TRAINING SUPPORT PACKAGE (TSP)

TSP Number / Title	052-E-5221 / Enforce Company Compliance with Host Nation, Federal, State, and Local Environmental Laws and Regulations	
Effective Date 	17 Apr 2009 	
Supersedes TSP(s) / Lesson(s) 	052-E-5221, DATED 01 JUNE 2008; 052-E-0006, DATED 2003; and TSP 051-E-0006, DATED 1997	
TSP Users 	Use this TSP to train Company Commanders in the Pre-Command Course.  It may also be used to train Warrant Officers and First Sergeants. 	
Proponent 	The proponent for this document is the Engineer School. 	
Improvement Comments 	Users are invited to send comments and suggested improvements on DA Form 2028, Recommended Changes to Publications and Blank Forms.  Completed forms, or equivalent response, will be mailed or attached to electronic e-mail and transmitted to: 

	US Army Engineer School 
	Directorate of Environmental Integration
	464 MANSCEN Loop 
	Fort Leonard Wood, MO  65473-8929

	Telephone (Comm): (573) 563-7673
	Telephone (DSN):     676-7673	
Security Clearance / Access 	 Unclassified 	
Foreign Disclosure Restrictions	FD5. This product/publication has been reviewed by the product developers in coordination with the U.S. Army Engineer School foreign disclosure authority.  This product is releasable to students from all requesting foreign countries without restrictions.	

PREFACE

Purpose	This Training Support Package provides the instructor with a standardized lesson plan for presenting instruction for:	
 	Task Number 	Task Title 
Individual 
052-250-5221	Enforce Company Compliance with Host Nation, Federal, State and Local Environmental Laws/Regulations 	

This TSP
Contains

TABLE OF CONTENTS

PAGE
Preface	2
Lesson 	Section I  Administrative Data	4
Section II  Introduction	7
Terminal Learning Objective - Enforce Company Compliance with Host Nation, Federal, State and Local Environmental Laws/Regulations	7
Section III Presentation	9
Section IV Summary	25
Section V  Student Evaluation	26
Appendix A - Viewgraph Masters                                                            A -	1
Appendix B - Test(s) and Test Solution(s)  (N/A)                                            B -	1
Appendix C - Practical Exercises and Solutions  (N/A)                                       C -1
Appendix D - Student Handouts  (N/A)                                                      D -	1

Enforce company compliance with host nation, federal, state, and local environmental laws and regulations.
052E5221 / Version 1
17 Apr 2009
SECTION I.	ADMINISTRATIVE DATA
All Courses Including This Lesson		Course Number	Version	Course Title
	
Task(s)
Taught(*) or
Supported	Task Number	Task Title

Individual
052-250-5221 (*)	Enforce Company Compliance with Host Nation, Federal, State and Local Environmental Laws/Regulations 	
Reinforced Task(s)		Task Number	Task Title
	
Academic    Hours	The academic hours required to teach this lesson are as follows:
	Resident
	Hours/Methods
	1 hr	40 mins	/ Conference / Discussion
Test	0 hrs		
Test Review	0 hrs		
	Total Hours:	1 hr	40 mins	
Test Lesson Number		Hours	Lesson No.
	Testing
	(to include test review)				N/A		
Prerequisite Lesson(s)		Lesson Number	Lesson Title
None	
Clearance Access	
Security Level:  Unclassified
Requirements:  There are no clearance or access requirements for the lesson.
	
Foreign Disclosure Restrictions	
FD5. This product/publication has been reviewed by the product developers in coordination with the U.S. Army Engineer School foreign disclosure authority.  This product is releasable to students from all requesting foreign countries without restrictions.
	
References	
Number	
Title	
Date	Additional Information	
	AR 200-1	Environmental Protection and Enhancement.	13 Dec 2007		
	ARMY STRATEGY ENVIRONMENT	The Army Strategy for the Environment - Sustain the Mission, Secure the Future.	01 Oct 2004		
	DOD 4715.04-G	Overseas Environmental Baseline Guidance Document.	01 May 2007		
	FM 3-100.4	Environmental Considerations in Military Operations. MCRP 4-11B.	15 Jun 2000		
	TC 3-34.489	The Soldier and the Environment.	08 May 2001		
	TM 38-410	Storage and Handling of Hazardous Materials. DLAM 4145.11/NAVSUP PUB 573/AFR 69-9/MCO 4450-12. 	13 Jan 1999		
Student Study Assignments	None	
Instructor Requirements	
None
	
