting reporting under Government Performance Results Act (GPRA). 3.1.1 Summary of Pertinent EMS Concepts 3.1.1.1 Background Formal Environmental Management Systems (EMS) emerged in the early 1990s to provide organizations with a proactive, systematic approach for managing the potential environmental consequences of their operations. Such systems have been widely adopted by industry and government and have been effective at improving regulatory compliance and environmental performance. In April 2000, President Clinton signed Executive Order (E.O.) 13148, “Greening the Government through Leadership in Environmental Management” that established a 5-year EMS implementation goal for all Federal Facilities. 3.1.1.2 EMS Model Although several recognized EMS frameworks exist, most are based on the International Organization for Standardization’s ISO-14001 EMS standard. As a result, ISO-14001 is the framework on which organizations most frequently choose to base their EMS, and this has proven to be the case with U.S. federal facilities.


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1. Phase 1: Planning The organization identifies how its operations might harm the environment, and develops measures to reduce this harm.

2. Phase 2: Doing The organization implements the systemic measures to minimize harm across all levels and functions of its operations.

3. Phase 3: Checking The organization assesses the effectiveness of the systematic measures for minimizing both the potential harm to the environment and its consequential impacts to mission.

Phase 4: Acting Based on its assessment of the implemented systemic measures, the organization undertakes actions

to make system adjustments and to promote continual improvement. . The findings of Phase 4 may indicate that adjustments to measures already in place are necessary or that entirely new approaches are needed to achieve desired environmental objectives. Output from this phase is fed back into Phase 1 Planning, to make necessary changes and additions designed to bring the EMS to the desired level of effectiveness. This system feedback propels the continual improvement of the EMS. The EMS continually moves through this cycle, fine-tuning its management of those areas of the organization’s operations that harm the environment. This “continual improvement cycle” is a fundamental characteristic of the EMS; it allows the system to adapt to the dynamic nature of the organization’s operations and to remain relevant and viable for its intended purposes.

4. EMS Procedures Chapter 4 contains PCD’s EMS Procedures. Each procedure describes the methodology used by PCD to execute various elements of an integrated EMS. The purpose of these procedures is to enable those who maintain the EMS to understand the requirements of the EMS and to ensure a reliable and consistent execution of those

ACT Management

Review

CHECK-Checking & Corrective Action

• Monitoring & measurement• Non-conformance,

corrective & preventative action

• Records• EMS audit

PLAN-Planning

• Environmental aspects• Legal & other requirements

objectives & targets• Environmental management

program

DO-Implementation & Operation

• Structure & responsibility• Training, awareness & Competence• EMS documentation• Operational control• Emergency preparedness & response

Figure 1: ISO14001 EMS Model


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requirements for an effective system. This chapter contains the authorized verbatim version of these procedures. Copies may be distributed to relevant functions and levels at PCD so that they are available to those individuals that need to reference them. This chapter contains the following EMS Procedures:

a. Identifying Significant Environment Aspects b. EMS Audit Program and Compliance Status c. Communications d. Document Control e. Environmental Management Programs/Operational Controls f. Emergency Preparedness and Response g. Legal and Other Requirements h. Monitoring and Measurement i. Management Review j. Nonconformity, Corrective and Preventive Action k. Objectives and Targets l. Control of Records m. Awareness and Competency Training


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4.1 Identifying Significant Environmental Aspects

1. 0 Purpose and Scope The purpose of this procedure is to identify the significant environmental aspects of the inputs associated with PCD’s activities, products, processes, and/or services in order to set objectives and targets for PCD’s Environmental Management System (EMS). The objectives and targets for significant environmental aspects will then be achieved through the implementation of Environmental Management Programs (EMPs).

This procedure will be applied to all Inputs within the scope of the EMS that have aspects that are under the direct control or influence of PCD. It is applied equally to those aspects within the scope of the EMS at PCD that may originate from external sources.

2.0 Definitions For definitions meant to help explain terms used throughout this procedure, see Chapter 1, Section 4.

3.0 Procedure The following approach will be implemented by the EMS Manager, in coordination with Environmental Management Office (EMO) personnel, to identify the significant environmental aspects associated with installation Inputs.

3.1 Define/Identify PCD Activities and Inputs Initial identification of activates will be based on the Depot’s mission. Initial identification of Inputs for those activities will begin with the EMS Manager identifying every organization that resides at PCD. They will create a baseline of the Inputs that are within the scope of the EMS and that have the possibility of interacting with the environment together with their environmental aspects and potential impacts. Each activity will have at least one Input. Each Input will have one or more aspects associated with it; likewise, each Input and aspect will have one or more environmental impacts identified.

The baseline list, in spreadsheet format (see Attachment A), will include Inputs that exhibit aspects that will be further considered for their significance. Any aspects that result from Inputs controlled or influenced by the installation or tenant will be evaluated for significance. In addition to identifying each Input and aspect, the baseline list must also include information on the potential environmental impact(s) associated with each Input.

A number of sources may contain relevant and applicable information that can be used to assist in the development of the baseline list. These sources include, but are not limited to installation operation plans; records of emergency response activities; environmental release incidents; environmental impact statements; range assessments; permit applications; outsourcing documentation; etc.

Additional information regarding environmental aspects will be collected by:

Brainstorming – Functional managers with a detailed knowledge of PCD’s specific Inputs will be assembled. This brainstorming team will meet to review PCD’s operations and reflect upon the likely sources of environmental implications (the aspects). Daily installation Inputs will be considered first, followed by Inputs that occur on a less frequent basis. Functional managers assembled for the brainstorming will include at a minimum: Environmental Program managers.


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Facility Walk Through – A physical walk-through of all areas and operations serves as a visual “trigger” to ensure that Inputs that should be included in the analysis are not inadvertently overlooked. The walk-through team will visit each work area within PCD and visually identify all of the Inputs that contribute environmental aspects, and make any necessary adjustments to the initial list. After the walk-through, the team will compare its list of “contributors” against the initial list and make necessary adjustments.

The following Inputs must be included in the baseline list of Inputs:

Inputs that have obvious regulatory or other requirements.

Inputs that have visible impacts on the environment.

Inputs that may not have visible impacts but are known to potentially cause harm to the environment or human health.

The following Inputs do not need to be included in the baseline list of Inputs:

Inputs that have minor and temporary impact on the environment.

Inputs that have been previously declared by qualified, competent experts to be insignificant.

Inputs that do not satisfy any of the criteria as outlined above.

3.2 Define/Identify PCD Aspects and Impacts Once the baseline spreadsheet of Inputs and their associated environmental aspects and impacts is completed, it is provided to all program managers of PCD’s Environmental Management Office (EMO) for review. The program managers will review this baseline list against existing environmental programs to determine its accuracy and provide feedback on baseline environmental aspects. The EMO will also assist the EMS Manager in refining the description of each of the potential environmental impacts associated with the aspects identified in the baseline list.

The aspects related to inputs that should be cataloged include both those that can be directly controlled as well as those that can be influenced. It is important to remember that these aspects are only those from the organization’s Inputs that fall within the scope of the EMS. The determination of aspects is made by following a sequence of questions:

1) What is the scope of the EMS?

2) What are the Inputs within that scope?

3) What are the aspects of these Inputs?

4) Which of these aspects can be directly controlled?

5) Which of these aspects can be influenced? Those that can neither be directly controlled nor influenced should not be included in the EMS.

PCD will also identify and address any impacts that may have a cumulative effect. This is especially important because a large number of different Inputs may produce a common impact. Individually, the impacts from these Inputs may be low, but in some cases, the cumulative impact may be significant.


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3.3 Identifying PCD Significant Aspects 3.3.1 Having identified the environmental aspects of PCD Inputs, the EMS Manager with assistance

from the IST will evaluate their significance. In general, all aspects that have a legal or other regulatory requirement will be considered to be significant environmental aspects.

Other factors that bear on significance will consider the severity of environmental, mission, and community impacts if the aspect were to occur and actually cause its greatest potential negative consequences. If one of these other factors is given a “high” severity score then the aspect will be considered a significant aspect irrespective of the existence of any applicable legal or other requirements. Inputs that score “high” on any of the impact categories will be listed in the Operational Control section of the EMPs. These other significance factors will be scored using the following criteria:

1. Positive or Negative Impact to the Environment:

(3) High: Environmental consequences are serious but reversible over time. Environmental benefits to ecology or to human health and welfare are moderate.

(2) Medium: Environmental consequences are noticeable but brief or totally correctable in a relatively short time period. Environmental benefits to ecology or to human health and welfare are minimal.

(1) Low: Environmental consequences are immediately reversible and and/or administrative, brief and totally correctable. Environmental benefits to ecology or to human health and welfare are minimal or non-existent.

