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Appendix F
IMPORTANCE OF HAZARDOUS MATERIAL/HAZARDOUS WASTE MANAGEMENT
F-4. Severe injuries or irreparable environmental damage could result from improper HM/HW
management. In addition to protecting human health and the environment, proper management of HM/HW
produces cost savings through HW minimization and P2. A portion of the funds used for cleanup
procedures due to mismanagement of HM/HW may impact unit training budgets and military readiness.
HAZARDOUS MATERIAL/HAZARDOUS WASTE MANAGEMENT PLANS
F-5. The key to a successful management program lies in planning and informing. HM/HW management
plans should be specific for the given operation, and commanders must place an emphasis on the program
to ensure that all personnel are aware of the requirements. Plans may be altered based on the mission or
tactical situation, but informing the command of proper procedures is critical in maintaining a successful
program.
KEY ASPECTS OF HAZARDOUS MATERIAL/HAZARDOUS WASTE MANAGEMENT
F-6. Several important aspects exist in HM/HW management. At a minimum, personnel must know how
to properly handle, transport, and store HM and how to properly collect and dispose of HW. Proficiency in
these management practices will ensure that neither personal safety nor the environment is jeopardized
during operations.
SPILL RESPONSE PLANS
F-7. Emergency HM/HW spill response plans must be prepared before any operation. These plans should
address all aspects of spill response, to include site-specific response procedures and spill response
equipment requirements for each major HM/HW operation. They should be distributed throughout the unit
before any operation.
HAZARDOUS MATERIAL/HAZARDOUS WASTE FIELD
PROCEDURES
F-8. Using the correct procedures for HM/HW handling is critical to protection measures and
environmental protection. Field environment operations, whether during training or deployment, present
additional hazards to the management of HM. Proper measures—including enforcement of the use of PPE
and proper procedures for the handling, storing, and transporting of HM/HW—must be developed and
implemented. See the following vignette.
F-2
FM 3-34.5/MCRP 4-11B
16 February 2010
Hazardous Material/Hazardous Waste Management Procedures for Field Operations
Issue
Field expedient HW accumulation sites pose environmental and safety risks.
Discussion
The DRMO Forward Support Team-Europe established two main HW accumulation
sites and nine feeder sites in Iraq for storing large volumes of waste oil generated in-
country. Mission variables dictated that the inherent risks of convoy operations in the
hostile environment were high, requiring commanders to reduce the frequency of HW
convoys or to discontinue transport altogether. Commanders were forced to set up
their own HW accumulation site inside their base camps.
These areas had problems associated with—
• HWs that were not segregated.
• Lack of secondary containment.
• Leaders that did not provide proper supervision on the sites.
• Sites that were situated too close to camp perimeters—creating a protection
issue. (Sites are a potential target for hand grenades and IEDs.)
• Actions that put the health and safety of Soldiers and Marines at risk.
Techniques and Procedures
• Commanders must ensure that personnel are trained in the handling of HM/HW
before setting up a base camp HW accumulation site.
• Leaders must familiarize themselves with the combatant command’s (command
authority) requirements for managing HW in-theater and ensure compliance.
• Trained personnel and leaders must supervise site operations and Soldiers and
Marines to ensure proper handling and management of HW.
• When setting up an HW accumulation site, units must—
▪ Identify a manager for the HW accumulation site.
▪ Identify the types of HW materials present.
▪ Specify the authorized amounts of HW collected.
▪ Segregate the HWs.
▪ Locate the HW accumulation site at a safe distance from troop bedding/duty
areas and perimeters (a minimum of 50 feet).
▪ Maintain adequate storage and proper collection containers on hand.
▪ Provide electrical grounding for containers.
▪ Label the containers.
▪ Maintain MSDSs on hand for each item.
▪ Set up an emergency wash/decontamination site.
▪ Plan for adequate secondary containment.
▪ Plan for spills and maintain appropriate PPE and spill kits readily available.
▪ Secure the HW accumulation site.
▪ Supervise all activities within the HW accumulation site.
Note. The fence is the perimeter around the HW accumulation site, not the base
camp perimeter.
16 February 2010
FM 3-34.5/MCRP 4-11B
F-3
Appendix F
HAZARDOUS MATERIAL/HAZARDOUS WASTE HANDLING
F-9. The most important aspect of HM/HW handling is in identifying the hazard(s) associated with each
individual chemical. Once appropriate hazards are identified, steps may be taken to minimize personnel
and environmental exposure. Hazardous characteristics may be found on the MSDS for each chemical.
F-10. MSDSs provide critical information for safeguarding human health and protecting the environment.
They include information on the hazardous characteristic(s) of the chemical, the appropriate PPE, spill
response procedures, signs and symptoms of overexposure, and first aid procedures. MSDSs may be
obtained through the unit supply channels and should be maintained at the following operations: HM
storage and HW accumulation sites, tactical-refueling operations, maintenance operations, and medical
treatment facilities. It is important to note that MSDSs are material and manufacturer-specific, which
means that each chemical brand name contains a different MSDS. HW managers should ensure that
appropriate MSDSs are available during operations.
F-11. Primary operations requiring the use of PPE include the transportation and accumulation of
HM/HW, tactical-refueling operations, and maintenance operations. In the event that MSDSs are not
available and cannot be obtained during an operation, a field expedient PPE should be used to help protect
personnel when handling HM/HW or in the event of a spill. Table F-1 lists national stock numbers (NSNs)
for PPE commonly used when handling HM/HW in a field environment.
Table F-1. Personal protective equipment
NSN
Description
Aprons
8415-01-189-6228
Rubber material, acid-resistant
8415-01-100-7742
Plastic material, oil-resistant, and waterproof
Gloves
8415-00-266-8673
Synthetic rubber, acid- and alkali-resistant
8415-00-266-8675
Synthetic rubber, acid- and alkali-resistant
8415-01-138-2497
Butyl rubber, acid- and alkali-resistant
8415-01-138-2498
Butyl rubber, acid- and alkali-resistant
Safety Goggles
Molded plastic flexible frame with clear plastic lenses and adjustable
4240-00-052-3776
headband
4240-01-055-2310
Lightweight goggles with vinyl resin frame and saddle-type nose bridge
Polycarbonate plastic lens with a molded plastic frame (may be worn over
4240-01-292-2818
most prescription glasses)
HAZARDOUS WASTE COLLECTION
F-12. HW should be collected at the point of generation. The key to proper collection is in segregating,
containerizing, and labeling the waste. HW managers should coordinate with brigade and battalion S-4s to
ensure that all units have the resources needed for proper collection. Units establish HW accumulation sites
to temporarily store HW until arrangements can be made to remove it. Each waste stream needs to have its
own container. Containers need to be inspected for dents, leaks, and corrosion; should be labeled; and
should be kept closed when not being filled. HW containers should be removed from the site as soon as
possible after being filled to 85 percent capacity. Secondary containment needs to be established, and the
site needs to be protected from damage (such as accidental spills, vehicle accidents, and weather effects)
and possible hostile actions (such as a mortar attack). HW accumulation sites should be located away from
troop billeting areas and should be located to avoid potential contamination of water sources (such as storm
drains, drainage ditches, and water courses).
F-4
FM 3-34.5/MCRP 4-11B
16 February 2010
Hazardous Material/Hazardous Waste Management Procedures for Field Operations
WASTE SEGREGATION
F-13. Generators of HW must ensure that waste streams remain segregated. Improper segregation of HW
streams at the point of generation could result in an incompatible waste mixture, posing a significant health
risk. In addition, a mixture of HW and non-HW (such as general trash) must be managed and disposed of
as HW, drastically increasing HW disposal costs. Proper segregation at the point of generation will
simplify the overall management process, protect human health and the environment, reduce disposal costs,
and enhance the potential for recycling the HW.
CONTAINERIZING HAZARDOUS WASTE
F-14. HW must be collected in appropriate containers. The best type of container is the original container
(if it is capable of being closed) in which the material was shipped in before being rendered a waste. If the
original container is not available or the waste volume exceeds the capacity of the original container, use
any container compatible with the waste stream. When filling a container, ensure that adequate headspace
remains to allow for expansion of the material (3 to 4 inches in a 55-gallon drum, 1.5 to 2 inches in a
5-gallon can, and 1 inch in a 1-gallon can). Only nonsparking tools should be used when containerizing a
reactive or flammable waste.
HAZARDOUS MATERIAL/HAZARDOUS WASTE TRANSPORTATION PROCEDURES
F-15. HM/HW should be transported only in approved vehicles. These vehicles should contain appropriate
placards and manifests for the materials being transported. In addition, drivers must be certified to transport
hazardous cargo. Certification training may be coordinated through the supporting transportation unit. The
supporting transportation unit can also provide site-specific information or waive certain requirements,
based on the tactical situation encountered during the operation.