Additional Support	
Name	Stu Ratio	
Qty	
Man Hours	
Personnel Requirements	None				
Equipment Required	Id
Name	Stu Ratio	Instr Ratio	
Spt	
Qty	
Exp	
for Instruction	6730-01-039-5465
Screen, Projection			Yes	1	No	
	6730-01-450-3339
Projector, Multimedia			No	1	Yes	
	7025-01-248-4317
Computer Desktop			No	1	No	
	* Before Id indicates a TADSS	
Materials Required	Instructor Materials: None
Student Materials: None
	
Classroom, Training Area, and Range Requirements	GEN INST BLDG, 1500 SF, 20 PN	
Ammunition Requirements	
Id	Name	
Exp	Stu Ratio	Instr Ratio	Spt Qty	
	None					
Instructional Guidance	NOTE: Before presenting this lesson, instructors must thoroughly prepare by studying this lesson and identified reference material.

Proponent Lesson Plan Approvals	Name
Vargesko, Al	Rank
GS-13	Position
Chief, Training Division	Date
09 Mar 2009	
	Danner, Robert	GS-14	Director, DEI	16 Mar 2009	

SECTION II.	INTRODUCTION
Method of Instruction:  Conference / Discussion	
Instructor to Student Ratio is:  1:20	
Time of Instruction:  5 mins	
Media:  Computer Based Instruction (CBI)	
Motivator	
Environmental protection is no longer the province of a few technical experts. It requires soldiers to prevent environmental problems by caring for those resources entrusted to them.  This environmental awareness implies financial, material, and environmental stewardship.  Consideration of the natural and cultural environment is an integral part of the decision-making process.  Preventing environmental problems is always more cost-effective than trying to clean them up after the fact.  Protecting the environmental is the smart thing to do, and it is the right thing to do.

Terminal Learning Objective	
NOTE:  Inform the students of the following Terminal Learning Objective requirements.
At the completion of this lesson, you [the student] will:
	
	Action:	
Enforce Company Compliance with Host Nation, Federal, State and Local Environmental Laws/Regulations 
	
	Conditions:	
Given a mission in garrison or the field, access to references, and a unit environmental officer.  
	
	Standards:	
Enforce company compliance with environmental legal requirements by identifying applicable laws/regulations, providing the necessary unit environmental training, conducting an inspection of the company area, and report to the chain of command on the results.  

Safety Requirements	

	
Risk Assessment Level	
Low
	
Environmental Considerations	
NOTE: It is the responsibility of all Soldiers and DA civilians to protect the environment from damage.
Training entirely of an administrative or classroom nature, little or no environmental impact.

Evaluation	
Individual students will be tested to measure their ability to successfully perform the action specified in the learning objective.  Students will be asked to answer questions during the lesson.  The final evaluation of the lesson is during the common leader block test.

Instructional Lead-In	
We all know the risk that our troops face each and every day while deployed.  Sometimes, we can be our own worse adversaries, if we do not take the proper and necessary precautions to protect ourselves and our environment.  Environmental issues arise while deployed and often in ways our troops are not prepared to deal with.  The environmental laws were written to protect us from ourselves.  Applying these laws while deployed, training our troops, and inspecting our own areas can reduce the threat the environment can have against us.

SECTION III.	PRESENTATION

1.	Learning Step / Activity 1. Identify applicable environmental legal requirements
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	5 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 4
References used in the compilation of this lesson are shown.  The Overseas 
Environmental Baseline Guidance Document applies to OCONUS installations and 
does NOT apply to contingency operations.  CFR stand for Code of Federal 
Regulations.

NOTE:  Show slide 5
Identify the applicable environmental legal requirements.  

NOTE:  Show slide 6
a.	Environmental laws.  There are four primary sources of environmental 
law: federal, host nation, state and local.  Installation policy and unit Standing 
Operating Procedures (SOPs) are based on sources of law. Environmental policy will 
change from installation to installation because environmental laws are different 
between localities, states, and host countries.  You must understand and comply with 
these laws as they apply to your location.  Your unit’s SOP should address 
environmental concerns.  The Army is subject to the requirements of federal law.  
These are some of the laws that the Army bases their policies on:

NOTE:  Show slide 7
	(1) National Environmental Policy Act (NEPA) – This act is the national policy   to protect the environment.