2. Positive or Negative Impact to Mission Capability:

(3) High: Interruption of normal mission operation (e.g. line stoppage) is likely and severe and could result in fines or remediation. Benefit to the organization or mission capability is substantially improved.

(2) Medium: Interruption of normal mission operation (e.g. line stoppage) is likely but recoverable without significant repercussions or the cost of a fine or remediation is moderate. Benefit to the organization is moderate or mission capability is moderately improved.

(1) Low: Interruption of normal mission operation is either unlikely or the consequences are very slight or easily corrected. Benefit to the organization or mission capability is minimally improved.

3. Positive or Negative Impact to the Community:

(3) High: Community would become concerned/aware but not unified in its opposition. Would produce media coverage and may or may not lead to legal action, political pressure, or significant embarrassment to PCD.

(2) Medium: Community may or may not become concerned/aware but would not be concerned and not likely to result in media coverage, legal action, political pressure or significant embarrassment to PCD.

(1) Low: Transparent to community and not a concern, not likely to result in media coverage, legal actions, or political pressure to PCD.


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3.3.2 The updated spreadsheet (an example sheet is enclosed as Attachment D – Significant Aspects Identification Table) that documents the significant aspects will be sorted by organization and distributed to the leaders for review and comment. The last updated spreadsheet can be found in section 2.3 of this manual.

3.3.3 The EMS Manager will finalize the list and staff it to the Depot Commander for approval. 3.3.4 Once finalized and approved, the list becomes input to the EMS Procedure for Objectives and

Targets. 3.4 Keeping the List of Aspects Updated This procedure will be applied as necessary to ensure that the PCD EMS identifies all significant aspects and will be reapplied every 18 months to maintain the currency of the EMS. 4.0 Guidance for Creating the Aspects Spreadsheet 4.1 Consolidate Inputs Within Each Significant Aspect and Determine Need for Subgroups.

The resulting list of significant aspects and their corresponding Inputs may be sub-divided into subgroups. In general, determining whether or not to split significant aspects into subgroups is based on management considerations for ease of tracking, for clarity in the assignment of responsibilities, and for operational considerations including the setting of objectives and targets and the development and implementation of EMPs. For example, the split may be made along organizational lines or to highlight a particular source:

• Organizational Differentiation: It may be that one part of the organization contributes a considerably greater proportion to the significant aspect than all of the other parts combined. In this instance, it would make sense to have a subgroup for that part of PCD (with the objective to improve on its performance) and a subgroup for the other parts (with the objective to maintain their performance). • Source Differentiation: It may be that there are two (or more) distinct classifications of sources that contribute to a common significant aspect. For example, painting and degreasing operations (generating volatile organic compounds) and internal combustion engine operations (generating Sox, Nox, and CO emissions) may both contribute to the aspect on Air Emissions. In this instance, it would make sense to split them into two subgroups since each would have a different strategy to improve its own performance.

4.2 Evaluating New/Modified Inputs

The EMO Director and/or EMS Manager will attend Production Planning Meetings (PPM). PPM meetings discuss new and changing functions within the Directorate for Maintenance. An additional method of notification that may be utilized is whenever a new Input is initiated, or an existing Input is modified, the relevant organization shall notify the EMS Manager by routing information on the new or modified Input to the Environmental Division. The NEPA Coordinator in EMO will also route pertinent information on new or modified projects to the affected EMO staff for an evaluation to ascertain if any significant environmental aspects have been introduced and/or modified, and to make necessary adjustments in the EMPs.


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Newly identified significant aspects will be added to the EMS in accordance will all applicable EMS procedures.

4.3 Evaluating Aspects from External Sources

This procedure is also applied to Inputs that originate from external sources (e.g., suppliers). Significant environmental aspects at PCD that originate from such sources shall be managed like all other significant environmental aspects. PCD may take steps to notify those external parties over which it has some influence to mitigate any aspects that may reasonably be mitigated at the source. Where no such influence exists or where mitigation at the source is infeasible, PCD will address such aspects within its own EMS.

5.0 Records The PCD EMS Manager will keep and maintain the following records that result from this procedure (the information may be organized into separate lists or into one or more tables to facilitate access and presentation):


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Attachment A: Operational Inputs and Associated Aspects and Impacts (sample)


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Attachment B: Significant Environmental Aspects List

1. Air Emissions (ODS (CFCs in building chiller systems), VOCs (fugitive emissions from vehicle fueling operations, chemical cleaning, parts washing, painting, etc.), criteria pollutants (machinery operations, vehicle operations, etc.), dust, particulates, odors)

2. Solid Waste Generation (other) a. Paper/Cardboard Generation b. Wood Pallet Generation c. Scrap Metal Generation d. Tire Generation

3. Hazardous/Regulated Industrial Waste Generation (laboratory or degreasing solvents, hazardous batteries, empty chemical containers, used oil, paint filters)

4. Universal Waste Generation (waste paints, blast media, florescent lights, batteries, etc.) 5. Chemical Spills/Leaks to Surface or Ground Water (fuel, hydraulic leaks, POL, storage tank

leaks, perchlorate, cadmium, other heavy metals etc.) 6. Toxics Releases (TRI and TIER 2 inventories) 7. PCB Releases 8. Asbestos Releases 9. Lead Based Paint Releases 10. Pesticide Applications (grounds maintenance, pest control) 11. Liquid Discharges (point and non-point) to surface and/or ground waters [(industrial wastewater

contributions from painting operations, metal etching/plating, X-ray activities, vehicle maintenance areas), sewage, wash-racks, air dryers, and storm-water]

12. Electricity Consumption (high electricity use operations) 13. Fuel Consumption (petroleum products, natural gas, and other alternative fuels) 14. Water Consumption (high water use operations) 15. Ecological Disturbance (NEPA, hydrological alteration, vegetation alteration, habitats, wetlands,

threatened and endangered species, invasive species, etc.) 16. Cultural Resource Disturbance (historic properties, graveyards) 17. Generation of Noise or Nuisances (testing operations, vehicle operation, vibration, visual

impairment) 18. Soil Erosion (construction activities and ground clearing)


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Attachment C: Sample Environmental Impacts Toxics contamination or addition to air, land, waterway Reduced visibility Air pollution (smog, acid rain, dust, visual impairment) Human health impact Landfill depletion Resource depletion Soil contamination Groundwater contamination Surface water contamination Hazardous material damage Biological material damage Ecological damage Ozone depletion Greenhouse gas release Habitat alteration Introduction of non-native species Pesticide damage Cultural resource property-damage Sedimentation of water courses Increased runoff / stream flow Watershed alterations Soil compaction Wind erosion Water erosion Loss or damage to threatened and endangered species Noise damage Vibration damage Heat damage Radiation damage Odor nuisance Nuisance to community Loss of indigenous species

December 2011 Draft UNCONTROLED IF PRINTED PCD EMS Manual

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4.2 PCD EMS Audit Program

1.0 Purpose and Scope The PCD EMS Audit Program is implemented to ensure the organization allocates resources, provides qualified auditors, plans the execution of audits and otherwise arranges for the efficient and effective conduct of internal EMS audits in support of the EMS. Internal EMS audits support the EMS and provide a periodic check of its status so that management can make decisions regarding its continuing suitability, adequacy and effectiveness. Internal EMS audits also assess conformance to the requirements of the ISO-14001:2004 standard and are used to verify that the organization periodically does compliance status checks. The PCD Audit Program is based on the ISO-19011 standard. 2.0 Definitions For definitions meant to help explain terms used throughout this procedure, see Chapter 1, Section 4. 3.0 Approach 3.1 Audit Program Chart: International Organization for Standardization. (Final Draft 2002). ISO-19011: Guidelines for quality and/or environmental management systems auditing. ISO/FBIS 19011: 2002(E).

Authority for the audit

program

Establish the audit program

• Objectives and extent• Responsibilities• Resources• Procedures

Implementing the audit Program

• Evaluating auditors• Selecting audit teams• Directing audit activities• Recording

Monitoring and reviewing the audit program

• Identify opportunities for improvement

Competence of Auditors

Improving the Audit Program Audit

Activities

P

L

A

N

D

O

C

H

E

C

K

A

C

T

3.2 Audit Program Manager Responsibilities - The EMS Manager also acts as the Audit Program Manager for internal EMS audits and internal compliance audits. The EMS Manager has the following responsibilities:


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a. Ensures adequate resources have been allocated in relevant budgets for the conduct of planned internal EMS audits.

b. At the beginning of each fiscal year, plans the audit strategy (e.g., functions to be audited, elements to be audited, schedule of audits, team members for each audit, lead auditor for each audit, etc.).

c. Ensures sufficient auditors will be available and that they remain competent through further training or other means of maintaining competency.

d. Stores and manages all documentation from previous audits (e.g., audit reports, records of corrective actions, etc.).

e. Maintains Audit templates and checklists of criteria for use by the audit teams. f. Evaluates auditors and makes decisions on qualifying additional individuals as competent

internal auditors. g. Works with the lead auditor assigned to a given audit to establish the objectives for that audit and

to ensure that the proper resources and information are available to conduct the audit. h. Ensures that the audit team conducts and completes the audit.

