New Jersey Army National Guard Supply NCO (Unit Environmental Compliance Officer [UECO] Oversight) Training JAN 2016
Learning Objectives Understand UECO Duties Review Environmental Compliance Desktop Guide Review EMS Goals and Objectives
UECO Duties Advises unit on environmental compliance Coordinates between unit and environmental staff Manages the unit’s environmental training Commander’s eyes and ears for environmental compliance
UECO Duties Conducts unit environmental compliance inspections Performs environmental risk assessments (when required for mission readiness) Determines if waste is hazardous Requests sampling and analysis, if necessary
UECO Duties Does shop-level personnel environmental training Implements the Environmental Management System (EMS)
UECO Duties Implementation Plan All supply NCOs receive EMB UECO training One supply NCO per Facility and shop supervisor takes UECO online training and EMB UECO training UECOs/Supply NCOs backbrief their respective Station Commanders
Backbrief to Station Commanders UECO Appointment and Training Plan Army Regulation 200-1, paragraphs 1- 27.a.(15) and 1-32.f., requires appointment and training of UECO to ensure required environmental compliance actions
Backbrief (Continued) UECO appointment is done by Station/Unit Commander Supply NCOs will provide oversight for the M-Day additional duty UECOs UECOs (full time and M-Day) are critical to environmental program
Environmental Regulations TAG Policy Letter 12-15 Environmental Protection and Compliance Policy FM 3-34.5 Environmental Considerations, Headquarters, Department of the Army AR 200-1 through 4, Environmental Protection and Enhancement NJARNG Environmental Compliance Desktop Guide http://www.state.nj.us/military/installations/docs/ envirocompguide.pdf
Environmental Compliance Desktop Guide Air Emissions/Permits Asbestos Management Cultural and Historical Resources Management Hazardous Material Management Hazardous Waste Management Natural Resource Management National Environmental Policy Act Noise Management Pesticide Management
Environmental Compliance Desktop Guide Spill Planning and Response/POL Management Pollution Prevention Solid Waste (Recycling) Management Wastewater Management
Environmental Compliance Desktop Guide Radon Management Storage Tank Management Toxic Substances Management Water Quality Management Training Requirements Inspection Checklists
Recycling REQUIRED
Recycling Steps Ensure all personnel understand and comply with recycling requirements Designate recycling areas Obtain collection containers Ensure that recyclable material is not taken to or collected by a private contractor without written approval Conduct periodic inspections
Recycling Tool Box Talk
Recycling Inspections DUMPSTERS & TRASH CANS LOOK FOR Copper Paint Cardboard, paper Aluminum cans Glass and plastic bottles
Recycling Check County requirements Track monthly recycling amounts Complete monthly recycling report
Air Emissions/Permits Ozone Depleting Substances Heaters Emergency generators Fueling facilities Other Sources – Diesel vehicle idling – Architectural coatings – Open burning
Ozone Depleting Chemicals (ODCs) ODCs = FOUND IN Chlorofluorocarbons Building fire (CFCs) and halons suppression systems Air conditioning and refrigeration equipment Motor vehicle air conditioners (MVAC) – ODC Compliance Checklist
Refrigerant Management It is illegal to intentionally release any refrigerants, including alternatives like R- 410A and other HFCs, into the atmosphere. Never discard old ODC- containing equipment or products in the general refuse container.
Boiler Permits Overview • Stationary boilers, hot water heaters, and furnaces over 1,000,000 btu/hr heat input capacity • 46 boiler/furnace permits statewide • One permit for multiple boilers (Freehold) • Multiple permits for multiple boilers (Lawrenceville) • Burner adjustment requirements (Teaneck, Lawrenceville, AC, and CLTF only)
Boiler Permits Overview Source labeling and record keeping requirements Fuel oil standards Visual and odor emission standards Emission and consumption limits and burner adjustment requirements (Teaneck and Jersey City only).
