Appendix J
Unit Environmental Standing Operating Procedures
This appendix provides an example of an Army unit environmental SOP, outlining the command environmental program within a unit. Unit environmental SOPs are described in figure J-1, page J-2. Figure J-2, page J-16; figure J-3, page J-18; and figure J-4, page J-20, further detail specific unit SOPs. Due to differing state, local, or foreign nation requirements, these SOPs must be modified based on consultation with unit higher headquarters and the installation/base camp environmental staff. This sample unit environmental SOP is divided into six sections (maintenance, supply, CBRN, communication, field mess operations, and operations/training), which correspond to a typical unit organization. Units should extract the information in these sections and incorporate them into the appropriate section of their SOP. Alternatively, a unit may use these samples as a guide to developing a stand-alone environmental SOP. While this approach elevates the visibility and importance of environmental issues and procedures, unit personnel in specific functional areas may overlook the information without adequate command emphasis. The environmental SOP should reflect requirements as they pertain to the unit's daily operations (such as installation or state regulations) and reflect requirements that may be in effect during deployments. The SOP should emphasize sustainable practices and the integration of environmental considerations into daily operations and should be flexible enough to accommodate both garrison and deployment environmental considerations. Additional information for specific requirements during deployments can be found in the mission OPORD/OPLAN or specific base camp SOPs.
APPENDIX TO ANNEX ENVIRONMENTAL STANDING OPERATING PROCEDURES
Unit Designation Mailing Address Date
1. References.
Installation Environmental SOP, Higher Headquarters Environmental SOP, and AR 200-1.
2. Purpose.
a. This appendix standardizes procedures for environmental compliance with federal, state, local, and HN laws and regulations. Failure to comply may result in the following:
(1) Endangerment of personnel health and safety.
(2) Citations by federal and state regulating agencies. (3) Civil or military penalties against offenders.
(4) Delay or halt in mission accomplishment.
b. This appendix is applicable to all assigned or attached personnel and governs the environmental aspects of all unit activities.
3. Responsibilities.
a. The commander-
(1) Establishes a unit HM and HW management policy.
(2) Ensures that personnel comply with the provisions of referenced SOPs, regulations, and public law.
(3) Ensures that the environmental compliance officer, the HM/HW coordinator, and senior personnel have received the proper training and that they, in turn, train their subordinates.
(4) Ensures that all personnel who are exposed to HM in the course of their work receive initial training within 90 days of assignment concerning the hazards to which they are exposed and the precautions required to protect themselves in the work environment. These personnel must also receive annual refresher training.
(5) Ensures that all unit personnel receive initial environmental awareness training within 90 days of assignment and refresher training annually thereafter.
(6) Ensures that all unit personnel have received HAZCOM training (OSHA requirement).
(7) Ensures that all environmental training is properly documented and records are filed in the unit operations/training office.
(8) Ensures that a self-inspection program is in effect for the unit. b. The executive officer-
(1) Serves as the commander's eyes and ears for environmental matters.
(2) Conducts periodic unit self-assessment surveys.
(3) Overses environmental integration into staff operations.
Figure J·1. Unit environmental SOP
c. The ECO and HW/HM (MOS 9954) Marine-
(1) Provides advice on environmental compliance to the commander.
(2) Serves as a link between the unit commander and higher/installation headquarters environmental staff.
(3) Performs other duties as outlined in chapter 1 of this manual. d. The maintenance officer-
(1) Serves as the unit's HM/HW coordinator.
(2) Serves as the unit's spill response coordinator. (3) Ensures accountability for all HM and HW.
(4) Ensures that HM and HW are stored and disposed of properly.
(5) Ensures that HM and HW spills are immediately contained and reported to the fire department and the installation's environmental office.
(6) Reports nonfunctional/inoperative treatment/collection facilities (oil/grease interceptors, floor drains, catch basins, and waste tanks) to the installation's environmental office via the unit's environmental compliance officer.
e. The motor sergeant-
(1) Establishes and maintains an HW accumulation (HW less than 55 gallons) area with proper separation of incompatible products.
(2) Inspects HW accumulation areas weekly and documents results.
(3) Ensures that leaking containers are overpacked and/or the uncontaminated contents containerized in functional containers.
(4) Ensures that only waste oil is placed in the waste oil tank or drums.
(5) Ensures that the waste oil tank or drums are pumped out when full or 90 days after previous pumping, whichever occurs first (check with installation environmental coordinator).
(6) Ensures that the wash rack oil/water separator is clean and serviceable.