3.3 Frequency of EMS Audits Internal EMS audits shall be scheduled on the basis of need as reflected by the importance of Inputs or the results of previous audits, but not less than annually, in order to verify that the system is implemented and functioning as expected. An individual audit may be limited to a sampling of EMS elements or areas and can be both random and/or focused on certain Inputs based on their importance and/or results of previous audits. The audit program manager will decide on the strategy to be pursued in the audit at the beginning of each fiscal year.

3.4 Scope of EMS Audits On an annual basis, internal EMS audits assess all operations and facilities described within the scope of the EMS to determine conformance for these operations and facilities against the requirements of ISO-14001:2004, and the organization’s internal performance objectives. Every organization will be audited at least once annually. Depending on the results of previous audits, the EMS Manager may opt to conduct one yearly audit or a series of audits that focus only on specific elements.

3.5 Selection of Audit Team The audit team shall be designated by the Depot Commander and shall consist of personnel that have received internal EMS auditor training and are deemed competent to conduct such audits. The PCD EMS Manager is responsible for overseeing the EMS Audit Program. He or she is also responsible for selecting the lead auditor for a given audit. The designated lead auditor is responsible for ensuring that the audit team conducts and completes the audit as planned. The Audit Program Manager shall not be a member of the audit team. The EMO Director may also bring in an outside contracted audit team to perform an internal audit or periodically, as needed, to get a fresh perspective and overview of whether the EMS is meeting established goals and functionality.

3.6 Internal Audit Procedure


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The internal audit will be conducted in accordance with the Internal EMS Audit Procedure (for details, please refer to that procedure below). EMS internal audits shall be conducted against pre-established audit criteria (see below). The audit criteria may be based on the sample audit criteria provided below which can be tailored to suit the specific needs and goals of the organization based on input from the EMS Manager and the lead auditor. Audit criteria shall consist of questions based upon the specified arrangements for the EMS, and shall be designed to elicit evidence of conformity with the organization’s EMS requirements. The focus of the EMS audit is to ascertain whether the EMS has been effectively implemented and is functioning in accordance with established PCD-specific arrangements. Audit findings must be based on objective evidence that is properly corroborated and authenticated. (Auditors shall avoid reaching conclusions on the basis of hearsay or opinion.)

3.7 Compliance Status

The EMS audit may also be used to verify that the compliance status has been established as arranged. The compliance status may be based on the results of a recent internal compliance audit (EPAS) that may have occurred. All internal compliance audits will utilize the most current EPAS Team Guide. PCD will rely on the internal EPAS compliance audits to ascertain its compliance status. Ongoing compliance checks will be conducted via routine walk-around inspections performed by the environmental division personnel. The internal EMS auditor shall ascertain that the organization has previously conducted a compliance status check as required by the ISO-14001:2004 standard.

3.8 Corrective Action

After conferring with the EMS Manager, the appropriate area or functional manager will address findings within a specified number of days by developing corrective actions which will be included in the summary response to the corrective action request.

If a nonconformity relates to the EMS itself, the EMS Manager will have the primary responsibility to apply the corrective and preventive actions. In this instance, the audit team ensures that the corrective and preventive actions have been completed when the next scheduled audit is conducted.

3.9 Preventive Action

Preventive action is undertaken to avoid repetition of the nonconformity in other areas or functions of the organization that may have similar vulnerabilities that caused the original non-conformity. It is the responsibility of the EMS Manager to initiate preventive actions as specified in the EMS procedure for Nonconformity, Corrective and Preventive Actions. The execution of preventive actions may be recorded in the Corrective Action Request report or it may be documented separately. For more detailed information, refer to the organization’s procedure for Nonconformity, Corrective and Preventive Action.

3.10 Follow-Up


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At the conclusion of the audit, the audit team will determine whether any findings require follow-up after the corrective and preventive actions are applied. This will be based upon the frequency, severity, and/or risk of continued or potential nonconformities, as well as on whether the finding was either a major or critical audit finding.

3.11 Closing the Audit

EMS audits are closed when the audit team leader establishes that the corrective and preventive actions have been completed.

3.12 Input to Management Review and to Next EMS Audit

The Audit Report and actions taken to address findings will be inputs to the Management Review. For more detailed information on the purpose and content of the Management Review, please refer to the Management Review Procedure. (The audit report, corrective action requests and records of corrective and preventive actions will also be available to auditors that will be preparing the next scheduled audit.)

3.13 Audit Process Documentation

Documentation that result from the conduct of an EMS audit may include the items listed below. The audit program manager provides proper templates for these items to the audit teams for their use on audits: i. Audit Plan j. Audit Criteria k. Internal Audit Report l. Detailed Audit Findings and Conclusions m. Completed corrective action.

3.14 Audit Resources

PCD management should be able to demonstrate that it has committed to allocate the resources necessary to support the continual improvement of the EMS by providing budget and staff resources necessary to maintain this EMS Audit Program. In addition, it should be able to show that auditor training will be provided for the audit team as necessary and that contracted resources may also be utilized, if necessary, to perform internal audits.

Attachments to Audit Program and Compliance Status:

1. Audit Work Flow 2. Audit Procedure 3. Audit Criteria


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Attachment 1 to Audit Program and Compliance Status: Audit Work Flow to audit) Attachment 2: Audit Work Plan

Initiating the Audit Appointing the audit team

leader Definition of objectives, scope and criteria Determination of the feasibility of the audit Establishing the audit team Initial contact with the

auditee

On site Audit Activities Conducting opening

meeting Collecting and verifying information Generate audit findings Communicating during the audit Preparing audit conclusions Conducting closing meeting

Reporting on the Audit Audit report

preparation Report approval and distribution Retention of documents

Audit Completion

Audit Follow - up

Initiating the Audit Appointing the audit team

leader Definition of objectives, scope and criteria Determination of the feasibility of the

audit Establishing the audit team Initial contact

with he

Onsite Audit Activities Conducting opening meeting

Collecting and verifying information Generate audit findings

Communicating during the audit Preparing audit conclusions Conducting closing meeting

Reporting on the Audit Audit report

preparation Report approval and distribution Retention of documents

Audit Completion

Audit Follow - up

Document Review of relevant management documents and records and determination of their adequacy

Audit Planning

Onsite Activities

Audit Completion

Preparing for Onsite Audit Preparing the audit plan Audit teamwork assignments Preparation of work documents


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Attachment 2 to Audit Program and Compliance Status: Internal EMS Audit Procedure Purpose and Scope

This procedure specifies the requirements for performing Internal Environmental Management System (EMS) Audits at the Pueblo Chemical Depot (PCD). These audits are a part of the PCD EMS and are conducted periodically to ascertain that the EMS is properly implemented and continues to conform to planned arrangements for environmental management, including the requirements of ISO-14001:2004.

Scope

An individual audit may be limited to a sampling of EMS elements or areas within the PCD, and can be both random and/or focused on certain Inputs based on their importance and/or results of previous audits.

Definitions

For definitions meant to help explain terms used throughout this procedure, see Chapter 1, Section 4. Approach Responsibilities:

The audit team shall be designated in writing and shall consist of personnel that have received internal EMS auditor training and are deemed competent to conduct such audits. The PCD EMS Manager is responsible for overseeing the EMS Audit Program. He or she is also responsible for selecting the lead auditor for a given audit. A designated auditor will be responsible for ensuring that the audit team conducts and completes the audit as planned.

Audit Planning: Each audit requires an audit plan (see attached Audit Plan template) that is prepared by the lead auditor for that audit. The audit plan addresses the following preparatory matters:

Audit scope and objectives; Audit criteria to be applied; Contacts and coordination with the auditee(s); Audit dates, times, and other logistics; Review of previous audits, records, and descriptions (e.g., programs, operations, etc.); Protocol for conducting the audit (e.g., interviews, access, coordination, safety, resolution of

findings, etc.); and Responsibilities for writing the audit report and for follow-up actions.

Requirements: Individuals on the audit team must receive internal auditor training and be designated as

competent to conduct internal EMS audits; EMS audits will be conducted against pre-established audit criteria; The audit criteria shall be developed jointly by the entire PCD audit team, and approved by

the EMO Director; Audit criteria shall consist of questions based upon the specified arrangements for the EMS,

and shall be designed to elicit evidence of conformity with ISO-14001:2004 and PCD arrangements for environmental management.