EMERGENCY EQUIPMENT
F-16. Personnel transporting hazardous cargo should be supplied with the required PPE. In addition to
PPE, each vehicle approved for HM/HW transport must be supplied with a spill response plan and the
appropriate spill response equipment.
F-17. Units should be prepared to respond to emergency operations. The unit should maintain—
z
Spill kits. Based on unit mission and the type of HM/HW used, spill kits provide containment
and cleanup should an accidental spill occur.
z
Fire extinguisher. Each storage area containing flammable materials or waste is supplied with an
ABC-type (monoammonium phosphate) fire extinguisher.
z
Emergency eyewashes. Potable water must be readily available for emergency eye washing.
This will help in providing first aid measures on-site in the event of a leak or spill.
z
PPE. Two sets of the PPE are readily available at each storage area. Reference the MSDSs for
the required PPE.
z
Spill response. A spill response plan and spill response equipment are readily available at each
accumulation area.
HAZARDOUS MATERIAL/HAZARDOUS WASTE STORAGE
F-18. As a rule, an HW accumulation site is considered a storage area when it contains more than 55
gallons of HM/HW. HW accumulation sites are temporary sites where HW may be stored for up to 90
days. Storage sites should be identified during the predeployment phase of the operation or as soon as the
unit establishes its operating area. Set up HM/HW storage areas at least 15 meters (50 feet) downwind and
down gradient of personnel billeting and dining facility operations. Eight-digit grid coordinates and
inventories of the storage areas should be maintained in the event that the unit must rapidly evacuate the
area.
16 February 2010
FM 3-34.5/MCRP 4-11B
F-5
Appendix F
F-19. HW accumulation site areas must be properly secured within the unit’s AO to prevent unauthorized
access from both U.S. and foreign nation personnel. The material stored may be considered valuable to the
local population and scavengers. Concertina wire may be necessary to properly secure the storage area.
F-20. HW accumulation sites must be segregated into the following four general categories or sections:
z
Reactives.
z
Flammables/ignitables.
z
Corrosives.
z
Toxics.
F-21. Further segregation may be required based on the compatibility of individual materials (reference
MSDSs for each material to identify appropriate storage sections). Each storage section must be separated
by a distance of 6 feet or a physical barrier to prevent incompatible materials from mixing and producing
an adverse chemical reaction or toxic fumes. A recommended storage segregation chart for materials
commonly used during operations is shown in table F-2. Containers holding reactive or flammable
materials or waste should be grounded during storage, and only nonsparking tools should be used when
handling these containers.
SECONDARY CONTAINMENT
F-22. Secondary containment is designed to protect human health and the environment in the event of a
leak or spill. Proper secondary containment includes hardstands, tarps, plastic liners, and sandbags. For
storage of materials on a hardstand, ensure that the containers are placed on a pallet with a sandbag
perimeter for containment of spilled liquids. If a hardstand is not available, place all materials within each
category on a tarp or plastic liner with sandbags surrounding the containers. Secondary containment should
be large enough to contain 10 percent of the overall volume or 100 percent of the volume of the largest
container of HM/HW stored, whichever is larger. An additional tarp or plastic liner should be available to
cover the tops of the containers during adverse weather conditions.
CONTAINERS
F-23. All containers must be kept closed and maintained in good condition at all times. Supervisors should
not permit open funnels or tubes to be attached to containers. Rusty or residue-covered containers are
unacceptable.
STORAGE OF FUEL CANS
F-24. Five-gallon fuel cans are usually scattered throughout a unit during operations. They should be
consolidated within each company or platoon AO, placed on a tarp or piece of plywood, and surrounded by
a soil berm or sandbags for secondary containment, if possible. This will prevent spills from adversely
affecting personnel or the environment. When filling fuel cans, personnel must ensure that 1.5 to 2 inches
of headspace remains to allow for vapor expansion.
F-6
FM 3-34.5/MCRP 4-11B
16 February 2010
Hazardous Material/Hazardous Waste Management Procedures for Field Operations
Table F-2. Storage segregation chart
Material/Waste
Hazardous Characteristic(s)
Storage Section A (Reactives)
Chlorination kits-reactive
Empty aerosol cans are reactive in a fire
Approved decontaminates
Possible reaction with other decontaminants or chemicals
Storage Section B (Flammables)
Chemical agent resistant
Paint flammable and toxic
coating-toxic
Cleaning compounds
Flammable and toxic
Deicing agents
Flammable
Fuels
Flammable
Lacquers/varnishes
Flammable, irritant, and noxious
Paints
Flammable and noxious
Paint thinners
Flammable and noxious
Parts cleaners
Flammable and toxic
Sealants
Flammable and toxic
Solvents
Flammable, irritant, and toxic
Windshield cleaners
Flammable
Storage Section C (Corrosives)
Antifreeze
Irritant and noxious
Carbon remover
Irritant and toxic
Paint strippers
Corrosive and noxious
Radiator leak compounds
Irritant
Weapons cleaners
Irritant and toxic
Storage Section D (Toxins)
Grease
Noxious
Lubricants
Noxious
Oils
Noxious
Oil contaminated solids
Noxious
Paint primers
Toxic
Storage Section E (Additional Storage Section)
Battery acid
Corrosive and toxic
Dry batteries
Reactive in a fire
16 February 2010
FM 3-34.5/MCRP 4-11B
F-7
Appendix F
BATTERY STORAGE
F-25. An activity that includes battery storage must provide fire suppression equipment. In addition,
storage areas and equipment must be approved by the local fire department. A point of contact must also be
provided to the local fire department. TM 38-410 and TB 43-0134 outline the requirements to—
z
Protect bulk storage of batteries with sprinklers.
z
Keep batteries cool, dry, and away from open flame, heat, and combustibles and in a well-
ventilated area with temperatures not to exceed 130 degrees Fahrenheit (54 degrees Celsius).
Refrigeration is not necessary.
z
Do not mix new and used batteries because it is difficult to distinguish between them. Many
next generation batteries contain state of charge indicators.
z
Segregate storage from other HM and other battery chemistries. It is critical that lead acid
batteries be kept away from nickel cadmium or nickel metal hydride batteries.
z
Protect batteries against being damaged, crushed, punctured, or short-circuited.
z
Do not smoke or eat in battery storage areas.
z
Store batteries separately from other HM.
z
Use open flame devices only under proper supervision and with adequate safeguards.
z
Do not accumulate nonhazardous solid waste batteries.
z
Do not store batteries collected for turn-in to the DRMO more than 90 days.
z
Ensure that fire extinguishers are available. Use an AB-type (water) fire extinguisher to fight
fires involving small quantities of batteries.
RECORDKEEPING
F-26. Detailed HW records start at the accumulation site. A log should be kept of the type of waste
received, the quantity received, the date received, and information on the unit that generated the waste.
This log should be kept at all accumulation areas at brigade and battalion level. The unit HW manager is
responsible for completing the appropriate turn-in documentation and applicable local forms. These should
be completed once the waste is retrograded from the maneuver battalion accumulation areas to the brigade
storage area. The unit should prepare a plan for the closure of HW accumulation sites. This plan should
detail the way in which all waste and waste residues will be removed from the accumulation areas when
they are no longer needed or in use.
INSPECTIONS
F-27. HW managers should conduct daily inspections of HM/HW accumulation areas. They will ensure
that all requirements described above are met and that containers are in good condition.
HAZARDOUS WASTE DISPOSAL
F-28. Two primary disposal options for HW exist that can be implemented in any joint operations area
(JOA): disposal through an approved contractor or retrograding HW back to CONUS. Units must not
incinerate or bury any HW unless explicitly approved by both U.S. and foreign nation authorities.
Commanders must determine the most viable means of approved HW disposal before entering the JOA by
contacting their higher headquarters/supporting DRMO.
SUPPLY ACTIONS
F-29. Supply officers should maintain a system to monitor the amount of HM on hand to ensure that units
are not stockpiling HMs. Excess HM storage may lead to unnecessary personal or environmental exposure.
Supply and logistics personnel should coordinate among themselves and with the various environmental
agencies to identify available alternative products, which can reduce the overall HW production.
F-8
FM 3-34.5/MCRP 4-11B
16 February 2010
Hazardous Material/Hazardous Waste Management Procedures for Field Operations
TACTICAL-REFUELING OPERATIONS
F-30. POL personnel should conduct tactical-refueling operations at a designated logistics release point.
Conducting tactical-refueling operations in a unit’s AO should be avoided due to safety hazards associated
with maneuvering a fuel tanker or heavy, expanded-mobility tactical truck (HEMTT) and conducting
grounding operations at each vehicle. POL personnel should conduct actual refueling whenever possible.