(7) Maintains an inventory log of all stored waste products, to include exact location of each container.
(8) Labels all HW containers properly as they are put in service and ensures turn-in and delivery to the DRMO or contractor and pick up within 90 days of accumulation start date (coordinate with the environmental management office).
f. The unit supply sergeant-
(1) Initiates and processes turn-in documents for the turn-in of HM and HW.
(2) Maintains a suspense file and validates receipt copies of turn-in documents for all scrap, HM, and HW shipped to the DRMO.
g. The prescribed load list clerk-requisitions mercury and lithium batteries with recoverability code "A" only upon turn-in of a like item and quantity.
h. The CBRN NCO-
(1) Inspects all possible decontaminant solution 2 (DS2) and super tropical bleach (STB) accumulation sites (CONEXes, wall lockers, and POL accumulation area) to ensure that these products have been properly turned over to DOL/supply for consolidated storage.
(2) If the unit is temporarily in possession of decontamination agents DS2 or STB:
(a) Ensures that DS2 and STB are stored in separate locations.
Figure J·1. Unit environmental SOP (continued)
(b) Inspects containers monthly for leakage, and records results. Arranges for leakers to be overpacked and turned in to the DRMO.
(3) Properly disposes of CBRNE-related training material that is classified as hazardous according to installation directives and DRMO policies.
i. Mechanics-
(1) Place HW in properly designated containers.
(2) Never place HW in a dumpster; this is an illegal disposal.
(3) Promptly report leaks/spills to the motor sergeant and/or maintenance officer. Report spills directly to the fire department and installation's environmental office, if necessary, to ensure prompt response.
(4) Wear proper protective clothing when handling HM or HW.
(5) Keep HM and HW accumulation containers closed except to add or remove product.
j. Medics-
(1) Segregate medical waste from nonmedical waste at the point of generation. (2) Place medical waste in designated containers.
(3) Wear proper protective clothing when handling medical waste. (4) Store collected medical waste in a secure manner/area.
k. Individual Soldiers and Marines-
(1) Comply with the unit's environmental requirements and the installation's SOP. (2) Maintain environmental awareness throughout daily activities.
(3) Provide recommendations to the chain of command on techniques to ensure compliance with environmental regulatory requirements.
(4) Identify the environmental risks associated with individual and team tasks. (5) Support recycling programs.
(6) Report HM and HW spills immediately to (phone number for spill reporting).
(7) Make sound environmental decisions in the absence of a supervisor or specific command guidance by considering the following:
(a) Prior training.
(b) General guidance from the chain of command. (c) Concept of right and wrong.
(d) Common sense.
(e) Environmental ethic.
Figure J·1. Unit environmental SOP (continued)
4. Safety.
a. Material Safety Data Sheet. MSDSs provide critical information for safeguarding human health and protecting the environment. This information includes the hazardous characteristics of the substance, the appropriate PPE, spill response procedures, signs and symptoms of overexposure, and first aid procedures. MSDSs can be obtained through unit supply channels and should be maintained at each location where HM is being used. It is important to note that MSDSs are material- and manufacturer- specific, which means that each brand name of a chemical has a different MSDS.
b. PPE. PPE is the primary means of safeguarding human health when handling HM/HW. The most important aspect when choosing the appropriate PPE for a given operation is the hazardous characteristics of the substance. Always refer to the manufacturer's MSDS before choosing the appropriate PPE. If the prescribed PPE cannot be obtained during a field or contingency operation, field-expedient PPE should be used to help protect Soldiers and Marines when handling HM/HW or in the event of a spill. Leaders ensure that their Soldiers and Marines have the appropriate PPE when exposed to HM/HW during handling. Recommended field-expedient PPE is listed below:
HM/HW stream Field-expedient PPE
1.Fuel products 1.Field gloves, goggles, and wet-weather gear
2.Oil products/lubricants 2.Field gloves and goggles
3.Antifreeze 3.Field gloves and goggles
4.Acid batteries 4.Double-lined field gloves, goggles, and wet-weather gear
5.Medical waste 5.Field gloves, goggles, and wet-weather gear
6.Pesticides 6.Consult the MSDS and Preventive Medicine
NOTE: Field-expedient PPE should only be used when the required PPE is not available since it does not provide the level of protection recommended by the manufacturer. Additionally, field-expedient PPE that is used to handle HM/HW should not be used for normal operations after being used as PPE.