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The focus of the EMS audit is to ascertain that the EMS has been effectively implemented and is functioning in accordance with established arrangements; and

Audit findings must be based on objective evidence that is properly corroborated and authenticated. (Note: Auditors should avoid reaching conclusions on the basis of hearsay or opinion.)

On-Site Audit Process: EMS audits will be conducted primarily through interviews with personnel; EMS audits may include sampling. For example, compliance data may be sampled to

ascertain that compliance programs are achieving their intended objectives; The EMS auditors may also rely on records for information related to the functioning of the

EMS and its objectives and targets; The EMS auditors may also rely on observations of operating conditions to gauge

environmental status and conditions, where appropriate and efficacious; The audit team will conduct opening and closing meetings with responsible management of

the areas being audited; The audit team will document corrective actions. Responsibility for corrective actions will

reside with management in the area where the findings occurred. If a corrective action relates to the EMS itself, the PCD EMS Manager will have primary responsibility to arrange for the correction to be made. The audit team validates that the corrective and preventive actions have been completed by the auditee.

Regulatory Compliance Status: The regulatory compliance status at PCD is established periodically through the external EPAS audits, internal compliance audits, routine walk-around inspections, state audits, EPA audits and other external audits.

Audit Report: When the audit is complete, the audit team will complete the audit details. After audit details have been completed they will be available to the PCD EMS Manager and the manager for the area audited.

Closing the Audit: The audit team will monitor the auditee’s completion of corrective and preventive actions for a proper closing of the audit. The EMS audit is closed when the audit leader establishes that the corrective and preventive actions have been accomplished.

Input to Management Review: The results of the audit and the status of the corrective actions are to be presented at the next scheduled Management Review meeting.

Records Records generated by this procedure are maintained by EMS Program Manager and include the following information:

1. Audit planning information 2. Audit criteria 3. Audit findings and conclusions 4. Completion of corrective and preventive actions.


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Attachment 3 to Audit Program and Compliance Status: Audit Criteria, ISO-14001:2004

4.2,1 Environmental Management System Audit Criteria ISO 14001:2004 Purpose The purpose of this document is to provide the criteria for the internal audit of the Environmental Management System (EMS) implemented at PCD as required by Executive Order 13423. Findings categories: Major nonconformity finding: A significant number of minor findings against one element of the EMS or a completely missing element. Minor nonconformity finding: A single nonconformity against an element of the EMS.


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Sample Audit Checklist


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4.3 PCD EMS Procedure for Internal and External Communications 1.0 Purpose and Scope The purpose of this procedure is to establish a reliable and consistent process for addressing and documenting communications pertinent to the Pueblo Chemical Depot (PCD) Environmental Management System (EMS). Specifically, this procedure is used: To enumerate the internal communication tools and processes for communicating EMS-related

information between levels and functions inside PCD; For receiving, documenting and responding to relevant information and requests from external

interested parties; and To communicate information and/or requirements related to the identified significant environmental

aspects of goods and services (used or outsourced at PCD) to suppliers and contractors in accordance with the requirements of PCD’s EMS.

This procedure is applied to all internal and external communications regarding the PCD EMS, including communications initiated by PCD as well as communications from PCD in response to external requests for information. 2.0 Definitions For definitions meant to help explain terms used throughout this procedure, see Chapter 1, Section 4. 3.0 Approach 3.1 Internal Communications: PCD utilizes several “information tools” as a means of maintaining a high level of information flow between all levels of the Depot’s structure. These include: Intranet web sites, e-mails, telephone, memorandums, recurring meetings, etc. All personnel are strongly encouraged to use these methods to exchange ideas, discuss problems and ask questions from supervisors and other Depot members. Major topics of internal communication include, but are not limited to:

Environmental policy, objectives, and targets; Environmental roles and responsibilities; Environmental regulatory requirements; Environmental performance compared to objectives and targets; Environmental policies and procedures; and, Hazards and emergency response procedures.

The Depot Commander is responsible for communicating the installation’s environmental policy. The proponent for all other internal environmental communications is the Environmental Division. However, dissemination of environmental information to all installation personnel is the responsibility of all levels of management. Conversely, all installation personnel are encouraged to provide feedback through their appropriate chain of command on issues that could impact the environmental performance of the installation.

1. The following actions promote internal communication regarding the PCD EMS:


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The PCD Environmental Policy will be communicated to all PCD personnel. A hardcopy of the most current policy statement will be posted on all “official” PCD message boards

EMS Training: o Awareness Training – All PCD personnel will receive EMS Awareness Training. (New

personnel will receive this training during the New Employee Orientation.) o Competence Training – For personnel whose work may involve significant

environmental impacts, PCD will evaluate competence and deliver training targeted to the person’s job function, if that is deemed necessary to upgrade his or her skills.

o Outreach campaign – As necessary, EMS outreach efforts will be undertaken to promote the EMS awareness (e.g., Earth Day activities, etc.).

o Contractors working on the depot for more than 6 months will be required to attend an EMS Awareness training session. If their work may involve a significant impact, the contractor will evaluate competence and deliver training targeted to the person’s job function, as appropriate.

3.2 External Communications:

1. Consistent with its commitments in the Environmental Policy statement, PCD will communicate relevant information regarding its EMS. Specifically, PCD will take the following actions under its EMS: Make its Environmental Policy available to the public via the Environmental Monitor

quarterly news letter; the AQWA/PCD Web Site or upon request; Report all environmental information required by regulation to the appropriate authorities;

and PCD has considered the external communication of its significant environmental aspects and

will do so fully as required by law.

2. Regarding non-regulatory inputs from external interested parties, PCD has instituted the following process: All written, non-regulatory external inquiries concerning environmental performance, are

received or routed to the PCD Public Affairs Office (PAO). A determination of Freedom of information Act (FOIA) is made. If the inquiry is determined to be FIOA then it is forwarded to the FIOA Office for processing.

The SME provides documentation and generates the OPSEC review forms for staffing the response prior to release from the Depot.

The PAO shall ensure that the response is timely. The EMS Manager and Environmental Program Managers will consider all external

communications when establishing and reviewing environmental objectives and targets for the EMS and will initiate any necessary changes to the EMS.

All responses to inquiries from members of Congress will be coordinated through PCD Legal Office and staffed through PAO for Depot Commander’s signature.

PAO prepares responses to inquiries from the media will be coordinated through the PAO and routed through the Legal Office and the Office of the Commander.


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3. Regarding regulatory written correspondence and requests, PCD has instituted the following process:

All regulatory requests concerning environmental performance are received or routed to the EMO Director.

The EMO Director may obtain input or task the appropriate EMO Program Manager to prepare a response to the regulatory body.

The EMO Director approves the response, and either signs it, or routes it for appropriate signature either to the Director of Public Works, Legal Office or to the Depot Commander.

Formal communications will be entered into the EISIS system or maintained in the EMO master files.

3.3 Communications with Suppliers and Contractors:

1. PCD will communicate the following information to appropriate suppliers and contractors, including contractors used for outsourcing:

PCD is concerned about environmental issues and desires to conduct its business operations in an environmentally sound manner.

Relevant significant aspects will be communicated to contractors (including those used for outsourcing) and suppliers through the bid package. It will also be applied to contractors working onsite at the depot for more than 6 months.

PCD has implemented an EMS, which is based on ISO-14001:2004. PCD expects its suppliers and contractors to provide, at the same quality and price, products

and services that have the least environmental consequence of all available options. Where a supplier’s product is causing a significant environmental aspect at PCD, PCD will

communicate to that supplier that wherever possible, they should select the available option that minimizes the potential environmental impact of that product.

2. Where a supplier or contractor is supplying goods or services associated with significant

environmental aspects, the affected PCD manager will work with the appropriate procurement representative to inform that supplier or contractor of applicable procedures and requirements to mitigate, minimize, or otherwise control the potential environmental impacts associated with those significant environmental aspects. This will also be applied to contractors used for outsourcing.

3. Communications with suppliers and contractors shall be documented in accordance with PCD

procurement procedures. 4.0 Records Records generated from the execution of this procedure will be maintained in electronic form and in hard copy and include:

Records of submissions to regulatory authorities; Records of environmental reports to the public if any; Copies of requests and responses to external parties; Copies of sent and received communications from suppliers and contractors.


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4.4 PCD EMS Procedure for Document Control and Documentation

1. 0 Purpose and Scope The purpose of this procedure is to provide a standard method for controlling documents that support the operation of the Pueblo Chemical Depot Environmental Management System (EMS). This procedure provides instructions, and assigns responsibilities for the establishment, review, authorization, issue, distribution, and revision of controlled documents and records.