F-31. During refueling operations, secondary containment (such as large drip pans) should be placed under
the vehicle and under the fuel hoses. When refueling 5-gallon fuel cans, the cans should be placed inside
the drip pans used for secondary containment. This will prevent small-volume fuel spills from
accumulating and contaminating the soil. The spilled fuel should be transferred to a labeled 5-gallon waste
fuel container and disposed of as HW. Ensure that proper emergency equipment is present during all
refueling operations.
FIELD MAINTENANCE OPERATIONS
F-32. Maintenance operations should be conducted on a hardstand, tarp, or plastic liner, if available.
Maintenance personnel will be required to supply their own PPE, spill response equipment, potable water
for emergency eye washing, and liquid waste. All wheeled vehicles should contain drip pans, and all
tracked vehicles should contain belly plates. Collected fluids must be placed in appropriate waste
containers and disposed of as HW. Each company-size unit must maintain one labeled 5-gallon container
for drip pan waste.
F-33. All drained fluids must either be returned to the vehicle or placed in an appropriate waste container
for recycling or disposal as an HW. Maintenance areas should be supplied with two labeled 55-gallon
liquid-waste containers for each of the following waste streams: used oil, waste fuel, waste antifreeze, and
POL-contaminated solids. HW managers can coordinate the proper set up of accumulation site and the
turn-in of waste containers and acquire empty 55-gallon liquid-HW containers from the appropriate
support platoon.
DINING FACILITY OPERATIONS
F-34. Dining facility personnel may use M-2 burners, which operate on motor gasoline, during operations.
Major safety and environmental issues include fuel storage, filling, and lighting operations.
F-35. Whether using motor gasoline or diesel fuel, filling operations should be conducted on a tarp or
plastic liner with a soil berm or sandbag perimeter for secondary containment in the event of a spill. Spilled
fuel must be collected immediately using an absorbent material. The used absorbent material should be
placed in a plastic bag and disposed of as HW.
F-36. Lighting operations must be conducted at least 50 feet away from fuel storage and M-2 burner filling
operations. Lighting operations should be conducted on open soil so that any residual fuel will freely burn
during the operation.
OPERATION OF HEATERS, GENERATORS, AND LIGHT SETS
F-37. Personnel who use field heaters must ensure that the fuel supply (usually a 5-gallon fuel can)
possesses secondary containment in the event of a leak or spill. The best way to provide this secondary
containment is to elevate the fuel supply on a tripod or the back of a vehicle and place a drip pan under the
fuel hose to collect any spilled fuel. The overflow fuel line should also have secondary containment, and
all leaking fuel lines must be repaired or replaced. Collected fluids must be placed in appropriate waste
containers and disposed of as HW. Each company-size unit should maintain one labeled 5-gallon container
for waste fuel from the operation of heaters.
F-38. Generators and light sets must be operated in a manner protecting the environment from potential
contamination. To provide this protection, operate generators on a piece of plywood and completely
surround the generator with a soil berm or sandbag perimeter. This will prevent leaking fuel from
contaminating the surrounding soil. Another alternative is to operate generators on a trailer and ensure that
16 February 2010
FM 3-34.5/MCRP 4-11B
F-9
Appendix F
all spilled fuel is collected and placed in appropriate waste containers; each company-size unit should
maintain one labeled 5-gallon container for waste fuel from the operation of generators. In addition,
personnel should conduct preventive maintenance checks and ensure that all leaking generators are
repaired or replaced.
SPILL RESPONSE
F-39. While good HM/HW management practices will minimize the chance of spills and thereby avoid the
additional effort required to clean up any incidents, accidents will still happen. When they do, it is
imperative that personnel are trained and prepared to mitigate the damage and to clean up the spills.
SPILL RESPONSE PLAN
F-40. A spill response plan must be available for each operation. The following major operations should
have a copy of this plan: tactical refueling, maintenance, and HM/HW accumulation and transportation.
The plan should address, at a minimum, site-specific response procedures and spill response equipment
requirements for each major operation.
SPILL RESPONSE PROCEDURES
F-41. In the event of an HM/HW spill, the procedures listed below must be implemented immediately by
trained personnel within the unit. Personal safety must never be compromised during the response. Should
the situation exceed unit capabilities, evacuate the area, inform the chain of command, and contact the local
HM spill response team or range control. Emergency telephone numbers or radio frequencies should be
obtained and distributed throughout the unit as necessary before the operation begins. Personnel—
z
Protect themselves. Use the required PPE for the spilled material specified in the MSDS and
evacuate all nonessential personnel from the immediate area.
z
Stop the flow. The flow of HM/HW must be stopped at the source to control the spill. This may
be as simple as placing the container upright or closing a valve. In the event of a spill of
flammable material, use only nonsparking tools and ensure that metal-to-metal contact is
avoided.
z
Contain the spill. Proper containment includes placing drip pans where the material contacts the
soil, placing soil berms or sandbags around the contaminated area, and placing absorbent
material in the area of the spill. The purpose of this step is to prevent the spread of
contamination.
z
Report the spill. Notify the chain of command and unit HW manager immediately.
z
Clean the spill. Equipment used to clean a spill must be chosen carefully. Use only nonsparking
tools if the material is flammable or explosive. For corrosive materials, use equipment that will
not corrode or deteriorate (for example, nonmetallic equipment). Collect used absorbent and
contaminated soil in plastic bags and transfer the bags into a labeled sturdy container to be
disposed of as HW.
z
Replace spill response equipment. Obtain replacement spill response equipment through the unit
supply channels to ensure that personnel can properly respond in the event of another spill.
SPILL RESPONSE EQUIPMENT
F-42. Spill response equipment is essential to protecting the environment in the event of an HM/HW spill.
The type and amount of spill response equipment needed depends on the operation. Units may also need to
acquire hydrophobic-absorbent materials for operations conducted in areas susceptible to large amounts of
precipitation. Spill response equipment required for specific operations is discussed in the following
paragraphs.
F-10
FM 3-34.5/MCRP 4-11B
16 February 2010
Hazardous Material/Hazardous Waste Management Procedures for Field Operations
Tactical-Refueling Operations
F-43. Tactical-refueling operations are limited to the handling of fuel products, such as diesel and motor
gasoline. The extent of the operations and load-carrying capabilities of fuel tankers and HEMTTs restricts
the amount and type of spill response equipment needed. In the event of a major spill during refueling
operations, personnel primarily need two nonsparking picks and two nonsparking shovels to excavate
contaminated soil and several large plastic bags to contain the excavated soil for disposal as HW.
Approximately 10 pounds of absorbent and several small plastic bags are sufficient to respond to small-
volume spills on a hardstand. Nonsparking tools should also be readily available. Additional resources may
be obtained through supply channels as required.
Field Maintenance Operations
F-44. Field maintenance operations deal with all Class III items. Repeated small-volume spills are
indicative of field maintenance operations. Approximately 25 pounds of absorbent, two nonsparking
shovels, two brooms, and several small plastic bags for contaminated absorbent are sufficient to maintain
field maintenance operations during operations. Additional resources may be obtained through supply
channels, as required.
Hazardous Material/Hazardous Waste Accumulation
F-45. HM/HW storage operations deal with all Class III items. Leaking containers and small-volume spills
are indicative of field HM/HW accumulation operations. Approximately 15 pounds of absorbent, two
nonsparking shovels, two brooms, and several small plastic bags for contaminated absorbent are needed at
each storage area. Additional resources may be obtained through supply channels as required.
Hazardous Material/Hazardous Waste Transportation
F-46. HM/HW transportation operations deal with several classes of supply in different size containers.
Leaking containers and small-volume spills are indicative of HW transportation operations; however, the
potential exists for large-volume spills in the event of an accident. Each approved vehicle for HM/HW
transportation should maintain approximately 25 pounds of absorbent, two picks, two nonsparking shovels,
one broom, and several small and large plastic bags for contaminated soil. Additional resources may be
obtained through supply channels if deemed necessary.
16 February 2010
FM 3-34.5/MCRP 4-11B
F-11
Appendix G
Base Camp Operations
This appendix provides guidelines for integrating environmental considerations into
base camp operations. The increase in the number of expeditions and contingency
operations has lead to an increased requirement for military personnel to operate from
base camp facilities. The establishment of base camps and the occupation of existing
facilities (such as ports and airfields) require extensive integration of environmental
considerations. These sites, which may approach the size of small cities, can require a
tremendous allocation of resources. In addition, they generate wastes in quantities
similar to small cities, but without the existing infrastructure to support it. Planning
for base camp operations must begin as early as possible in the operation, including
in the establishment of environmental guidelines, oversight authority, site selection,
and camp operating procedures. Refer to FM 3-34.400 for additional information.