Figure J·1. Unit environmental SOP (continued)
SECTION 1 · MAINTENANCE
1. General.
a. Select maintenance activity sites so that POL-contaminated water will not enter a storm drain.
b. Conduct the following activities daily:
(1) Check the level of used oil in storage tanks. Schedule for tanks to be picked up when 3/4 full.
(2) Clean all foreign material from drip pans and aboveground oil tank screens. (3) Empty refuse barrels when 3/4 full to prevent overflows.
c. Procure, store, and use only those chemical products specifically authorized by the appropriate TM or lubrication order for the level of maintenance performed.
d. Keep MSDSs for all chemicals/solvents/materials used in work areas in a file that is readily accessible to personnel who work there. Brief personnel on chemical hazards, protective clothing requirements, first aid, and spill response before they use hazardous chemicals.
e. Use products that are safe and biodegradable, when possible.
f. Comply with the Army's oil analysis program as a method of reducing the amount of waste oil produced.
g. Properly label, segregate, and store HM.
2. Maintenance Bays.
a. Conduct maintenance washing/steam cleaning at the motor pool wash rack-not in the maintenance bay. (Maintenance cleaning in the bays will be authorized only during extended, below freezing temperatures that interfere with the vehicle maintenance mission [applicable only if equipped with an oil/water separator].)
b. Do not wash heavily soiled and/or oily maintenance bay floors with solvent or other unauthorized material. Clean up oil and fuel with dry sweep or rags only. Collect dry sweep and dirt in nonleaking containers as HW for disposal through the DRMO.
c. Confine solvent use to solvent washing machines that meet the National Fire Prevention Association's safety regulation standards. Obtain approval for use of solvents, other than mineral spirits, from the installation's environmental office before use.
d. Ensure that all solvent washing machines have lids that remain closed when not in use.
e. Do not sweep or dump trash, garbage, nuts, bolts, and other solid waste into floor drains or mix with used dry sweep. Put such items into covered, leak-proof containers. Empty containers into dumpsters, as needed, to prevent spillover.
f. Place drip pans under points of leakage on vehicles with known seeps and leaks to preclude discharges into wastewater collection systems. Drain all water from drip pans daily and dispose into a sanitary sewer drain protected by an oil separator.
g. Use the exhaust ventilation system whenever a stationary vehicle is running inside the maintenance bay.
h. Keep catch buckets in all floor drains that are designed for them. Inspect and empty dry sweep and trash daily. In bays not equipped with oil-water separators, keep floor drains permanently closed if HM/HW are handled or stored there.
i. Use the exhaust ventilation system whenever a stationary vehicle is running inside the maintenance bay.
3. Grease Racks/Pits.
a. Use approved used oil tanks to collect and subsequently recycle used oil. (Grease racks and maintenance or inspection pits are designed for oil change and vehicle lubrication only.)
b. Introduce only uncontaminated used motor oil into the used oil tanks. Use separate containers for hydraulic, transmission, and brake fluids. Do not place solvent, fuel, water, antifreeze, dirt, dry sweep, hardware, or trash in used oil tanks.
c. Dispose of used oil, transmission, and fuel filters in normal trash containers after draining for
24 hours and double bagging in plastic. (Units/installations should purchase equipment for pressing oil from filters and then recycling the metal.)
d. Mark and position containers for new and used dry sweep at the grease rack to clean up spills or leaks.
e. Keep floor of the grease rack and the immediate surrounding area free of POL buildup.
4. Wash Racks.
a. Use wash racks for light exterior washing only. Wash extremely soiled vehicles at the installation's central vehicle wash facilities.
b. Obtain authorization from the installation's environmental office for cleaners used in washing activities, since cleaners will drain into the sanitary sewer. Post readable signs to indicate specific, authorized cleaners, solvents, or soaps.
c. Do not use portable steam cleaners or clean engines at wash racks. These activities cause the oil to suspend in the water and the separator to function improperly. Only use steam cleaners in designated areas.
d. Do not pour POL products, solvents, antifreeze, or other regulated substances into wash rack drains.
e. Position trash containers at wash racks for disposal of refuse generated during the washing process.
f. Do not sweep dirt and trash resulting from washing vehicles into the wash rack or pile trash along the perimeter. Place trash in proper containers for disposal at the landfill. Report quantities of dirt in excess of what can reasonably be placed in a trash container to the installation for disposal.
g. To prevent pooling and possible discharge into storm drains, immediately discontinue washing if a wash rack drain becomes clogged. Notify a supervisor to call in a work order request immediately. Maintain wash rack as "out of service" until all necessary repairs are made.
h. The motor sergeant will do the following on a daily basis:
(1) Check for leaking water hydrants and report leaks to the DPW or facility engineer work order desk.