This procedure applies to the creation, revision, approval, distribution and version control of all documents associated with the EMS.

2.0 Procedure Personnel with specific EMS document responsibilities will ensure that documents are current, available to personnel that need them, and are removed when they no longer apply or have been rendered obsolete by updated versions.

Controlled documents, such as SOPs or management plans, are accessible through the intranet website. Printed copies of these controlled documents will be marked with the statement “Controlled Document, Uncontrolled if Printed.” Further detail of this procedure for approval and version control is supplemented by specific requirements.

Other documents and records may exist outside the system and are not considered official controlled documents. These documents may exist as information transport tools to final record locations and/or may be developed and used for personal use only. 3.0 EMS Documentation EMS documentation provides a standardized structure for organizing PCD’s EMS programs, procedures, work instructions, and records. The structure of the documentation is as follows:

The EMS Manual - describes the core elements of the management system, including their interrelationships. The manual provides an overview of the EMS. It refers to, and cross-references, related documentation such as EMS Procedures, and EMPs. EMS Procedures detail specific EMS requirements and the roles, responsibilities and authorities to fulfill the requirements. As appropriate, procedures reference related documentation such as EMPs and work instructions. EMPs included in chapter 5 of the manual are included for reference only and will be replaced with the most recent version only when the EMS manual is updated. These procedures and programs are applicable to the operations at Pueblo Chemical Depot. The EMS Manual details requirements and guidelines for implementation. (The EMS Manual is available in electronic media at relevant workstations).

Depot Level Documents – PCD Regulations, Commander’s Policy Statements, Pamphlets, and

other directives published at the depot level that supports the EMS Manual requirements and guidelines are located on the Depot Intranet.


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Policy and Instructions (P&Is), Standing Operating Procedures (SOPs), Operating Instructions (OIs) – Internal organizational Policy and Instructions, Standing Operating Procedures, and other Operating Instructions.

EISIS Database – the following EMS documentation will be maintained in the EISIS Database:

o List of environmental aspects associated with PCD Inputs o Routine Recurring tasks outlined in the EMPs o EMS records not managed by Environmental Program Managers o Training information

4.0 Records


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4.5 PCD EMS Procedure for Environmental Management Programs and Operational Controls

1.0 Purpose and Scope The purpose of this procedure is to establish a reliable and consistent approach for creating and documenting the Environmental Management Programs (EMPs) associated with the Pueblo Chemical Depot (PCD) Environmental Management System (EMS). EMPs provide the guidance, information, and references necessary for the efficient and effective accomplishment of the objectives and targets that are set for the PCD EMS. PCD documents its EMPs in order to avoid confusion and ambiguity about what needs to be done and who is responsible for doing it. This EMS procedure also provides guidance for applying Operational Controls (OCs) to PCD’s Inputs with the potential for significant environmental impacts. PCD’s EMO staff applies this procedure to develop and document the EMPs that they create, update, and implement to achieve the objectives and targets of the PCD EMS. Objectives and targets are set through the execution of the EMS Procedure for Setting Objectives and Targets. 2.0 Definitions For definitions meant to help explain terms used throughout this procedure, see Chapter 1, Section 4. 3.0 Approach PCD uses the EMP Template (See attached EMP Template) as a guide to structure existing and new EMPs. The EMPs also demonstrate the different elements of the EMS and their interaction. Existing PCD programs are periodically reviewed to ensure they contain the programmatic information elements shown in the EMP Template. Once completed, the EMP templates are reviewed by the Environmental Management Office Director. EMPs will be reviewed and updated if needed by each program manager at least one time a year and are available to the Office of the Commander. The official version of the EMPs will be maintained by Environmental Management Office. 4.0 Records EMPs generate a variety of EMS records. In most instances, the EMP template itself serves as a record:

1. The previous 3 years of completed EMP templates (Starting May 2006); 2. Records that reflect the status of objectives and targets as measured during the course of

program implementation, where applicable; 3. Records that reflect the assignment of roles and responsibilities, when used; 4. Records that reflect the allocation of other resources, when used; 5. Records other than the EMP that substantiate declarations of employee competency, when

used; 6. Records of maintenance performed on operational controls; 7. Records of any Corrective Actions taken in the event of interrupted or failed controls;


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8. Records of operational controls that were communicated to external sources of goods and services; and contractors working on site or doing outsourced work and

9. Records that demonstrate the functioning of operational controls, either ongoing or periodic depending on what is appropriate and actually implemented.


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Example Environmental Management Plan (EMP) Significant Aspect:

Tracking Number

Department/Area(s): Date:

Objective:

Process/Activity:

Potential Impacts:

Target:

Legal and Other Requirements:

Task Responsible

Party Schedule/Resources Key Characteristics/Performance

Criteria

.

Approvals: Submit to the Environmental Quality Control Committee (EQCC) for review and approval.


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Guidance for Completing the EMP Template

This guidance complements the information in the EMS Procedure for creating environmental management programs (EMPs) and their associated operational controls (OCs). Specifically it provides guidance for completing the EMP template which is designed to capture programmatic, management summary information for a more structured, consistent and documented management of environmental programs at PCD. The EMP template is designed to not only to incorporate all the main elements of the EMS and document their interaction, but actually be a usable tool in managing PCD’s Significant Environmental Aspects. Field 1. Significant Aspect: The aspect listed here may be generic (e.g., air emissions), it may be by

criteria (e.g., particulates), or it may be specific to a function or Input (e.g., CFC emissions from refrigeration). The aspect needs to be as specific as is required to manage it efficiently and effectively. The degree of granularity and specificity in categorizing aspects is therefore dependent on how they will be managed and on how best to communicate that information in the EMP documentation. It is not useful to aggregate dissimilar aspects when their management requires different protocols and controls. Such agglomeration may result in lack of clarity and increase the likelihood of mismanagement of the environmental aspect in question.

Field 2. Tracking Number: This designator is a unique number used by EMO to control document

version as a means to ensure that only the authorized and currently valid version is in use. Field 3. Department/Area(s): This is the name by which this program will be known in the organization. Field 4. Date: This is the date when the document was last revised. Such information may be of value

to different users of the EMP. It may be used, for example, to archive previous versions of the EMP. Field 5. Objective: The objectives listed here are those that the organization has set for itself with

respect to the environmental aspect that is treated in this EMP. The number of the objective is set by the EMS manager and should remain the same. If the number of the objective changes the EMS manager will notify all program managers via e-mail. (See EMS Procedure for Setting Objectives and Targets for an explanation of what they signify.)

Field 6. Process/Activity: The information recorded here should signify the reason why each impact is

“significant” (e.g., regulation; mission impact; environmental impact). It should provide sufficient detail to inform prospective users on the full consequences of each individual impact. This is valuable insight that underlies the importance of the EMP and should not be assumed to be “obvious” to newcomers that are not familiar with the issue. For example: Noise is a significant aspect because it is regulated and because complaints from the adjoining community could cause a shutdown a major operation at the Depot.


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Field 7. Potential Impacts: These are the potential impacts enumerated through the execution of the EMS Aspects Identification Procedure. Their documentation within the EMP allows for a fuller description of these potential impacts. Field 8. Target: : The targets listed are those that have been set by the organization to achieve the

objectives specified. Once a target has been completed the word completed should follow the target where one would normally identify the target date of completion. Once this completed target has remained for one update it should then be deleted from the EMP. This will insure that a record of compulsion will de documented on the EMP.

Program indicators should be specified for all the targets. Program indicators should have been selected during the setting of objectives and targets while the nature of the objectives and targets are fresh on the minds of the EMO Program Managers. EMP leads should ensure that a complete list of program indicators that correspond to the targets is shown in this field; normally, there is a one-to-one correspondence between them.

Field 9. Legal and Other Requirements: This field contains details on the applicable legal and other

requirements derived through execution of the EMS Procedure on Legal and Other Requirements. These are the legal and other requirements that apply to the Inputs that exhibit the environmental aspect in question. The level of detail for legal and other requirements should be as complete as possible. That detail is necessary if the organization expects to maintain compliance with legal and other requirements. This field should, therefore, list all the detailed legal and other requirements that apply to this environmental aspect for the Inputs listed in field 11 below.

Field 10. Task: This field describes what controls are to be implemented to achieve target goals of the EMP. Field 11. Responsible Party: This field contains the name or names of organizations within PCD that have been given the responsibility to operate or otherwise implement the operational controls. Field 12. Schedule/Resources: This field sets forth the date the target goal is to be achieve and any resources needed. Field 13. Key Characteristics/Performance Criteria: The information in this field of the EMP should be as detailed as necessary to ensure effective control of the Inputs that exhibit the environmental aspect in question so as to prevent that aspect from occurring. Field 14. Approvals: The approving authority for PCD is the EQCC for all EMP’s.