BASE CAMP OVERSIGHT AND PLANNING
G-1. Senior commands may establish a base camp coordination agency/JEMB to assist in the conduct of
operations. While these agencies perform separate functions, their coordination is important to ensure
consistent operations. The base camp coordination agency establishes the standards for and coordinates the
location, construction, and occupancy of base camps and installations. The JEMB establishes and
coordinates policy for environmental matters. While sometimes referred to as a “temporary” board, the
JEMB is a requirement as long as there are base camps and similar sites to manage. The JEMB may even
be created during the planning phase to support the integration of environmental considerations into the
planning process. Chaired by the senior engineer or a member of his staff, the JEMB includes primary staff
membership (such as legal, medical, and CA) expertise to round out input for all environmental
considerations. By working together, these two agencies may complement each other’s efforts.
G-2. Base camp planning is typically initiated at a joint level and is a function of the collaboration
between operators and logisticians as they attempt to define the number, the size, and the locations of
potential base camps to support a deployment and the questions related to the standards (construction and
other) that will be applied to each base camp. Staff assessments are collated by the engineer and fed into
the base camp planning process. For each site, a base camp development site plan is developed with a
supporting base camp development plan. The base camp development plan is a set of interrelated
documents that record the planning process for laying out, determining the scope, and initiating
implementing actions for the base camp.
Site Selection
G-3. The selection of base camp and installation sites is critical to the integration of environmental
considerations. While the tactical situation may often dictate the locations, whenever possible
environmental considerations need to be integrated into the decision process. Units must avoid areas that
may contain contamination, such as industrial facilities and other areas that include or are adjacent to
landfills or other health hazards. In addition, military personnel should not be billeted in structures such as
ammunition bunkers or aircraft hangers for extended periods of time to avoid exposure to TIC/TIM
hazards. Some areas of consideration in site selection include—
z
Presence of TIC/TIM or HM/HW hazards (including asbestos and PCBs).
z
Industrial facilities in the area that may subject personnel to contaminants.
z
Potential for dust or noise.
16 February 2010
FM 3-34.5/MCRP 4-11B
G-1
Appendix G
z
Landfills and waste dumps.
z
Drainage (both into and from the site).
z
Proximity to civilian populations.
z
Adequate space for HM/HW and POL storage and protection.
z
Adequate space for latrine and gray water facilities.
z
Existing environmental infrastructure, such as water and sewer.
z
Overall safety of structures on the site.
z
Proximity to areas of standing water that may spread illness.
z
Possible endangered species or critical habitats.
z
Presence of historical, cultural, or religious sites.
z
Interference with the normal routine of the local civilians.
G-4. Although not all of these criteria may be met, a good balance of factors will help to ensure the
protection of the environment and the health of Soldiers and Marines. As always, the tactical mission and
the requirements of protection will also weigh heavily on any base camp locations. The EBS is an
important part of determining site suitability.
Environmental Baseline Surveys
G-5. An EBS (see Appendix E) should be conducted within 30 days of site occupation. This survey helps
to address three primary issues: the identification of risk factors, the determination of initial site conditions,
and assistance in base camp or installation layout. Environmental and safety risks to the health of Soldiers,
Marines, and local civilians may be determined by investigating the site. This helps determine the overall
site suitability for occupation. Factors such as evidence of environmental contamination, landfills, and
surrounding land/industrial uses may impact site suitability. Determining initial site conditions also helps
when comparing the closeout EBS; this prevents liability to U.S. forces for damage or contamination that
may have been present before site occupation. The existing infrastructure and the surrounding area are
surveyed to help planners determine the best locations (from an environmental and health standpoint) for
force beddown, maintenance, sanitation, HM/HW and POL storage, and motor pool locations.
G-6. The survey requires personnel with the necessary training and expertise to identify potential hazards
and may require the taking of various air, soil, and water samples. It will be helpful to determine previous
site usage, hazards on the site, and the potential for hazards generated from areas surrounding the site.
Hazards are those generated as a result of military operations and include both those presented to personnel
occupying the site and to the surrounding civilian population.
Environmental Health Site Assessment
G-7. An EHSA is conducted to determine whether environmental contaminants from current or prior land
use, disease vectors, or other environmental health conditions that could pose health risks to deployed
personnel exist at the deployment sites. Additionally, it also identifies industrial facility operations and
commodities near the site that could, if damaged or destroyed, release contaminants harmful to personnel.
An EHSA is generally conducted in conjunction with an EBS, since the two documents support each other.
While the EBS is generally more visual and engineer-related, the EHSA is more analytical (including a
greater variety and detail of sampling), with a greater focus on health hazards.
Environmental, Safety, and Occupational Health
G-8. Environmental, safety, and occupational health (ESOH) standards should be addressed from a safety
and environmental standpoint. Initial site selection, structure use, and repair estimates must include ESOH
factors. These include items such as electrical systems; water systems; ventilation; air quality; slip, trip, and
fall hazards; structural integrity; PPE; and the use of existing industrial infrastructure, such as overhead
lifts, chain hoists, and cable systems.
G-2
FM 3-34.5/MCRP 4-11B
16 February 2010
Base Camp Operations
BASE CAMP LAYOUT
G-9. While all base camps are unique in their layout due to variables (such as terrain, use, size, and type
of tenant units), certain relationships between base camp layout and environmental considerations tend to
be constant. Considerations with regard to base camp layout include—
z
Locating POL and HM/HW storage areas and motor pools away from billeting areas and
drainage features.
z
Locating latrines and gray water disposal areas away from dining facilities, food storage areas,
and water distribution points.
z
Locating landfills and burn pits downwind from the camp or from billeting areas when possible.
z
Avoiding locating billeting areas in low-lying areas or adjacent to standing water.
BASE CAMP OPERATIONS
G-10. The operation of base camps and other installations (such as airfields, ports, internment/resettlement
facilities, and enemy prisoner of war camps) requires the integration of environmental considerations.
Commanders and staffs must identify and use all available knowledge, including reachback capabilities to
CONUS, to assist in meeting these challenges. Certain areas of base camp operation require particular
attention to avoid environmental impacts and to protect Soldier, Marine, and civilian health and quality of
life. Environmental considerations in the development and operation of these sites include the following:
z
Field sanitation.
z
HM/HW storage, transportation, disposal, and safeguarding.
z
Spill response and reporting.
z
Potential for base camp or mission expansion.
z
POL storage and safeguarding.
z
Solid waste disposal sites or waste removal.
z
Dust abatement.
z
Burn pit locations and operation.
z
Latrine and shower facility locations.
z
Gray water disposal or removal.
z
Mess facility locations.
z
Establishment of guidance and policy on ESOH standards.
z
Medical and infectious waste storage and disposal.
z
Protection against disease vectors (such as rodents and insects).
z
Guidelines for pesticide use.
z
Motor pool locations.
z
Wash rack locations and operation.
z
Drainage.
FIELD SANITATION
G-11. The baseline FHP concern for field commanders is in field sanitation. This is directly linked to
preventive medicine, which each commander may directly affect as a resident unit of a base camp. For
information on unit-focused protective/preventive measures, see FM 4-25.12 and FM 21-10. Most of these
measures should be captured in unit SOPs, and the transition to applying them to base camp standards
should be virtually seamless in its application. As standards on the base camp improve, some of these
considerations will be alleviated by improvements in camp facilities.
16 February 2010
FM 3-34.5/MCRP 4-11B
G-3
Appendix G
HAZARDOUS MATERIAL/HAZARDOUS WASTE MANAGEMENT
G-12. Controlling and managing HM/HW protects the water, the soil, and the air of a base camp from
harmful levels of contamination. The military uses large quantities of HMs, such as fuels, paints, batteries,
pesticides, and solvents. Often, these compounds contain acids, metals, and other toxins. The military work
environment is at least as conducive to HM/HW spills as is the standard workplace. Given these
conditions, U.S. military forces must take extra precautions to ensure that they minimize environmental
contamination by hazardous substances. Even low-level exposure to HM may adversely affect the health of
Soldiers and Marines. This is one of the first environmental protection issues that should be addressed at
base camps. Its FHP aspects cause it to be of critical importance to the base camp commander and the units
living there. Appendix F provides additional guidance on HM/HW operations.
PETROLEUM, OIL, AND LUBRICANTS OPERATIONS
G-13. Refueling of vehicles and containers always raises the level of risk that spills will occur. Because
refueling operations are a necessity for base camps and the units associated with them, commanders must
make them a priority. Spills have significant implications for safety, FHP, and environmental protection—
especially the potential effect on water supplies. Because of these realities, POL operations are a focus area
for base camps, even in their initial stages of development. In addition, these operations may have a
potentially damaging effect to the inhabitants of the base camp. Planning for spills and spill response
should already be a part of unit SOPs, and Soldiers and Marines should generally follow these basic
procedures in conjunction with base camp guidance. See Appendix F for additional information on POL
procedures and spill response.