NOTE:  Show slide 8 and 9
	(2) Resource Conservation and Recovery Act (RCRA) – This act gave the Environmental Protection Agency (EPA) the authority to regulate solid and hazardous waste.  Hazardous waste, solid waste, underground storage tanks, and medical waste all fall under RCRA regulations.

NOTE:  Show slide 10
	(3) Clean Water Act (CWA) – This act made it illegal to pollute our water and helped local governments to build waste water treatment plants.  Be careful when conducting military operations near or in water bodies.  Be aware of regulations that may restrict your operations.  If you have an oil/water separator in your motor pool, check it for proper maintenance and operations.  Check your wash rack for proper maintenance and operations also.  Contact your local DPW or Mayor’s cell engineers on base camps for assistance if your oil/water separator or wash rack are not working properly.

NOTE:  Show slide 11
	(4) Clean Air Act (CAA) – This act gave the EPA the authority to set emission standards for air pollution.  Some installations may have an air permit enforced by air monitoring stations across the installation.  Be familiar with your installation clean air requirements.  For base camp operations, site unit facilities upwind of burnpits or incinerators.

NOTE:  Show slide 12
	(5) National Historic Preservation Act (NHPA) – Protects historical sites.  Protection of cultural and historic sites while OCONUS helps to generate goodwill by showing respect and the local population will notice.  This requirement is normally included in the environmental annex of the OPLAN/OPORD.

NOTE:  Show slide 13
	(6) Endangered Species Act (ESA) – Protects the threatened or endangered plants and animals from extinction and protects their habitats.  Just about every Army installation has one or more of these.  For more information contact your DPW environmental office and/or range control.  Range regulations will restrict training near these plants or animals.

NOTE:  Show slide 14
	(7) Federal Facilities Compliance Act (FFCA) – Allows regulatory agencies to inspect federal facilities and impose civil fines on other federal agencies, like the Department of the Army, for violations of the Resource Conservation and Recovery Act (RCRA).  Military installations are now required to comply with state, local, and host nation laws.  

NOTE:  Show slide 15
	(8) Noise Control Act (NCA) – NCA established noise emission standards.  Know your installation noise restrictions.  Try to be sensitive to the local community when making noise.

NOTE:  Show slide 16
b. International and foreign nation laws/Final Governing Standards/Status of Forces Agreements, Basel  Convention.  While serving in areas outside the continental United States (OCONUS), we are required to maintain cooperative relationships with the regulatory agencies of the host nation, and comply with their environmental control standards.  
	(1) Status of forces agreements (SOFAs) are considered part of the environmental pollution abatement standards that apply to the Army in the host country or jurisdiction.  
	(2) The Department of Defense created the Overseas Environmental Baseline Guidance Document (OEBGD), which establishes the minimum environmental standards that DoD installations must follow overseas.  
	(3) When a country has environmental laws, the OEBGD and the host nation environmental laws are compared and the standards that are more protective of human health will be used in what is called the Final Governing Standard (FGS).  
	(4) Major commands such as CENTCOM and AFRICOM developed Environmental Annexes (Annex L) as part of their OPLAN/OPORD.  They may also issue SOPs, policies and guidance for their AORs.

NOTE:  Show slide 17
c.	State environmental laws

	(1) Each state has its own regulatory organization charged with developing and implementing environmental regulations.  Many of the state regulations parallel federal environmental regulations.  In fact, most federal statutes allow states to set standards which, at a minimum, must be as stringent as the federal requirements.  The Environmental Protection Agency (EPA) must approve a state’s program, and then the state is granted “primacy” (responsibility and authority) for that particular program.  The Army must stay in compliance with federal, state, and local, as well as applicable host nation laws and regulations.
	
	(2) Only a few states do not have primacy.  With primacy, state environmental inspectors can enforce both the state laws and federal environmental laws on behalf of EPA.  Prosecution could be separate with a violator being taken to both state and federal courts.

	(3) Some states like California, Massachusettes and Hawaii have very strict environmental laws that are more severe than federal environmental law.  You must be familiar with both.

NOTE:  Show slide 18
	d.  Local Laws.  Local laws and ordinances address the concerns of the local communities.  Generally, they will be based on federal and state laws.  However, each municipality or community may place more stringent restrictions on certain activities; noise restrictions during certain hours of the day are very common.  Water restrictions are another common example in areas where a common water supply is used by the installation and nearby community. 