Recordkeeping Done by Contractor Done by Facility – Boiler Compliance - Permit Displayed Checklist - Copies of delivery tickets – Equipment Visual with sulfur content Monitoring Log – Equipment Usage Log – Records of Equipment Repairs
Recordkeeping Maintain records for 5 years Meet visual and odor emission standards
Emergency Generator Overview – Over 1,000,000 btu/hr heat input capacity requires a permit – Over 37kW output but less than 1,000,000 btu/hr don’t require permit but have operational limitations – Less than 37kW output must comply with sulfur in diesel fuel requirements only – Mobile military generators are exempt
Air Quality Regulations DO NOT RUN Emergency Generators on days when the NJDEP forecasts air quality anywhere in New Jersey to be "unhealthy for sensitive groups," "unhealthy," or "very unhealthy" (i.e. ozone action days) EPA's Air Quality Index http://airnow.gov
Recordkeeping Done by Contractor Done by Facility – Generator Compliance - Copies of delivery tickets Checklist with sulfur content – Equipment Visual Monitoring Log – Equipment Usage Log – Emergency Generator Usage Log
Recordkeeping Maintain records for 5 years Meet visual and odor emission standards
Fueling Stations Overview Westfield, Picatinny, Lawrenceville, and any location using an MFT as fueling station Review and comply with all permit conditions Submit MONTHLY: – Fueling Facility Checklist – Fueling Facility Throughput Log – Copies of delivery tickets with diesel fuel sulfur content
Other Air Pollution Issues • Diesel Truck Idling Law – 3 Minutes • Open Burning Prohibition • Architectural Coatings • Paint Booths − Paint Booth Compliance Inspection − Paint Booth Usage Log − Paint Booth Filter Removal Log
Asbestos Naturally occurring mineral fiber Once widely used in building materials and products for fire resistance Intact, undisturbed asbestos-containing materials generally do not pose a health risk
Common Uses in NJARNG Buildings
General Information Present in most of NJARNG buildings For remodeling, contact the facility armorer or regional maintenance manager Summary asbestos management plan: http://www.nj.gov/military/installations/all_faci lities.pdf. Asbestos laws require maintenance not removal
Management In-Place Asbestos Management Plan Outlines general responsibilities, notification and labeling, training, work practices, requesting work, emergency response, inspections, and documentation requirements Work in progress and may not reflect actual conditions Check with facility armorer or regional maintenance manager Observation of Suspect ACM Checklist
Weekend Projects 35
Weekend Projects/Self Help CFMO approval prior to self help projects Contact CFMO EMB FIRST to find out about – Asbestos, Lead-Based Paint, PCBs – Cultural/Historical Areas/Buildings – Environmentally Sensitive Areas – Radon – Pesticide Applications
Hazardous Materials Hazard communication or “HAZCOM” is a program to tell workers about the hazardous materials used in the workplace.
What Is A Hazardous Chemical? • Any chemical that can harm your body. • Most industrial chemicals can cause some harm. • It depends on the dose.
Program Requirements Written Hazard Communication Program Responsible Party Material Safety Data Sheets (MSDSs) or Safety Data Sheets (SDSs) Labeling Chemical Inventory Training Recordkeeping
Safety Data Sheets Product identification Hazard(s) identification Ingredients First-aid measures . Fire-fighting measures Accidental release measures Handling and storage Exposure controls/personal protection Physical and chemical properties Stability and reactivity Toxicological information Other information
Hazardous Materials Inventory Control Material Safety Data Sheets (MSDSs) and Safety Data Sheets (SDSs) Material Compatibility Maintaining Material Shelf-life
STORAGE ROOMS and LOCKERS 42
STORAGE ROOMS Must be accessible Dispose of excess unusable paints, chemicals, cleaning liquids, broken spray containers through supporting FMS Label all excess chemicals/materials before disposal 43
Out-of-Date Products = Shelf Life Dates are key to the shelf life (Chapter 4 – Hazardous Material Management) Local purchases do not have a published expiration date. – Call the manufacturer
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