DUST SUPPRESSION
G-14. Dust created by operations presents both a health hazard and hazard to equipment. Unfortunately,
clearing large areas for motor pools, helicopter landing pads, roads, and billeting areas creates significant
dust hazards. Various techniques, such as placing larger aggregate paving areas (when feasible), ensuring
that vegetative strips remain in place, and applying various chemical dust palliatives help to suppress dust.
GTA 05-08-018 and TM 5-830-3 provide additional supporting information.
BASE CAMP SUSTAINMENT
G-15. From an environmental considerations view, sustainment includes periodic inspections of conditions
in the form of the ECR and various medical reports in support of FHP. This will support the base camp
staff in a similar way to the support provided to an installation commander and staff.
G-16. The longer U.S. forces operate a base camp, the more likely it is that efforts will be made to increase
quality of life for the Soldiers and Marines living there. This could occur in a variety of areas. One of the
areas that may be impacted is environmental considerations. The reestablishment of a foreign nation
government and the ensuing establishment of an FGS for that nation may also affect environmental
standards. Compliance requirements may make the adjustment to these standards a requirement rather than
a commander’s decision.
BASE CAMP CLOSURE
G-17. The closure of a base camp is a part of the initial planning process that identified the need for a given
base camp and provided an estimate for its duration. The environmental considerations included in the
initial planning must attempt to factor in the end state of a base camp and the requirement to ultimately
return the real estate and facilities to a local government. In some cases, restoration involving the removal
of pollution and contaminants from the environment may be required. An EBS is included in the process
of closure to provide the final snapshot of conditions for documentation. Together with the initial
EBS/EHSA and subsequent ECRs/medical inspections, the final EBS provides a picture of the
environmental life of a base camp, which may be used to deal with claims against the government (or
G-4
FM 3-34.5/MCRP 4-11B
16 February 2010
Base Camp Operations
directed remediation) or to address questions of FHP after the site is no longer occupied by Soldiers and
Marines. Areas of environmental concern in the closure of base camps include—
z
Removing HM/HW and POL stockpiles.
z
Removing soil contaminated by HM/HW or POL.
z
Filling in fighting positions and bunkers and removing tactical and communications wires.
z
Closing and marking landfills and latrines.
ENVIRONMENTAL PROGRAM GOALS AND IMPACTS
G-18. Environmental program areas provide the framework for all programs on an installation to support
environmental protection. To a degree, these are also used to support base camps. Although these program
areas focus on installation use, they are also relevant for base camps, especially those with a long life
where the base camp approaches the standards associated with installations.
G-19. Military programs protecting the environment correspond to legal requirements to protect air, land,
water, human health, and natural and cultural resources. Portions of these programs will almost certainly be
brought forward to affect life on a base camp. To the degree that they do, table G-1 summarizes program
goals and their impacts.
Table G-1. Typical environmental program areas and goals/impacts
Program Area
Goal
Military Impact
POL storage, energy production, waste disposal,
Air
Control emissions
smoke operations, fugitive dust
Minimize release of and
Building acquisition, site demolition, vehicle repair
Asbestos management
exposure to asbestos
costs
Cultural resource
Protect historical and cultural
Restricted buildings, additional costs for building
management
heritage
renovations
Prevent pollution, comply
Procurement, base camp storage and inventory
HM management
with HM regulations
management, turn-in programs for HM
HW and solid waste
Minimize waste generation
Training in segregation, recycling, and substitution
management
Reduce pollution and waste
P2
Turn-in procedures for reusable items, recycling
generation
Spill prevention and
Prevent and respond to spills
Base camp and unit spill plans
response
Water resource
Conserve and protect water
Erosion control, storm water control, vehicle drip
management
sources
pans, wash racks
G-20. In general, at the battalion level or below, these program requirements are integrated into existing
unit programs and procedures. They need not be addressed as separate environmental programs. However,
commanders should coordinate with appropriate base camp environmental staff (and the base camp
coordination agency and base camp assistance/assessment team) to determine their application.
16 February 2010
FM 3-34.5/MCRP 4-11B
G-5
Appendix H
Environmental Officer
AR 200-1 defines an environmental officer/Marine Corps environmental compliance
coordinator as an individual assigned to an organization or unit to accomplish
environmental compliance requirements on behalf of the commander, director, or
supervisor. The designated person also coordinates with supporting installation
environmental staff for requirements clarification and assistance. The commander
determines organizational levels and the required grade suitable for environmental
officers. Environmental officers are generally required at battalion and unit
(company, battery, or troop) level. In garrison directorates, they are generally
required at the division level (branch level if the organization generates HW).
ENVIRONMENTAL OFFICER
H-1. Environmental compliance is the unconditional obedience to international, foreign nation, federal,
state, and local environmental rules, regulations, and guidelines that affect current operations. In units
including a staff officer with similar responsibilities, the environmental officer will usually be given this
additional duty. In company-size units, this duty will generally translate to an additional duty.
H-2. The environmental officer manages environmental issues within the unit and ensures environmental
compliance. He also coordinates through the respective chain of command with the supporting installation
environmental staff to clarify requirements and obtain assistance. The vignette on page H-4 further
illustrates the requirement to coordinate with the installation environmental staff.
H-3. While this position of responsibility is not a formal staff position, the environmental officer is critical
to the commander’s environmental program. The environmental officer—
z
Advises the unit on environmental compliance during training, operations, and logistics
functions.
z
Advises and updates the commander on the unit’s environmental consideration integration and
performance standards.
z
Updates and maintains the environmental portion of the SOP.
z
Coordinates between the unit and higher/installation headquarters environmental staffs.
z
Manages information concerning unit environmental training and certification requirements.
z
Conducts unit environmental self-assessments.
z
Conducts environmental risk assessments.
z
Serves as the SME to the commander on the integration of environmental considerations into
OPLANs/OPORDs.
H-4. Table H-1, page H-2, provides information relating to the environmental officer and applicable
references, required training, and the point of contact for each duty. The environmental officer must
identify and assess the status of compliance with any new regulatory requirements enacted since the last
assessment and address any special areas of concern specified by higher headquarters.
16 February 2010
FM 3-34.5/MCRP 4-11B
H-1
Appendix H
Table H-1. Environmental officer duties
Applicable
Duties
Specific Training
Point of Contact
References
•
Chain of command
Advise the
•
Supporting environmental
commander on
management office
environmental
considerations
•
SJA office
affecting unit
•
United States Army Engineer
operations, and
•
AR 200-1
School (USAES), Directorate
provide liaison
of Environmental Integration
•
MCO P5090.2A
between the unit,
(DEI) <http://www.wood.army.