NOTE:  Show slide 19
    e.  Ways in which eMS is supported at the installation level and within the units are by( the “e” is lower case to put less emphasis on the environment but more on management):  
•	Recycling
•	Conservation
•	Waste Minimization
•	eMS training for all installation residents
•	Alternative transportation
•	Alternative energy sources
•	Sustainablilty

NOTE:  Show slide 20
f.  The Army Environmental Strategy has six goals: 
•	Foster a Sustainable Ethic (do the right thing)
•	Strengthen Army Operations (reduce the logistical footprint)
•	Meet Test, Training and Mission requirements (Integrated Training Area Management and Sustainable Range Programs)
•	Minimize Impacts and Total Ownership Costs (Support the environmental Management System and Sustainability programs)
•	Drive Innovation (technological aids)
This strategy was developed in 2004 by Army environmental professionals and is a long term plan to meet mission, community and environmental requirements.
 
 NOTE: Show slide 21
	g.  Army Environmental Program – Commander’s Responsibilities
The Army has its own environmental regulation and the revised AR 200-1 was published 13 Dec 2007. Although many of these regulations are similar to the EPA regulations, several requirements are more stringent than those of the EPA.  Unit Commanders are given specific responsibilities in paragraph 1-28 of AR-200-1.
 
(1) Another key publication is Army Regulation 200-2, “Environmental Analysis of Army Actions” is found under Title 32 of the Code of Federal Regulations.  These major regulatory documents apply to installations in the continental United States and overseas.
 
(2) Army installations are subject to the requirements of federal, state, local, and host nation environmental laws.  All personnel, military and civilian, are subject to certain penalties for noncompliance with those laws.
 
(3) Violations can subject military installations to fines and civil suits; they can also subject military personnel to fines and suits.  Military violators are also subject to prosecution under the UCMJ and/or in federal, state, or municipal courts.
 
(4) Assume a platoon sergeant failed to ensure that all concertina/communications wire is collected and stored following a field exercise.  The resulting damage and injury to personnel or wildlife that became entangled and injured would be the responsibility of that platoon sergeant.
 
(5) Purposeful actions are environmentally damaging actions that the commander/leader/supervisor knew was illegal.  If a supervisor directs a Soldier to dispose of used parts in a pond located in a secluded part of post, the supervisor has just deliberately broken the law.  Claiming ignorance is not an excuse; common sense dictates that this action is illegal.  The soldier could also be charged for breaking the law.  Soldiers are not required to follow illegal orders and should report any such incidents to their chain of command.

NOTE:	Conduct a check on learning and summarize the learning activity.	

2.	Learning Step / Activity 2. Identify legal requirements for managing hazardous material (HM) properly
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	10 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 22
	a.  Hazardous Materials are necessary for mission accomplishment.  They simply require proper handling and storage. 

NOTE:  Show slide 23
			b.Title 49 of the Code of Federal Regulations (49 CFR) defined a hazardous material (HM) as “a material or substance which the Secretary of the Department of Transportation (DOT) has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce and has been so designated”. 

NOTE:  Show slide 24
c.  These are common hazardous materials found in units.

NOTE:  Show slide 25
	d.  If you have hazardous materials in your unit, you will need to have the material safety data sheets (MSDS) for those materials.  You and your troops should know how to read and understand a MSDS.  By knowing what the risk are of a substance you can reduce the threat and protect the troops to complete their mission.

NOTE:  Show slide 26
	e.  MSDS Sheets.  Identify materials by proper hazard class using labeling and marking data on package, if available.  If marking and labeling data are not readily available or if individual processing material is unsure as to whether item is classified as hazardous material, research National Stock Number (NSN)/common name of Hazardous Material Information Resource System (HMIRS) compact disk to clarify transportation classification.

 		(1) Occupational Safety and Health Administration (OSHA) regulations (Right-to-Know) requires that each hazardous material in shipment be accompanied by a Material Safety Data Sheet (MSDS).
		(2)If the MSDS is unavailable, notify the installation environmental office for assistance. 
		(3) In addition, OSHA requires all facilities to have an MSDS or equivalent for every hazardous material used or stored at the facility.  The MSDS must be readily accessible to all employees.