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4.6 PCD EMS Procedure for Addressing Emergency Preparedness and Response 1.0 Purpose and Scope The purpose of this procedure is to describe the process to identify potential emergency situations and potential accidents and how Pueblo Chemical Depot will respond to them, and prevent or mitigate associated adverse environmental impacts. This procedure specifies those EMS requirements that pertain to the environmental consequences of an incident or emergency. It does not address itself to other consequences that may result from an incident or emergency. An incident or emergency involves more than a nonconformity in the EMS or a minor spill or release. For purposes of the EMS, nonconformities and minor spills or releases are corrected through the provisions of Pueblo Chemical Depot Procedure for Nonconformities. 2.0 Definitions For definitions meant to help explain terms used throughout this procedure, see Chapter 1, Section 4. 3.0 Procedure 3.1 General: Despite Pueblo Chemical Depot’s best efforts, incidents and other emergency situations can occur. Effective emergency preparation and response can reduce injuries, prevent or minimize environmental impacts, protect employees and neighbors, reduce asset losses, and minimize mission impacts. Pueblo Chemical Depot has developed numerous plans that address various types of incidents and emergencies. These plans form the basis for Pueblo Chemical Depot emergency preparedness and response actions. The operational requirements that have been implemented to address hazardous substance spills and/or releases are provided in the Pueblo Chemical Depot Installation Spill Contingency Plan (ISCP). Responses to emergencies such as fires, floods, and earthquakes are managed through the National Incident Management System (NIMS) and the Incident Command System (ICS). See below for additional plans. 3.2 Responsibilities: All Pueblo Chemical Depot personnel have a responsibility to prevent and minimize incidents and other emergency situations. Emergency preparedness and response can involve multiple organizations on and off the installation. Specific responsibilities include: EMS Manager: Ensure all appropriate environmental plans (see section 2 .0) are prepared and current, and are maintained in accordance with Pueblo Chemical Depot’s document control procedures. On Scene Coordinator: Has overall responsibility for leading an emergency response action. The On-

Scene-Coordinator will be the Chief, Pueblo Chemical Depot Fire Department. 3.3 Emergency Preparedness: All required plans will be reviewed and updated, as appropriate, at least every 18 months by the plan POC. Plans will be reviewed to ensure they meet all current regulatory requirements and to identify changes on the installation that may affect plan execution. The review should include plan attachments, such as contact names, phone numbers, maps, facility floor plans and material safety data sheets (MSDS). Emergency preparedness procedures will be exercised and tested


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through drills and tests in accordance with regulatory and plan requirements, and to ensure all mitigated actions are considered and implemented. Plans will be readily accessible to potentially affected personnel and hard copies posted in high risk work areas. 3.4 Emergency Response: Responses to all accidents and emergencies will be conducted in accordance with the procedures specified in the applicable response plan. 4.0 Records This procedure generates the following EMS records. Items 1, 2, and 3 will be maintained as part of the plan:

1. Records of incidents and emergencies that can result in environmental consequences; 2. Records of exercises and associated reviews; and 3. Records that indicate changes to the ISCP as a result of exercise reviews.


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4.7 PCD EMS Procedure for Legal and Other Requirements

1. 0 Purpose and Scope The purpose of this procedure is to ensure that appropriate site personnel are aware of all legal and other regulatory requirements that are applicable to the environmental aspects of Pueblo Chemical Depot’s (PCD) Inputs. Information on legal and other regulatory requirements is incorporated into the installation’s environmental management system (EMS) and will be considered, with other factors, to set objectives and targets.

The listed environmental aspects that were documented through the use of PCD’s EMS Procedure for Identifying Significant Environmental Aspects provide the base for identifying the legal and other requirements that are applicable and relevant to PCD’s environmental aspects.


3.0 Procedure

3.1 Identification of Existing Requirements The EMO EMS Program Managers (EPMs) will obtain and review the regulations pertinent to all environmental aspects identified within their area of responsibility. The EPMs may do this by accessing the internet, subscribing to free email notification services, attending periodic training, reading trade or technical journals and environmental newsletters, consulting with other environmental professionals (other installations or private industry), hiring consultants, requesting assistance from colleagues in EMO, or requesting input from the Legal Office on regulatory information associated with aspects. Any of these methods and sources of regulatory information are suitable as long as they provide a high degree of certainty regarding the regulatory implications of each environmental aspect identified by PCD’s EMS Procedure for Identifying Significant Environmental Aspects. Other sources, means and methods for identifying legal and other requirements include, but are not limited to the following: Daily Federal Register or Federal Register Summary, Code of Federal Regulations, Colorado Department of Health and Environment (CDPHE) website, Defense Environmental Information Exchange (DENIX) Web site, Bureau of National Affairs database, and Hazardous Technical Information System Bulletins. Correspondence pertaining to enforcement actions, Notices of Violation (NOVs), consent orders,

and findings from internal compliance audits.

The compiled list of legal and other requirements must be maintained in a format that is readily updatable to allow for the insertion of additional requirements as they are identified. Information compiled must include, at a minimum, the full citation for the requirement identified, where the full text of the requirement can be found for review, and a brief statement addressing specific applicability to the environmental aspects. This information will be maintained in EMPs and in EISIS Database.

3.2 Identification of New and Emerging Requirements


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The EPMs must review the identified legal and other requirements on a regular basis, but at least annually. When legal and other requirements change, the EPMs must notify the EMS Manager. Sources of applicable requirements information that may be relevant in this analysis include:

Publications dedicated to regulatory information and updates such as the Environmental Compliance Alert and the Federal Register;

Periodic contact with state and local regulatory officials; Consultation with external regulatory compliance experts that provide professional services to

the location; Periodic attendance at environmental training courses that include regulatory updates and

compliance issues; Identifying local requirements through locally mandated permits; and Consultation with site management and headquarters staff on new or revised requirements that

may apply to site operations.

Timely notification of changes is necessary to ensure continuous compliance with legal and other requirements these changes must also be supplied to the EMS Manager.

Updates to legal and other requirements will then be used to continually improve relevant parts of the EMS, particularly the relevant EMPs.

3.3 Applicability to Pueblo Chemical Depot’s Environmental Aspects Once the baseline of existing legal and other requirements has been established they will be integrated into the EMS when determining the significance of PCD’s environmental aspects, during the establishment of objectives and targets for the EMS, and through their inclusion in Environmental Management Plans (EMPs) designed to achieve those objectives and targets. The identification of the legal and other requirements will also be used to help ensure that PCD operations maintain compliance to those requirements.

4.0 Records The EMS Manual will contain a current list of legal and other requirements and their associated aspects.


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4.8 PCD EMS Procedure for Monitoring and Measurement

1. 0 Purpose and Scope This procedure outlines the process for monitoring and measuring the key characteristics of PCD operations that may have significant impacts on the environment. Monitoring and measuring ensures that PCD is meeting its environmental policy, objectives, and targets through the EMS.


3.0 Procedure Monitoring and measuring of key characteristics and environmental performance associated with significant aspects will be specified in the Environmental Management Programs (EMPs) as Program Indicators.

3.1 Roles and Responsibilities: 3.1.1 Environmental Program Manager (EPMs): Each EPM will verify performance in meeting environmental objectives and targets through the monitoring and measurement of specified program indicators. In addition, EPMs are responsible for evaluating the results of the monitoring and measuring efforts, and track how well objectives and targets are being met. Periodically, EPMs will tabulate monitoring and measuring data on progress for assigned objectives. Progress reports will be distributed to management, as appropriate, to ensure oversight and accountability.

3.1.2 Management Review of Program Data: Management will review the reports and meet with the EPM or other appropriate personnel if nonconformities are found or progress is falling significantly behind schedule.

3.2 Utilization of EMS Performance Data – All information collected from the monitoring and measuring of progress in attaining the objectives and targets of the EMS is a required input into the periodic EMS Management Review by top management. The effectiveness of the EMS is in large measure determined by its effectiveness in meeting the objectives and targets.

3.3 Establishing Indicators and Baselines 3.3.1 Selection of Program Indicators – Program Indicators are selected as part of establishing Environmental Management Programs (EMPs) for significant aspects. They are selected for the objectives and targets in the EMP and for any other objectives and targets specified in the EMS. The indicators allow the organization to measure progress towards the attainment of objectives and targets.

Other factors to consider when selecting indicators for regulatory targets are the provisions in regulations that often specify the unit of measure that needs to be monitored and/or controlled for the given environmental aspect. For example, air emissions may include particulates and volatile organic compounds and can be measured by volume, concentration, and periodicity; recyclables


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can be measured by weight, volume, or value; hazardous waste can be measured by toxicity, corrosiveness, flammability, combustibility, weight, etc.