higher
mil/dei>
headquarters, and
•
United States Army
supporting
Environmental Command
environmental
(USAEC)
management office
Training in compliance
•
Chain of command
•
AR 200-1
Assess unit
topics applicable to the
•
Supporting environmental
environmental
•
Command policies
organization and
management office
management
and regulations
unit/organizational
•
USAES, DEI
program
compliance assessment
•
MCO P5090.2A
tools and techniques
•
USAEC
• Annual training in
HW requirements
•
Chain of command
related to the job
•
AR 200-1
and measures to
•
Supporting environmental
Assess unit HW
•
Command policies
take during an
management office
accumulation site
and regulations
emergency
•
USAES, DEI
•
MCO P5090.2A
• Satellite
•
USAEC
accumulation point
training
• Annual training in
HW requirements
related to the job
and measures to
•
Chain of command
•
AR 200-1
take during an
•
Supporting environmental
Assess unit
•
Command policies
emergency
management office
HM/HW program
and regulations
• Annual training in
•
USAES, DEI
•
FM 3-34.5
HM requirements of
their job and
•
USAEC
measures to take
during an
emergency
H-2
FM 3-34.5/MCRP 4-11B
16 February 2010
Environmental Officer
Table H-1. Environmental officer duties (continued)
Applicable
Duties
Specific Training
Point of Contact
References
•
Chain of command
•
AR 200-1
Assess unit solid
•
Supporting environmental
waste
•
Command policies
management office
management
and regulations
•
USAES, DEI
program
•
MCO P5090.2A
•
USAEC
•
Chain of command
Assess unit spill
Annual training, hours
•
Supporting environmental
•
AR 200-1
prevention
vary
management office
program and P2
•
MCO P5090.2A
•
USAES, DEI
program
•
USAEC
•
Chain of command
•
AR 200-1
Annual training, hours
•
Supporting environmental
•
Command policies
vary
management office
Respond to a spill
and regulations
•
USAES, DEI
•
MCO P5090.2A
•
USAEC
•
Chain of command
•
Supporting environmental
Assess unit
•
AR 200-1
management office
recycling program
•
MCO P5090.2A
•
USAES, DEI
•
USAEC
•
AR 350-19
Assess unit
•
Chain of command
•
Command policies
training area
• ITAM briefing
and regulations
•
Local ITAM coordinator
management
• Range safety officer
•
Local installation
•
USAES, DEI
procedures (field
briefing
operations)
regulations for
•
USAEC
training area usage
•
Chain of command
Assess
• Unit-level training
environmentally
•
Supporting environmental
•
Unit SOP
• Safety officer
related risks in
management office
training
military operations
•
USAES, DEI
•
AR 200-1
•
Chain of command
Conduct
•
Command policies
Ongoing, with use of
•
Supporting environmental
and regulations
environmental
poster's briefings and
management office
awareness training
•
MCO P5090.2A
written information
•
USAES, DEI
•
Unit SOP
16 February 2010
FM 3-34.5/MCRP 4-11B
H-3
Appendix H
Table H-1. Environmental officer duties (continued)
Applicable
Duties
Specific Training
Point of Contact
References
Integrate
• AR 200-1
environmental
• FM 5-0
• Chain of command
consideration into
• Command policies
Command information
• Supporting environmental
unit SOPs, policies
and regulations
briefings
management office
and procedures,
and OPORDs/
• MCO P5090.2A
• USAES, DEI
OPLANs
• Unit SOP
ENVIRONMENTAL OFFICER TRAINING
H-5. The environmental officer will be trained to accomplish assigned duties. Improper training may
result in NOVs, fines, and more work (see the vignette for more information about proper training). The
training requirements for the environmental officer depend on the environmental issues within the unit and
the coordination required through the respective chain of command. Units should consult with their higher
headquarters and supporting environmental management office for location-specific training requirements
outlined in table H-1.
H-6. Installations (including OCONUS) currently provide installation-specific training programs. Check
with the local environmental management office for attendance requirements. The Environmental
Compliance Officer’s Course (052-E-0036) and other training resources for the unit environmental officer
to use are available through the Army’s Reimer Training and Doctrine Digital Library at
H-4
FM 3-34.5/MCRP 4-11B
16 February 2010
Environmental Officer
Issue
Troop self-help projects result in state environmental fines (asbestos/lead-based
paint).
Discussion
State environmental regulatory departments closely scrutinize the demolition projects
of older structures on installations. Many of these structures contain asbestos-
containing materials and lead-based paint, both of which are known health hazards.
Installations are required to notify the state before beginning demolition or renovation
projects. All asbestos-containing materials and lead-based paint must be removed by
trained personnel. Several installations received NOVs for failure to comply with this
requirement. These NOVs were issued to units who disturbed asbestos-containing
materials and lead-based paint during self-help projects. State regulators also issued
an NOV for Soldiers and Marines discarding asbestos-containing materials items into
trash containers.
Techniques and Procedures
Commanders and installation environmental offices must be proactive in promoting
asbestos and lead-based paint awareness not only to tenant units but also those
units training or conducting mobilization operations on the installation.
Unit leaders must—
• Ensure that the environmental officer contacts the supporting environmental
management offices or DPW for all self-help projects.
• Comply with installation-specific regulations and approved self-help project plans
to prevent the disturbance, mishandling, or improper disposal of asbestos-
containing materials and lead-based paint.
• Attend asbestos and lead-based paint awareness classes conducted by the
environmental management office or DPW.
• Supervise Soldiers and Marines conducting self-help projects. Ensure that
Soldiers and Marines comply with guidance in the self-help project work plan.
For more information on asbestos and lead-based paint, view the USAEC Web site:
16 February 2010
FM 3-34.5/MCRP 4-11B
H-5
Appendix I
Sample Command Policy
This appendix provides an example of an environmental policy letter and a unit order
for appointing an environmental officer. Figure I-1, page I-2, depicts a commander's
environmental policy letter, and figure I-2, page I-3, provides an example of an
environmental officer appointment order. Additional policy letters may be required
for specific operations within your unit and may be drafted using the basic format of
the memorandums in this appendix.
16 February 2010
FM 3-34.5/MCRP 4-11B
I-1
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.
16 February 2010
FM 3-34.5/MCRP 4-11B
J-1
Appendix J
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
J-2
FM 3-34.5/MCRP 4-11B
16 February 2010
Unit Environmental Standing Operating Procedures
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)
16 February 2010
FM 3-34.5/MCRP 4-11B
J-3
Appendix J
(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)
J-4
FM 3-34.5/MCRP 4-11B
16 February 2010
Unit Environmental Standing Operating Procedures
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)
16 February 2010
FM 3-34.5/MCRP 4-11B
J-5
Appendix J
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.
Figure J-1. Unit environmental SOP (continued)
J-6
FM 3-34.5/MCRP 4-11B
16 February 2010
Unit Environmental Standing Operating Procedures
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.
Figure J-1. Unit environmental SOP (continued)
16 February 2010
FM 3-34.5/MCRP 4-11B
J-7
Appendix J
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.
Figure J-1. Unit environmental SOP (continued)
J-8
FM 3-34.5/MCRP 4-11B
16 February 2010
Unit Environmental Standing Operating Procedures
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.
Figure J-1. Unit environmental SOP (continued)
16 February 2010
FM 3-34.5/MCRP 4-11B
J-9
Appendix J
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)
J-10
FM 3-34.5/MCRP 4-11B
16 February 2010
Unit Environmental Standing Operating Procedures
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 90-day period, date removed to the DRMO or by contractor, remarks (condition of storage area and
containers), inspector's printed name, signature, and date of inspection. Coordinate this action with
the installation’s environmental office.
9. Vehicle Parking Areas.
a. Park vehicles only in designated parking areas.
b. Do not discharge any POL product or contaminated soil into or near a storm drain. This is
forbidden. Vehicle parking areas drain into storm sewers; storm sewers drain into streams, which lead
into the nearest surface-water body.
c. Place drip boxes/pans under all drip points of vehicles with potential for leaking POL.
d. Use dry sweep to clean up POL spills where vehicles are parked, and dispose as HW through the
DRMO.
e. Do not wash vehicles on the vehicle parking line. Wash according to paragraph 4 of this SOP.
f.
Ensure that no vehicle leaves the motor pool if it leaves a visible, continuous, or intermittent trail
of POL on the ground (Class 3 leak).
10. Disposal of Empty Containers and Hazardous Items. Include information on turn-in of mufflers and
exhaust pipes, brake shoes and clutch plates, fuel tanks, aerosol cans, PCB capacitor and transformers,
hydraulic rams and gas cylinders, shock absorbers, oil-saturated wood and pallets, paint and paint
containers, solvents and thinners, oils and greases, antifreeze, oily rags, sweeping compound, oil and fuel
filters, wash rack soil/sand residue, spill clean up debris and residue, and products with expiration dates.
a. Turn-in procedures. The procedures for turning in HM varies widely due to differing state and
local requirements. Seek the assistance of the supporting installation and DRMO for information on
filling out and processing the turn-in document.
b. Transport. Transportation of HW is strictly controlled. Check with the supporting installation and
DRMO to determine if transport by the unit is allowed.
11. Refueling Operations.
a. General.
(1) Conduct tactical refueling operations at a designated logistics resupply point.
(2) Avoid conducting refueling operations in a unit’s operations area due to the safety hazards
associated with maneuvering a fuel tanker or HEMTT and conducting grounding operations at
each vehicle.
(3) Ensure POL section personnel conduct the actual refueling whenever possible.
b. Secondary containment.
(1) Place secondary containment (large drip pans) under the vehicle and under the fuel hoses
during refueling operations.
(2) Place 5-gallon fuel cans inside the drip pan when refueling, for secondary containment,
preventing small volume fuel spills from accumulating and contaminating the soil.
(3) Transfer spilled fuel to a labeled 5-gallon waste-fuel container, and dispose as HW.
c. Emergency equipment.
(1) Firefighting. Supply each refueling vehicle with a minimum of two fire extinguishers. Set up
fire extinguishers on each side of the tanker or HEMTT during refuel operations to expedite
emergency response measures. Ensure that vehicles have their basic issue inventory items.
Figure J-1. Unit environmental SOP (continued)
16 February 2010
FM 3-34.5/MCRP 4-11B
J-11
Appendix J
(2) Emergency eyewash. Ensure potable water is readily available for emergency eye
washing to provide first aid measures on-site in the event a spill or leak occurs during refueling
operations.