NOTE:  Show slide 27
 f. Personnel Requirements.  Personnel that deal with HM have special training and requirements that have to be met.  Their certifications must be kept up to date.  This is no longer called DOT HAZMAT Training.  The title changed in October 2008 to Technical Transportation of Hazardous Materials Training.  It is now taught by the Ammunition Center in McAlester.

NOTE:  Show slide 28
g.  Considerations for HM Storage include: consolidation, location, security, containment, and container maintenance.

NOTE:  Show slide 29 
 h.  Rules for handling HM.  The first-in, first out rule (FIFO) is a good practice to follow to prevent a hazardous material from becoming a hazardous waste because its shelf life expired.  Many hazardous materials have expiration dates on the container since they degrade over time.  Storage conditions (extreme heat or cold) can reduce the effective shelf life of hazardous materials.

NOTE:  Show slide 30
  i.   Rules for handling HM.  Most of these are self-explanatory.  Do not store flammable and reactive wastes close to where Soldiers are working.

NOTE:  Show slide 31
j.  Ensure fire extinguishers are approved for the type of HM/HW being used on are readily available.
k.  Post no smoking signs outside the storage cabinet, facilities or structure where they are visible from all directions.
l.  Preparedness and prevention of spills are two of the major elements of environment compliance.
		(1) Post the contact roster
		(2) Develop and post a spill plan
		(3) Meet all safety requirements
		(4) Ensure the Material Safety Data Sheets (MSDSs) and inventory sheets for all HM/HW are on hand
		(5) Understand the Environmental Coordinator’s responsibility
		(6) Understand the Installation On-scene Coordinator’s responsibility
     (7) Pre-coordinate with local authorities and emergencies.

NOTE:  Show slide 32
m. If you have a HM that you do no longer need, do not discard it if it can still be used for its intended purpose.  Look for ways to recycle it into the system or call your local environmental office for assistance.

NOTE:  Show slide 33
	n. This incompatibility chart outlines and shows many common hazardous materials and hazardous waste that needed to be kept segregated.  If you ever have a question about the compatibility of a material you can refer to the MSDS for the material.  The embedded video is showing the mixture of STB (Super Tropical Bleach) and waste oil and the reaction of mixing to incompatible materials. 

NOTE:  Show slide 34
	o. There are many ways in which a HM can become a HW.  Once your HM has become a HW you will have to deal and dispose of it properly.  Our next section talks about HW.

NOTE:	Conduct a check on learning and summarize the learning activity.	

3.	Learning Step / Activity 3. Identify legal requirements for managing hazardous waste (HW) properly
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	10 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 35
	a.  Identify legal requirements for managing hazardous waste (HW) properly.

NOTE:  Show slide 36

	b.  The mismanagement of hazardous waste will create a problem for the generator and the unit. Mismanagement increases liabilities and costs. Money diverted from training funds to correct the action and fines by federal, state or local authorities can severely impact personnel, unit and the mission.
	(1)  If you don’t know what the material is, and you have exhausted your sources to acquire the information then it must be tested by a lab ($1000 average).
	(2) Mismanagement creates a negative public image.

NOTE:  Show slide 37
		c.  Solid wastes according to RCRA may be solids, semi-solids, liquids or may contain gaseous materials that are no longer suitable for their original purpose. 

NOTE:  Show slide 38
			d. There are three ways a solid waste becomes a hazardous:
		(1) Is listed by EPA as a hazardous waste in 40 CFR 261(2) Meets the definition of one or more of the hazardous waste “characteristics”.  The four characteristics are:  

		Ignitable. Ignitable waste materials are liquids that have a flashpoint of less than 140 degrees F. or solids that catch fire easily and burn so rapidly that they create a serious health hazard. 

		Corrosive. A corrosive is a liquid that has a pH value less than or equal to 2.0, or a ph value equal to of greater than 12.5. Corrosives will corrode a standard metal container.  

		Reactive. Waste materials that are normally unstable, react violently with water, have explosive potential, or release poisonous gases, are reactive. 

		Toxic. A waste is toxic if, when tested by an EPA-approved method, an extract from the waste contains specified concentrations of heavy metals or pesticides.   

  	(2) The waste is a “listed” hazardous waste (EPA has provided four lists of specific wastes in the hazardous waste regulation).
  	(3) With prior knowledge from testing or some other means to determine that the waste is hazardous.