(2) Check for proper policing of the wash rack, and ensure that the area is free of trash, oil-soaked rags, and soil/sand.
(3) Inspect drains and sand traps to ensure proper operation of the wash rack drainage system. Call the DPW work order section if plugged.
(4) Inspect oil-water separator for proper operation.
5. Parts/Material Requisitioning and Storage Areas.
a. Requisition the minimum quantity required for mission accomplishment.
b. Ensure that recoverability codes are used whenever applicable.
c. Keep a copy of the applicable MSDS for each HM on hand in a binder in the parts storage area.
d. Label and segregate all HM from nonhazardous items.
e. Make special indications for any materials that have shelf life considerations.
f. Consider alternative, nonhazardous substitutes whenever processing a request for HM. Check with the installation's environmental office for suggestions.
6. POL Storage Areas.
a. Store all POL products with secondary containment. Construct berms 1 1/2 times the volume of the largest container ("must contain the contents of the single largest tank plus sufficient freeboard for precipitation") stored in the storage area to preclude spillage outside the immediate area. Obtain exceptions to this policy from the installation's environmental office.
b. Store all HM in a location protected from the elements to maintain container integrity (to prevent rusting and protect labels from fading).
c. Inspect containers and labels weekly for leaks and incomplete/unreadable or out-of-date labels. Stop leaks in containers (overpack the container or place the contents in a nonleaking container). Maintain legible labels to reflect actual container contents.
d. Maintain an inventory of POL products. Keep MSDSs on hand for any HM present. e. Use POL and other HM stock on a first-in, first-out basis.
f. Do not tip a drum on its side to issue POL products outside the POL storage area. Use transfer pumps (preferred method) for dispensing POL products.
g. Place a drip box or pan under the supply valve when the drum is tipped on its side. Line boxes and pans with absorbent pads and maintain on a regular basis. Clean up spillage immediately using dry sweep in areas with concrete floors.
h. Immediately report spills of any quantity that enter the environment (soil, water, or drain) to the unit's environmental compliance officer and the appropriate installation officials. (See tab A.)
i. Keep used oil free of contamination (water, dry sweep, hardware, trash, solvent, antifreeze), and store only in approved used oil aboveground storage tanks.
j. Use separate containers to store used brake fluid, solvents, and hydraulic and transmission oils. (Should mixing of waste streams occur, the product becomes "waste contaminated with an unknown substance" and will require analysis by the DRMO before disposal.)
k. Contact DRMO for pumping or turn-in, whichever applies, when used oil tanks/barrels are 3/4 full. (Units may be required to go through the installation's environmental management office, who will contact the DRMO.)
l. Discontinue accumulation of used oils if leaks in storage containers are detected. Immediately report leaks to the unit environmental compliance officer and the installation environmental management office.
m. Obtain approved containers from the DRMO for proper disposal of contaminated dry sweep and other accumulated HW. Clearly mark containers for proper waste disposal.
n. Dispose of used filters for oil, transmission, and fuel as normal trash after draining for 24 hours and double bagging in plastic. (Units/installations should investigate equipment for pressing oil from filters and then recycling the metal.)
o. Permanently close all floor drains in maintenance areas where HM/HW are handled or stored and provide for secondary-containment, single-wall containers. Do not store HM near sanitary or storm sewer drains. Immediately report any amount of POL spillage entering a floor or storm drain to the unit's environmental compliance officer and the installation's environmental management office.
p. Place each HM container of 5 gallons or more accumulation capacity in a POL shed or portable secondary-containment device. (If these storage means are not available, the storage area will be bermed to contain 1 1/2 times the largest container volume in the event of a spill.)
7. Fuel Dispensing and Storage Area.
a. Two personnel perform the operation when filling any size container with fuel-one will run the pump, and the other will dispense the fuel. This procedure provides adequate manpower, to monitor the pump for leaks and shut off the pump in case of an emergency. It also prevents overfilling the container.
b. Handle fuel contaminated with dirt and water as HW, and dispose through the DRMO.
c. Dispose of oil-contaminated fuel, as a result of fuel cell leaks or other mechanical system failure, as HW through DRMO.
d. Contact the direct support unit for assistance and guidance if tankers or fuel pods must be purged.