(3) PPE. Ensure that each refueling vehicle has two sets of PPE. Reference the MSDS for
required PPE, or reference paragraph 4 at the beginning of this SOP for field-expedient PPE.
Wear gloves and goggles when conducting refueling operations. Use aprons or wet weather
gear to respond to a spill or repair a leak. Ensure that this equipment is available.
(4) Spill response. Ensure that a copy of the spill response plan is readily available during all
refueling operations.
12. Spills. (See tab A for spill response plan. You should also refer to GTA 05-08-003.)
a. Protect yourself and other personnel, stop the flow, and then contain the spill. Immediately contain
and report all spills that have entered or threaten to enter floor or storm drains.
b. Report all spills according to the installation spill contingency plan. Reporting procedures and
reportable quantities may vary from installation to installation. The unit’s spill response team conducts
clean up. Allow light fuel to evaporate into the atmosphere; absorb oil with dry sweep or equivalent.
(See tab A.)
c. Report POL spills larger than 1 gallon of heavy oil or 5 gallons of fuel to the installation’s fire
department. (Check the installation spill contingency plan for any differing local requirements.)
d. Conduct spill cleanup per the spill response plan at tab A. Additional cleanup guidance will be
provided when the spill is reported.
e. Maintain
(on hand) supplies and equipment
(absorbent materials) appropriate for initial
containment of the types of spills possible in the unit. Refer to the MSDS associated with each
product, or call the HW material section of the DRMO for guidance on the necessary spill response
supplies to have on hand. Spill equipment and material will be similar to that contained in tab B.
SECTION 2 - SUPPLY
1.
Requisitioning. Check with the installation’s environmental office for an up-to-date list of HM and
guidance on the Army’s Hazardous Substance Management System. The Hazardous Substance
Management System, with its centralized management and strict inventory control, will reduce the use and
disposal of hazardous substances.
a. Requisition the minimum quantity required for mission accomplishment.
b. When processing a request for an HM, consider alternative, nonhazardous substitutes. Check with
the installation’s environmental office for suggestions.
c. Ensure that recoverability codes are used whenever applicable.
d. Special indications will be made for any materials that have shelf life considerations.
2. Storage.
a. Label and segregate all HM from nonhazardous items.
b. Keep a copy of the applicable MSDS for each HM on hand in a binder in the HM supply storage
area.
3. Turn-In/Disposal. Check with the supporting installation and DRMO for local requirements for turn-in of
HW and unused HM.
Figure J-1. Unit environmental SOP (continued)
J-12
FM 3-34.5/MCRP 4-11B
16 February 2010
Unit Environmental Standing Operating Procedures
a. Keep an accumulation log for each HW that is waiting turn-in to DRMO. Identify the date each
container was opened, date and quantity of each addition to the container, name of the person adding
to the container, date container is filled or closed, and date of turn-in to DRMO.
b. Keep turn-in documents for HM and HW on file for 2 years. Keep HW manifests on file for 50
years.
4.
Paint.
a. Do not open more than one can of each color of paint at any time.
b. Store paints indoors in a nonflammable material locker or in a POL shed. Store paints by
compatibility.
c. Keep paint in original, labeled containers.
d. Maintain an MSDS in the paint locker for each type of paint stored.
e. Turn in any unopened, reusable, excess, or no longer needed paint products to the appropriate
material management support activity for redistribution or sale.
f.
Store all waste paint and thinners/solvents separate from unused or good paint products.
g.
Consult the installation environmental management office and chain of command for proper
disposal of all paint.
h. Store and dispose of paint thinners (HM) as directed by the environmental office and the DRMO.
5.
Batteries.
a. Exchange batteries on a one-for-one basis.
b. Store used batteries separately by type while waiting turn-in; accompany with an accumulation
log. Coordinate with your local installation environmental management office to confirm proper
labeling requirements.
c. Ensure that there are no leaking batteries; handle carefully, and place leaking batteries in
appropriate containers.
d. Keep turn-in documents on file for a period of 2 years.
SECTION 3 - CBRNE
1.
Requisitioning, Storage, and Disposal/Turn-In. (See section 2.)
a. Process all requisitions and turn-ins through unit supply.
b. Keep a copy of the applicable MSDS for each HM on hand in a binder in the storage area.
c. Store DS2 and STB containers in dry and well-ventilated separate locations.
d. Check daily DS2 and STB containers for leaks or corrosion.
e. Overpack and turn in to DRMO any DS2 and STB container found to be leaking.
f.
Properly dispose of out-of-date chemical agent testing kits as HW.
SECTION 4 - COMMUNICATION
1.
Requisitioning, Storage, and Disposal/Turn-In. (See section 2.)
2.
Batteries.
a. Issue batteries by exchanging them with used batteries on a one-for-one basis.
b. Immediately turn in used batteries to unit supply for storage while waiting turn-in to DRMO.
Figure J-1. Unit environmental SOP (continued)
16 February 2010
FM 3-34.5/MCRP 4-11B
J-13
Appendix J
SECTION 5 - FIELD MESS OPERATIONS
Field mess personnel use M-2 burners that operate on motor gasoline during field and contingency
operations. The major safety and environmental issues are fuel storage, filling, and lighting operations.
1.
Fuel Storage.
a. Store 5-gallon fuel cans closed at all times.
b. Do not attach open funnels or tubes to the containers. Maintain containers in good condition.
c. Do not use rusty or residue-covered containers. They are unsafe and unacceptable.
2.
Filling Operations.
a. Conduct filling operations on a tarp or plastic liner with a soil berm or sandbag perimeter for
secondary containment in the event of a spill.
b. Immediately collect spilled fuel using an absorbent material.
c. Place used absorbent material in DOT-approved containers, and dispose of as HW.
3.
Lighting Operations.
a. Conduct lighting operations at least 50 feet away from fuel storage and M-2 burner filling
operations.
b. Conduct lighting operations on open soil so that any residual fuel will freely burn during the
operation.
SECTION 6 - OPERATIONS/TRAINING
1.
Training.
a. Provide initial environmental-awareness training to all personnel within
90 days of
assignment and annually thereafter.
b. Train all personnel to accomplish their tasks according to laws and regulations and to
respond properly in emergencies.
c. Train all personnel that have contact with HM or HW within 90 days of assignment and
annually thereafter. Ensure that personnel who have not yet received initial environmental
training are properly supervised when they work with materials potentially hazardous to
themselves or the environment.
d. Document all environmental training and keep on file in the operations/training office.
e. Identify quarterly requirements for environmental compliance officer training. Request training
allocations from the installation’s environmental management office for two personnel (primary
and alternate) in the installation’s environmental compliance officer course. Request an additional
training allocation when either environmental compliance officer is within 90 days of departure.
2.
Risk Assessment.
a. Complete an environmental-related risk assessment for all field training of platoon size or
larger. (See chapter 2 and appendixes D and E.)
b. Use checklists, found in Appendix D, for long-range, short-range, and near-term planning,
training execution, and training evaluation as an aid in minimizing negative environmental
impacts for those areas found to have high risk.
Figure J-1. Unit environmental SOP (continued)
J-14
FM 3-34.5/MCRP 4-11B
16 February 2010
Unit Environmental Standing Operating Procedures
3. Maneuver Damage.
a. Designate a maneuver damage control officer for each FTX.
b. Incorporate maneuver damage considerations into the OPORD for each FTX.
c. Brief unit personnel on maneuver damage considerations and minimization measures before
each exercise.
d. Include maneuver damage as a discussion topic at all AARs.
Tabs:
A. Spill Response Plan.
B. Spill Equipment and Materials.
C. Electronic Message Report Formats.
D. Field Procedures.
E. Points of Contact for Assistance.
Figure J-1. Unit environmental SOP (continued)
16 February 2010
FM 3-34.5/MCRP 4-11B
J-15
Appendix J
TAB A - SPILL RESPONSE PLAN
1. Immediate Action. A spill is defined as any quantity of petroleum product over 5 gallons (or according
to local laws since some states are more stringent than 5 gallons) or any quantity of any other HW. Should a
spill occur, the immediate actions are as follows:
a.
Protect yourself and other personnel.
(1) Evacuate the area, if necessary, due to the type of spill.
(2) Take personal precautions as detailed on the MSDS for the material spilled.
(3) Use the proper PPE.
(4) Extinguish smoking materials and all sources of ignition.
(5) Turn off power if there is the possibility of fire.
(6) Ventilate the area.
b.
Stop the flow (do it safely).
(1) Shut off valves, turn drums upright, and use other procedures that will stop the flow, if
possible.
(2) Do not take unnecessary chances, but stop the flow if it is possible without injury or
contamination.
(3) Shower and change clothes as soon as possible if HW contamination occurs.
c.