NOTE:  Show slide 39
	e.  Facility/unit waste streams include:
·	Contaminated soil
·	Used batteries and acid
·	Used solvents
·	Mixed wastes
·	Used brake fluid
·	Used filters
·	Used antifreeze
·	Contaminated fuels, when non-recycle
·	Discarded fertilizer, pesticides and herbicides
·	Expired or discarded paints, inks, acids and oxidizers
·	Discarded explosive
·	Lead tire weights and battery connectors
·	Flame Ration Heaters

NOTE:  Show slide 40
	f.  Other hazardous waste streams include:
·	Weapons cleaning material
·	Aqueous corrosive liquids
·	Chlorofluorocarbons (CFC) waste
·	Wiping rags
·	Painting material
·	Lead tire weight
·	Lead battery connector
·	Expired shelf life material

NOTE:	Conduct a check on learning and summarize the learning activity.	

4.	Learning Step / Activity 4. Identify proper packaging procedures for hazardous material (HM) and hazardous waste (HW) containers
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	5 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 41
	a. Examples of items to check in container management are:
(1) HM/HW container must have proper shipping name.
(2) HM/HW container must be labeled according to directives.
(3) The original container, to the extent possible, will be used to store. In addition, transport HM/HW.
(4) Containers must be labeled and marked properly.

NOTE:  Show slide 42 
(5) Ground container holding ignitable HM/HW.
(6) Containers must have warning signs (flammable, corrosive, etc)
(7) Containers must be in good conditions and able to withstand handling, transport and long-term storage without leaking.
(8) Must meet DOD regulation, as cited in CFR 49.
NOTE:  Show slide 43 
(9) Do not overfill containers. 90% rule for thermal expansion.
(10) Do not stack drums more than 2 high.
(11) Empty drums will be stacked on their side.
(12) Flammables will not be stacked.
(13) There must be at least 3 feet between containers to permit aisle space.
(14) Glass containers will not be used unless they are original shipping containers.
NOTE:  Show slide 44
(15) Containers must be protected from the weather (if stored outside, cover).
(16) Store in approved cabinets, rooms and building.
(17) Containers must have lids and remain closed when not being filled.

NOTE:  Show slide 45
b. In the event that original containers cannot be used for storage, handling, transportation, etc, request containers by determining container requirement from CFR 49 or call the installation environmental office.
  
NOTE:  Show slide 46
c. HM/HW deposited in containers must be compatible with the container and with each other. Do not mix wastes. Examples of segregated wastes include:
	(1) Used oil and hydraulic fluids.
	(2) Solvents.
	(3) Paints and thinners.
	(4) Acids.

NOTE:  Show slide 47
d. Don’t mix hazardous materials. Certain hazardous materials are capable of posing an unreasonable risk to health, safety and property when mixed.

NOTE:  Show slide 48
 e.  The following are the requirements for a container to be classified as an “Empty Container”.(3% rule)
	(1) Old markings and labels must be removed or painted to avoid confusion regarding contents.
	(2) Ensure container is clean.
	(3) Ensure all documents pertaining to the contents have been annotated.
	(4) Turn-in of empty container not required if used for collection of used oils, solvents, etc.

NOTE:  Show slide 49 
f. Ensure containers meet the requirements. Remove or paint old markings and labels to avoid confusion about the contents. Annotate all documentation pertaining to the contents (tracking number). Turn in empty container(s) not required for collection of used oils, solvents, etc 
All HW containers must be marked and labeled when accumulation begins. 
Accumulation must be marked on the label.
	(1) Ensuring all information is annotated using permanent marking pen. 
		HW on the label on the container as are as follows: 
		(a) Used Material, (oil, solvents).
		(b) Start date.

NOTE:  Show slide 50
g. Stencil the common chemical name and the FSN on the HW containers legibly and permanently.
 		Examples of required labels are:
		(1) Waste- Paint-related material.
		(2) Waste -trichloroethylene.
		(3) Waste petroleum distillate.
		(4) Used Oil.
		(5) Used diesel fuel.
		(6) Used brake fluid.
For CONUS, some states impose stricter standards on POL products.  Check with 
your  local environmental office or DRMO to find out.

NOTE:  Show slide 51 and 52
h. Affix DOT approved HW labels on the container, preferably on the same side as other labels and markings. The placement is critical so that emergency personnel can identify and react to the contents accordingly. If more than one label is required, place labels side by side. Examples are:
		(1) Explosives
		(2) Flammable Gas
		(3) Flammable Solids
		(4) Flammable Liquids
		(5) Oxidizer
		(6) Poison
		(7) Radioactive
		(8) Corrosive
    (9) Misc

NOTE:	Conduct a check on learning and summarize the learning activity.	