8. Procedures for Accumulation Site.
Provide accumulation sites for used petroleum products and HW. Place sites aboveground on a nonpermeable, bermed hardstand; label them; and locate them 50 feet or more from any building. Leaking, corroded, or otherwise deteriorated containers must be overpacked in DOT-approved drums. Coordinate with the installation environmental management office for assistance in determining the appropriate overpack containers, labeling/marking requirements, arranging for pick up of used oil, and other HW/HM collection issues.
a. Keep an accumulation log for each used oil or HW container in use. Specify as follows: (1) Contents.
(2) Date the container was opened.
(3) Date and quantity of each addition to the container. (4) Name of person adding to the container.
(5) Date container is filled or closed.
(6) Date the container is removed by DRMO.
b. Store used oil and HW according to installation guidelines.
(1) Place all accumulation of HW on a nonpermeable bermed hardstand. (2) Label and locate the stand 50 feet or more from any building.
(3) Protect the accumulated HW from the elements, including heat and cold.
(4) Provide an enclosure to keep containers free from obscuring snow cover to allow for routine visual inspections in areas prone to heavy snowfall.
(5) Store used greases, solvents, brake fluids, hydraulic fluid, motor oil, and antifreeze in separate containers.
(6) Keep containers (drums, cans, or tanks) closed, except when depositing waste, as a safeguard against spills and to prevent water from entering the containers.
(7) Obtain a replacement through the prescribed load list section or the troop support office if
2 1/2- or 2 3/4-inch threaded caps on 55-gallon drums are missing.
(8) Ensure that secondary containment is provided that is capable of containing 11/2 times the volume of the largest container stored in the storage area.
(9) Do not accumulate HW in an open container; it is a serious violation of HW regulations.
c. Leave the following headspace to prevent overflow due to expansion:
55-gallon drum ................................3 to 4 inches.
5-gallon cans...................................1 1/2 to 2 inches.
1-gallon can ....................................1 inch.
d. Dispose of used oil in an appropriate aboveground container.
(1) Label the storage tank(s) USED OIL ONLY (by type such as motor oil, transmission oil, or hydraulic oil), and make certain personnel are trained to place only used oil in the tanks. If a 55-gallon drum is needed, use NSN 8110-00-823-8121.
(2) Ensure that waste oil tanks are pumped on a regular schedule. Notify the motor sergeant or the unit's HM/HW coordinator if the tank fills up before the scheduled pick up date or the tank is not pumped on schedule.
e. Use vermiculite (NSN 7930-00-269-1272) or absorbent pads to soak up puddles and Safestep (NSN 7930-01-145-5797) or sawdust (NSN 7930-00-633-9849) to clean up hardstands if HM or HW is spilled. Place all contaminated soil and absorbent material in removable head drum(s) (NSN 8110-00-082-2626 or 8110-00-292-8121) and turn in to the DRMO. Notify the installation's environmental office (see tab A).
f. Overpack chemical products and POL contained in leaking, corroded, or otherwise deteriorated containers in approved drums, and dispose of them as HW through the DRMO. Contact the installation's environmental office for assistance in determining the appropriate overpack containers.
(1) To be accepted for turn-in, waste material must be in a safe, nonleaking, durable container.
(a) Overpack leaking containers in steel or plastic removable head overpack drums, available through the supply system.
(b) Pack leaking containers of liquids in absorbent material (NSN 7930-00-269-1272), available at the General Services Administration (GSA) store or through GSA or Defense Logistics Agency catalogs.
(c) Overpack a leaking 55-gallon drum in an 85-gallon drum. Place an absorbent material all around a leaking, overpacked container, to include underneath the container and with the maximum amount possible placed in the space between the overpack container and leaking container. There must be 6 inches of absorbent on the bottom and top of the interior container, with at least 2 inches around the sides (adjust for different-size drums and overpacks).
(d) Overpack leaking containers of nonliquid HW in a serviceable container. Call the installation's environmental office or the DRMO when in doubt as to the type of container to use since many liquids such as battery acid cannot be packed in steel containers.
(2) Contact the installation's environmental office for a loaner if drums are not available for overpacking an emergency spill. Requisition a replacement drum for the installation's environmental office. Used drums are frequently available at the DRMO. Removable head 55-gallon drums (NSN 8110-00-082-2626) should be stocked by installation supply. Ensure that spill kits are procured for handling future spills.
(3) Request assistance from the installation's environmental office on compatibility of waste, packing, and labeling of containers. Maintain this information in the waste-stream file for each waste.
Figure J·1. Unit environmental SOP (continued)
g. Inspect HW weekly. Document results of the inspection on a log made accessible to state and federal inspectors. Identify description of the waste, location, quantity, date accumulation started, end of gO-day period, date removed to the DRMO or by contractor, remarks (condition