Contain the spill (quickly and safely).
(1) Contain the spill by throwing absorbent, floor sweep, or dirt on it.
(2) Make dams to keep the spill from spreading further, and do not let it enter storm or sewer
drains or other waterways.
(3) Divert the flow to prevent the spill from entering any water source, including drains, if
containment is not possible.
d.
Report the spill immediately.
(1) Report the spill to the supervisor/superior.
(2) Sound the alarm or give verbal warning.
(3) Have another person call the installation’s fire department while you continue to assess the
size and severity of the spill.
(4) Immediately report to the unit environmental compliance officer or the installation’s
environmental office spills of any HM other than a petroleum product, regardless of quantity.
(5) The senior person in charge makes a copy of the pertinent MSDS for emergency response
personnel in the event of a reportable spill.
e.
Clean up the spill.
(1) Scoop up contaminated material and put it in a container. Mark the container with
“Hazardous Waste, Contaminated Absorbent (Dirt)” if the spill occurred on concrete or asphalt
and the spill was cleaned up with absorbent or dirt.
(2) Check with the unit supply sergeant or the DRMO for proper disposal.
f.
Replace spill equipment.
(1) Immediately after a spill is cleaned up, the spill response team’s noncommissioned officer
in charge (NCOIC) will account for all tools and supplies. The NCOIC will order replacement
consumables (sweeping compound and rags) from unit supply. He will also identify missing
property and initiate appropriate action (statement of charges or report of survey) to maintain
accountability.
(2) The spill response team’s NCOIC will ensure that spill kit inventories are complete before
resealing the drums.
Figure J-2. Tab A - Spill response plan to unit environmental SOPs
J-16
FM 3-34.5/MCRP 4-11B
16 February 2010
Unit Environmental Standing Operating Procedures
g. Maintain a point of contact list for assistance (listed by office, name, telephone number, and
building).
(1) Fire department.
(2) Installation’s environmental management office.
(3) Unit’s environmental compliance officer.
2.
Response and Cleanup Instructions.
a. Take the immediate actions in paragraph 1 above.
b. Ensure any PPE specified in the MSDS is properly used.
c. Transfer the fluid to a serviceable container if the container is still leaking fluid.
d. Absorb the remaining spilled liquid with absorbent material. Use only the amount necessary to
absorb the spill. Take remedial action if the spill is too large while waiting for the fire department.
e. Clean up the material with a nonsparking shovel or broom and place the residue in a serviceable
container with a secure lid.
f.
Label the container.
(1) Label the container—“POL SPILL RESIDUE”—for fuel, oil, or hydraulic fluid spills.
(2) Label the container—“(Name of Chemical) SPILL RESIDUE - FLAMMABLE”—for flammable
liquid spills (including solvents, paints, paint thinners, and alcohol).
(3) Label the container—“(Name of Acid) SPILL RESIDUE - ACID”—for acid spills.
g. Store the container in the HW storage area while waiting turn-in.
h. Turn in the residue container to the DRMO.
(1) Label the container—“(Name of Chemical) SPILL RESIDUE - FLAMMABLE”—for flammable
liquid spills (including solvents, paints, paint thinners, and alcohol).
(2) Label the container—“(Name of Acid) SPILL RESIDUE - ACID”—for acid spills.
i.
Store the container in the HW storage area while waiting turn-in.
j.
Turn in the residue container to the DRMO.
Figure J-2. Tab A - Spill response plan to unit environmental SOPs (continued)
16 February 2010
FM 3-34.5/MCRP 4-11B
J-17
Appendix J
TAB B - SPILL EQUIPMENT AND MATERIALS
Each unit/activity should maintain a spill kit to respond to accidental releases and spills of HM.
Below is a list of recommended equipment that should be maintained in the unit/activity spill kit. This
list is not all-inclusive and should be expanded depending on the mission of the unit/activity. It is the
responsibility of the unit/activity to purchase replacement or additional items to keep the contents of
the kit stocked with necessary equipment. Additional kits must be purchased by the unit/activity that
needs them, and additional quantities will be based on the likely size or frequency of potential spills.
Hazardous Material/Hazardous Waste Supplies
Containers (DOT or equivalent)
NSN
ITEM
8105-00-848-9631
Bag, polyolefin, 5 millimeters, 36 x 54 inch
8125-00-174-0852
Bottle, plastic, 1 gallon (polyethylene)
8125-00-731-6016
13 gallon
8125-00-888-7069
5 gallon
8110-00-254-5719
Drum, steel, 1 gallon*
8100-00-128-6819
1-gallon steel drum (17C)*
8110-00-254-5722
4-gallon steel drum*
8110-00-282-2520
5-gallon steel drum (17C)*
8110-00-254-5713
Drum, steel, 6 gallon (w/ring)*
8110-01-204-8967
Pail, shipping, steel, 5 gallon (DOT 17C)*
8110-00-519-5618
Drum, steel, 10 gallon (DOT 17C)*
8110-00-753-4643
19-gallon steel drum (17C)*
8110-00-366-6809
30-gallon steel drum (17C)*
8110-00-030-7779
30-gallon steel drum*
8110-00-030-7780
50-gallon steel drum (17C)*
8110-00-823-8121
55-gallon steel drum (17M)*
8110-00-030-9783
Drum, steel 55 gallon (bung & vent) (DOT 17E)*
8110-01-282-7615
Drum, polyethylene, 55 gallon*
8110-01-101-4055
85-gallon steel disposal drum (no lining)*
8110-01-101-4056
85-gallon steel recovery drum (epoxy phenolic lining)*
8110-01-101-4055
Drum, hazardous material*
* Refers to open top containers
For bung container, refer to federal logistics or contract the G-4.
Figure J-3. Tab B - Spill equipment and materials to unit environmental SOPs
J-18
FM 3-34.5/MCRP 4-11B
16 February 2010
Unit Environmental Standing Operating Procedures
Absorbent
NSN
ITEM
7930-00-269-1272
Clay, ground unit of issue (UI-bag)
1939-01-154-7001
Nonskid absorbent (UI-40 bag skid)
5640-00-801-4176
Insulation, thermal, vermiculite (UI-bag) (packing material)
4235-01-423-1466
4 each, 1 cubic foot bag
4235-01-423-0711
1 each, 1 cubic foot bag
4235-01-423-1463
30 each, 18 x 18 inch pillows
4235-01-423-1467
20 each, 2 inch x 10 foot sock
4235-01-423-1465
10 each, 4 inch x 8 foot booms
4235-01-423-2787
10 inch x 10 foot booms
Spill Prevention
NSN
ITEM
8135-00-579-6491
Plastic sheet, clear
8135-00-579-6492
Plastic sheet, black
4235-01-423-7214
Spill kit
4235-01-423-7221
Spill kit
Figure J-3. Tab B - Spill equipment and materials to unit environmental SOPs (continued)
16 February 2010
FM 3-34.5/MCRP 4-11B
J-19
Appendix J
TAB C - ELECTRONIC MESSAGE REPORT FORMATS
References: FM 6-99.2, “US Army Reports and Message Formats,” 30 April 2007.
1.
(
) ECR Format.
TITLE: ENVIRONMENTAL CONDITION REPORT
REPORT NUMBER: E035
GENERAL INSTRUCTIONS: Used to send periodic information (interim snapshots) of the environmental
status of specific sites (assembly areas, base camps, logistical support areas, and medical facilities) where
hazards are likely to occur and can result in significant, immediate, and/or long-term effects on the natural
environment and/or health of friendly forces and noncombatants. Sent according to unit SOP and
commander’s direction.
LINE 1—DATE AND TIME________________________________ (DTG)
LINE 2—UNIT _________________________________________ (Unit making report)
LINE 3—LOCATION ____________________________________ (UTM or
6-digit grid coordinate with
MGRS grid zone designator of
site/incident)
LINE 4—DESCRIPTION _________________________________ (Description of site/incident)
LINE 5—CHANGES ____________________________________ (Changes from last ECR or EBS)
LINE 6—HAZARDS
(Hazards to natural environment, friendly
forces, and/or civilian personnel)
LINE 7—ACTIONS _____________________________________ (Summary of actions to minimize
hazards/remedial effects)
LINE 8—UNIT POC _____________________________________ (Reporting unit point of contact)
LINE 9—ASSISTANCE __________________________________ (Assistance required/requested)
LINE 10—REFERENCE _________________________________ (Site specific EBS, if required)
LINE 11—NARRATIVE
(Free text for additional information
required for clarification of report)
LINE 12—AUTHENTICATION _____________________________ (Report authentication)
Figure J-4. Tab C - Electronic message report formats to unit environmental SOPs
J-20
FM 3-34.5/MCRP 4-11B
16 February 2010
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