5.	Learning Step / Activity 5. Identify satellite accumulation point requirements
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	10 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 53
	a.  SAPs are located near the site of generation, and they can accumulate up to fifty-five gallons of hazardous waste or up to one quart of acutely hazardous waste. Full or one year limit containers must be turned into a permitted or temporary storage area within 72 hours.  SAP must be formally designed and must meet Resource Conservation Recovery Act requirements.  In some states, additional requirements are even more stringent, so it’s wise to contact the environmental office for specific requirements.  A satellite accumulation point may be in a Motor Pool, Arms Room, Hospital Labs and NBC Room or all four locations.  You still need to take care of each location and check periodically.  General items to look for are:
	(1) Containers cannot be larger than 55 gallons or 1 quart for acutely hazardous waste.
	(2) Containers are located at or near the hazardous waste point of origination.
	(3) Containers are under control of the operator generating the waste.
	(4) Containers must be closed except when being filled.
	(5) Containers must be clearly identified with the contents of the hazardous waste.
	(6) Containers must be dated once first drop of waste is put into the container.
	(7) Full containers must be turned in within 72 hours.
 
	b.  SAP must be secured with a controlled access.  Warning signs must be posted and emergency telephone numbers posted with fire fighting Equipment onsite.  Do not accumulate incompatibles. 

NOTE:  Show slide 54
c. Generate discussion by asking students if they can identify and relate to the slide.  Reassure students that compliance is the right thing to do and that it will not happen overnight. In addition to the general requirements for storing HM/HW, good housekeeping habits are a necessity.

NOTE:  Show slide 55
d. Accumulation requirements for HW are generally identical to requirements for non-waste hazardous material. Hazardous waste accumulation requirements include:
	(1) Accumulation begins with the first drop of material in container.
	(2) The Unit Environmental Officer/Satellite Accumulation Manager is responsible for the accumulation point unless a designated person is otherwise assigned.
	(3) Maintain aisle space within the hazardous waste accumulation area to provide unobstructed movement of personnel and fire/spill control equipment in an emergency.
	(4) Annotate accumulation log with any deficiencies and corrections.  By regulations, this must be accomplished weekly.
	(5) Store by characteristics and separate like items by a dike, berm or wall in main accumulation areas.
	(6) Seal tightly, mark and label all containers in accumulation. Orient containers to ensure the identification of the contents are not obscured.
	(7) If available, containers are to be arranged on pallets in a hazardous waste accumulation structure that is covered, curbed, or have an (secondary containment) impermeable surface.
	(8) Flammable and reactive waste must be stored at least 50 feet from the property line or meet requirements for approved flammable containment. Quantities less than 500 gallons must be accumulated at least 25 feet from the property line, or 10 feet from any street, alley or public way.
	(9) Secure accumulation facilities and limit access, as determined by the unit.
	(10) Exercise the First In First Out (FIFO rule when issuing accumulated HM).

NOTE:  Show slide 56
e. General outdoor accumulation requirements differ minimally from those of indoor accumulation. Some pertinent requirements are as follows:
	(1) Protect a HW outdoor area from unauthorized access and inadvertent damage from vehicles or equipment
	(2) Place containers that hold free liquid on a curbed and impermeable surface, if available
	(3) If exposure to moisture or sunlight could create a hazard or adversely affect a container’s ability to hold a particular HW (i.e. ignitable waste), then place the container in an area with an overhead roof or cover with a plastic drum cover that does not obstruct the visibility of the labels.

NOTE:  Show slide 57
f.  Resource Conservation Recovery Act recognizes three types of HW accumulation:
	(1) Permitted
	(2) Temporary
	(3) Satellite Accumulation Points (SAP)
g. Permitted facilities may store wastes for longer than ninety days.  Their design moreover, management is beyond typical organizations.  For that reason, this lesson is limited to a discussion of temporary storage, and accumulation points.
h. Temporary storage areas may accumulate and store hazardous waste up to 90 days.
i.  SAPs can accumulate up to 55 gallons of a common waste stream (antifreeze, waste oil) or up to 1 gallon of an acute hazardous waste (DOT designation).