Examples of indicators for the EMS system itself may include: The percentage of employees that have not received awareness training; the time lapse from finding a nonconformance to implementing corrective action; the number of employees that have received competency training relative to their responsibilities with respect to significant aspects.

3.3.2 Establishing Baselines – Having selected the program indicators, a typical first step is to

establish performance baselines in order to measure progress from a specific starting point. Baselines may not be appropriate for some objectives and targets where, due to the nature of the Input, measurement over time may not be indicative of meaningful progress.

3.3.3 Measuring Indicators – Each identified indicator must also include the methods to be

employed to monitor and measure that indicator so as to track progress. For example, if temperature is the indicator, the technological measurement method could be a thermometer, and the procedural methods would be the frequency of measurements or location of measurements. It is also important to specify the records that will be created with this information and where and for how long such records will be kept.

4.0 Records This procedure will generate the following records:

Records of baselines for objectives and targets of the EMS; Data records of ongoing or periodic measurement and monitoring, as appropriate; List of instruments used for monitoring and measurement of EMS program indicators that

require periodic calibration; Records of calibration instructions; and Records of actual calibrations (when and by whom)

Refer to PCD’s EMS Procedure for Documentation and Records Management for further details on document retention.


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4.9 PCD EMS Procedure for EMS Management Review

1.0 Purpose and Scope This procedure is implemented at PCD as a guideline for the periodic management reviews of the installation’s Environmental Management System (EMS). Implementation of this EMS procedure will ensure the periodic review of the EMS for its continued suitability, adequacy, and effectiveness. Additionally periodic management reviews will address the need for modifications to policy, objectives and targets, and other elements of the EMS.


3.0 Procedure The management review of PCD’s EMS will be conducted on an annual basis, as part of the EQCCl, unless circumstances warrant a more frequent review. The review will cover key elements of the EMS and will include necessary and sufficient information for management to make informed decisions on whether the EMS continues to be suitable, adequate and effective for its intended purposes, and for taking decisions or authorizing actions that need to be taken by PCD personnel to ensure the continual improvement of one or more of its elements.

3.1 Participant Roles and Responsibilities PCD’s Depot Commander, or in his absence a designee, will serve as the Chairperson for the

Management Review.

EMS Manager is responsible for coordinating and scheduling meetings with appropriate personnel to review PCD’s EMS.

Third Parties: Any interested third parties not directly involved in the EMS review (e.g., PCAPP) may be invited by the Director of EMO if their presence is relevant.

3.2 Contents of the Management Review: At a minimum, the following items will be discussed during the EMS management review:

Results from recently completed EMS audits;

Communication from external interested parties to include complaints received;

Status report on the progress of attaining objectives and targets (refer to the EMS Procedure for Objectives and Targets);

Status of regulatory compliance;

Status of corrective and preventive actions to include information on violations received since the last EMS review;

Status of action items from previous EMS management reviews;

Developments in legal and other regulatory requirements (refer to the EMS Procedure for Legal and Other Requirements) related to PCD’s environmental aspects (refer to the EMS Procedure for Identifying Significant Environmental Aspects); and


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Recommendations for improvement of the EMS. In addition, the EMS management review will evaluate the need to change the environmental policy, objectives and targets, and other elements of the EMS due to the following:

Changes in mission;

Addition of new facilities;

Changes in expectations and requirements of interested parties;

Changes in the Inputs of the installation;

Advances in science or technology;

Lessons learned from environmental incidents or emergency response; and

Changes in reporting and communication structures within the installation.

3.3 Results of the Management Review Results of the management review will include:

The identification of areas of opportunity for continual improvement of the EMS that lead to improved environmental performance;

The identification of the root cause(s) of nonconformance or deficiencies;

Management approval for new corrective and preventative action plans or concurrence that existing plans continue to be adequate and effective;

Identification of procedural changes resulting from process improvement; and

The identification of needed changes to the environmental policy, objectives and targets or other elements of the EMS.

4.0 Records Records generated by this procedure will be maintained by EMO include:

Minutes or notes of the management review that cover the attendance, the information that was presented, the determinations made, and the decisions taken; and

Records of follow-up actions initiated and completed to give effect to top management decisions taken in the review.


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4.10 PCD EMS Procedure for Nonconformity, Corrective and Preventive action

1.0 Purpose and Scope The purpose of this procedure is to describe the process to identify actual and potential nonconformities and specify a process to make corrective and preventive actions. Implementation of this EMS procedure will ensure that nonconformities are addressed in a timely manner, corrective and/or preventive actions are taken, and investigations are conducted to determine their cause so as to avoid their recurrence.


3.0 Procedure 3.1 General: Potential or actual nonconformities can be identified from audits and other reviews; from findings, conclusions, and recommendations reached as a result of measuring and monitoring; from accidents or spills; from employee observations or comments; and from changes to Pueblo Chemical Depot mission, Inputs, or structure. Typical causes of nonconformities include poor communication, faulty or missing procedures, equipment malfunctions, lack of training, lack of understanding of requirements or procedures, failure to enforce rules or procedures, and corrective actions that fail to address root causes of problems.

3.2 Responsibilities: The EMO Director has the overall oversight responsibility to ensure nonconformities of the EMS are corrected and actions are taken to avoid their recurrence.

3.3 Correcting and/or Preventing Actions: 3.3.1 Whenever a nonconformance in the EMS is detected it will be reported to the EMS Manager

for documentation and follow-up.

3.3.2 The EMS Manager assigns the Nonconformity to the appropriate Environmental Program Manager for investigation and resolution.

3.3.3 The Environmental Program Manager confers with the affected operational management to investigate the root cause, develop appropriate corrective and preventive actions, and oversee implementation of those actions, as appropriate.

3.3.4 The EMS Manager approves or rejects the completion of the corrective and preventive actions of internal reported nonconformances. Nonconformances identified by external parties will be approved or rejected by the EMO Director.

4.0 Records Records generated by this procedure include the following and are maintained by EMO:

Records that list the instances of nonconformances of the EMS, the date of occurrence, date of corrective action, and date of completion of preventive action;

Records that reflect the analysis of the nonconformance, and the corrective and preventive actions that were taken with respect to it; and


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Records of changes made to any of the EMS procedure(s) as a result of implementing corrective and preventive actions.


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4.11 PCD E MS Procedure for Setting Objectives and Targets

1.0 Purpose and Scope The purpose of this procedure is to outline how PCD provides a consistent means for developing EMS objectives, targets and program indicators. Objectives and targets will be established to address the significant environmental aspects identified at PCD and must adequately address compliance with the legal and other requirements.

The objectives and targets established with this EMS procedure extend to all levels and functions of the organization(s) where they are applicable.

A list of Objectives is provided as Appendix A.


3.0 Procedure The EMO Environmental Program Managers will propose objectives and targets for the significant environmental aspects identified at PCD. They will also establish the program indicators necessary to measure achievements associated with the objectives and targets. Once the objectives, targets and program indicators are set, they will be reviewed by EMS Manager and the EMO Director.

Environmental Program Managers will develop objectives and targets to define: The performance objectives (e.g., monitor, study, control or improve) for the significant

environmental aspects; The specific, quantified targets which particularize those performance objectives; and The planned schedule for achieving targets.

Whenever possible, objectives will be set in measurable terms with specific time frames for their accomplishment to facilitate performance monitoring and trends analysis. Objectives for significant environmental aspects should be set irrespective of their suitability for measurement. In most cases, it is appropriate to establish a baseline against which to measure progress and as such the first cycle of measurements will act as a baseline against which to quantify future performance.

Objectives and targets will be integrated into Environmental Management Programs (EMPs) that are developed and implemented to stimulate action within individual units, departments or across all operations within the scope of the EMS. Development of objectives and targets take into account:

Pueblo Chemical Depot Environmental Policy; Identified significant aspects; Legal and other requirements; Views of interested parties; Mission requirements PCD’s sustainability goals; Pollution prevention goals; Achievement of continual improvement of the EMS; Technological options;


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Financial, operational, and organizational requirements; and The Installation Master Plan

Objectives and targets will be included in the EMP documentation, and are also summarized in a listing that is compiled and maintained by the installation’s EMS Manager, or his designee.

PCD will establish program indicators (measures) when setting objectives and targets, and will include these within the EMP documentation. Program indicators will be set for all targets and for objectives when that is appropriate. These may include indicators for environmental performance, compliance, pollution prevention, and/or other elements of the EMS for which objectives and targets have been established. Program indicators will be tracked as part of the EMPs to ensure that objectives and targets are on track for attainment within their specified timeframes.

When setting objectives and targets, Program Managers shall obtain estimates for the additional resources needed for their achievement. Management shall apply financial, operational, and organizational considerations when approving the recommended objectives and targets.

4.0 Records Records that pertain to the setting of objectives and targets for the installation’s EMS will be maintained electronically and will be readily available to Depot management. Records will include, but will not be limited to:

1. The final approved list of objectives for the installation’s EMS ( in EMS Manual);

2. The documented views of interested parties, if applicable;

3. Accomplishment of objectives and targets (in EISIS Database); and

4. Information on additional resources needed to achieve the objectives and targets.

Refer to PCD’s EMS Procedure for Documentation and Records Management for further details on document retention.


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Attachment A

Objective List

1. To maintain compliance with all applicable legal, regulatory and other requirements. 2. Maintain a self sustaining forestry, wildlife, and land management program (income and sustainable management practices) in accordance with INRMP. 3. Provide assistance and support to the P2 program to evaluate P2 opportunities and to implement those that have been approved for implementation. 4. To create operational controls for identified Inputs that are to be included in SOP. 5. To improve the flow of information in relation to facility maintenance activities or any other activities where asbestos may be encountered. 6. To evaluate energy saving opportunities to reach a goal of 30% reduction by 2015. 7. To evaluate water conservation opportunities to reach a goal of 16% reduction by 2015. 8. Continue to encourage community outreach programs. 9. Control Public health pests, structural damage from pests, and undesirable vegetation.


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4.12 PCD EMS Procedure for the Control of Records

1. 0 Purpose and Scope The purpose of this procedure is to describe the process for managing records that document Pueblo Chemical Depot’s EMS operations and performance.

2.0 Definition

For definitions meant to help explain terms used throughout this procedure, see Chapter 1, Section 4.

3.0 Procedure 3.1 General: Records demonstrate the ongoing operation of Pueblo Chemical Depot’s EMS and its conformance to arrangements specified in the EMS. Records also allow Pueblo Chemical Depot to track its progress in meeting its objectives, targets and overall management performance. Environmental records must:

be legible, identifiable and traceable to the Input, product or service involved be stored and maintained so that they are readily retrievable and protected against damage,

deterioration or loss have established and recorded retention times

3.2 Responsibilities: Environmental Management Office Director – The PCD EMO Director will:

a. Appoint in writing a Record Control Officer. b. Approve all record retention times.

Environmental Program Managers - Pueblo Chemical Depot’s Environmental Program Managers have the overall responsibility for the identification, storage, protection, retrieval, retention, and disposal of Pueblo Chemical Depot’s EMS records related to their programs. Records Control Officer – The Records Control Officer will ensure that EMS and Quality records are being maintained in accordance with appropriate procedures. 3.3 Record Identification and Storage: Each program manager will identify records that are required for their programs. The EMS Manager will maintain records that result from EMS Procedures that are not covered under any of the EMPs. Other EMS records not related to EMPs will be maintained by the EMS Manager or his designee. 3.4 Record Retrieval: Requests for program specific records should be routed through the appropriate Environmental Program Manager. Other EMS records that are maintained on the Pueblo Chemical Depot intranet web site may be reviewed and retrieved by any Pueblo Chemical Depot personnel with access to the system. 3.5 Record Review: Environmental Program Managers will review records and discard those no longer needed in accordance with the records retention and disposal section of the procedure. Records maintained on the EMS web site will be reviewed on an annual basis to determine if they are still appropriate to retain.

3.6 Record Retention and Disposal: A record is a permanent document that typically will not be revised. However, new records are normally generated for EMS operations and activities (e.g., new


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audit reports). Pueblo Chemical Depot’s EMS Manager or Environmental Program Managers will decide which records to retain or archive, and which records can be disposed. In many cases the duration a record should be retained may be governed by a regulatory or legal requirement. Where necessary or prudent, Environmental Program Managers should coordinate with PCD’s Legal Office to ascertain safe retention periods.


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4.13 PCD EMS Procedure for Competency Training

1.0 Purpose and Scope The purpose of this procedure is to provide guidelines for the conduct of periodic environmental awareness and competence training (as required) of all personnel at Pueblo Chemical Depot (PCD). Such training is the foundation for personnel awareness, involvement, and commitment to environmental protection as an ongoing responsibility of work life. It is fundamental to the efficient and effective implementation and execution of the PCD EMS. To further the EMS, PCD will periodically conduct both General Environmental Awareness and Competence Training:

1. All PCD personnel, whether or not they are associated with significant environmental aspects, shall receive General Environmental Awareness Training.

2. Competence Training is provided, as necessary, to ensure proficiency of personnel whose work may create or contribute to a significant environmental impact.


3.0 Approach 3.1 General Environmental Awareness Training – The objectives of general environmental

awareness training is to make all appropriate PCD personnel aware of: a. The importance of conformance with the PCD Environmental Policy and procedures, and

with the requirements of the EMS; b. Their roles and responsibilities in achieving conformance with the Environmental Policy

and procedures and with the requirements of the EMS; and c. The potential consequences of departure from specified operating procedures; d. Their responsibility to report spills or other releases; and e. Their responsibility to report nonconformities or suggested improvements to the EMS.

General Environmental Awareness Training will be conducted for all personnel as part of the initiation of the EMS. New employees will receive awareness training as part of the new employee orientation training. Periodically, all employees will receive refresher awareness training that reemphasizes the above stated elements. General Environmental Awareness Training will be provided during the course of EMS development and implementation at appropriate times to the groups represented in attachment A below.

3.2 Competence Training – PCD will identify significant environmental aspects according to PCD’s EMS Procedure for Identifying Significant Environmental Aspects and Impacts. Following this, the Inputs that have the potential to cause a significant environmental impact will be identified and documented accordingly.

The Environmental SOP’s will be provided to the appropriate areas. Division Directors will be responsible for understanding and training their personnel on their responsibilities.


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Personnel that perform tasks that can cause significant environmental impacts shall be competent on the basis of appropriate education, training, and/or experience. Such personnel shall receive competence training when it is determined that it is required to address the significant environmental aspect(s) that are associated with their work assignments. Such Competence Training will include:

a. Environmental training required by applicable regulatory requirements

b. The significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance;

c. Their roles and responsibilities in achieving conformance with the Environmental Policy and procedures, and with the requirements of the EMS, including emergency preparedness and response requirements. Specific objectives and targets related to their work activities

d. The potential consequences of departure from specified operating procedures;

Declaration of competence for personnel named in the Environmental Management Programs (EMPs) shall be documented in each EMP. Where competence training is indicated as the reason for such declaration, a reference to that training should be provided. Supervisors will maintain training records to provide evidentiary proof of such training. (Note: In many cases, Competence Training will be satisfied by existing Health and Safety training required by OSHA and/or environmental regulations.) When competence training is required, it will be conducted before the individual begins an assigned function that has the potential to have a serious environmental impact. Such Competence Training could include formal training or on the job training. It is the responsibility of the immediate supervisor to ensure that the individual has appropriate competence.

Contractors whose work may cause a significant environmental impact and that work at PCD for more than six months will be identified and required competency training for those individuals that need such training.

4.0 Records Records that pertain to competency training for the installation’s EMS will be maintained either in hard copy or electronically and will be readily available to management. Records will include, but will not be limited to:

1. Awareness training documentation (mechanisms used for training dissemination); 2. The contents of the awareness training; 3. Competence training records (date and attendance); and 4. The contents of competence training.


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Attachment A

Required Training for Appropriate PCD Groups

Group Required Training EMS Program Manager EMS Orientation Training

EMS Lead Auditor Training Organizational Leadership Training

Director Environmental Management Office

EMS Orientation Training

Environmental Program Managers

EMS Orientation Training EMS General Environmental Awareness Training

EMS Internal Auditors EMS Auditor Training (at least one Lead) Top Management EMS Orientation training All Employees EMS General Environmental Awareness

Competence Training, if appropriate Long Term Contractors (> 6 months or $ amount of contract)

Same as "all employees"

Tenants (covered by the scope) Same as "all employees" Short Term Contractors (< 6 months) Competence Training, if appropriate


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5. EMS Records 1. Introduction This chapter references the records of actions completed under the EMS, including carrying out the procedures. For example, these should include records of having identified significant aspects, delivered training, and conducted EMS audits. 2. Records/References

a. Records of the process of identifying significant aspects are located in the PCD Input/Aspect spreadsheets. These are in the office of the EMS Coordinator in the EMO.

b. The location of records that are a result of the execution of specific operational controls is

described in each operational control document (see Chapter 5). c. Records related to EMS awareness training attendance within each PCD organization are

maintained by that organization. d. Records pertaining to EMS internal and external audits are located in the office of the EMS

Coordinator.