NOTE:	Conduct a check on learning and summarize the learning activity.	

6.	Learning Step / Activity 6. Identify compliance requirements for turn-in of HW items
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	5 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 58
a.  Turn in HM/HW items.  Identify compliance requirements for turn in of HM/HW items.

NOTE:  Show slide 59

b. Hazardous waste for turn-in must be properly packaged and labeled as outlined in installation policy or by the direction of the DRMO or the installation environmental office.
	(1) Ensure that hazardous waste containers are properly packaged for turn-in and free of leaks.
	(2) Prepare the paperwork. Check with your organization for the correct forms to be completed.
	(3) Off-post activities, including off-post training and garrison locations of most National Guard and Reserve units, require different methods of turning in HW. Contact the S-4 or environmental office for the required paperwork and turn-in procedures.

NOTE:  Show slide 60
c. Transporting hazardous waste requires special coordination.  Contact the closest Defense Reutilization and Marketing Office or DRMS for turn-in guidance. A contractor may be on an existing contract for transport.  If not, check the local environmental office for guidance.
	
NOTE:  Show slide 61
d. Transportation requirements. Many areas will require you to transport HW to the turn-in storage site.  Certain requirements and restrictions will apply.
	(1) HAZMAT- train and certify personnel IAW 49 CFR 172.700 and DOD 4500.9-R.
	(2) Take refresher training.
	(3) Make safety the primary concern.
	(4) Close containers tightly and ensure they are in good condition.
	(5) Secure the load to prevent spills.
	(6) Transport only compatible items in the same vehicle.
	(7) Ensure spill kits are readily available.
	(8) Do not smoke when transporting oxidizing waste combustible or flammable liquids or solids.
	(9) Know what to do in case of an accident.
	(10) Have emergency response telephone numbers on-hand.
   (11) Plan ahead when your unit is scheduled to deploy. Check with the chain of command for environmental requirements. Do not bring HW back to the home station unless absolutely directed to do so. Turn in HW at the deployed location.

NOTE:	Conduct a check on learning and summarize the learning activity.	

7.	Learning Step / Activity 7. Develop Inspection Checklist
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	10 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 62
   Develop a checklist that has identified areas where environmental problems are likely to occur within the company area.  Demonstrate the use of an environmental checklist found in TC 3-34.489, Appendix A to conduct an inspection of these certain areas.

NOTE:  Show slide 63
a. Vehicle Maintenance – Drip pans under vehicles (Are they there? Are they full? Is the drip residue properly disposed of?); leaks from vehicles; are parts lying around?  Trash; stained soil/concrete; spills.

NOTE:  Show slide 64
b. Weapons Maintenance – Are your Soldiers properly disposing of contaminated patches and cleaning supplies?  Are they keeping small lubricant bottles and refilling them when they are empty?

NOTE:  Show slide 65
c. CBRN Maintenance – Hazardous materials stored in proper storage area and segregated; MSDS available for hazardous materials on hand; damaged equipment properly marked and turned in; dispose of out dated chemical detection kits as HW; secondary containment for HM.

 NOTE:  Show slides 66 and 67
d.  Supply- self explanatory.  Discuss each item.
NOTE:  Show slide 68 and ask a question. 
e. When you are conducting fueling operations, what environmental consideration should you consider?
Some possible answers would be:
     Contain, cleanup, and report spills
     Spill kits are available and properly stocked
     Have drip pans and absorbent material available
     Location of fuel point
     Training of fueling personnel
     Protective equipment for personnel

NOTE:  Show slide 69
e. Enforce the use of field latrines instead of expedients such as “catholes”.  Know where your waste is going to.  Waste segregation from the mess area is a key factor in managing solid waste efficiently.

NOTE:  Show slide 70
f. This list of maneuver damage control goals can assist you in many ways in complying with regulatory requirements as well as reducing the cost of damages.

NOTE:	Conduct a check on learning and summarize the learning activity.	

8.	Learning Step / Activity 8. Provide necessary unit environmental training on the regulatory requirements.
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	5 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 71
a. It is the commander’s responsibility to ensure that the troops assigned to the company have had the necessary and required environmental training.

NOTE:  Show slide 72
b. There are many ways to meet these requirements.  Here is a list of courses that can be taken in the unit or on-line.  In addition, training information can be obtained from these sources and presented in a classroom environment.

NOTE:  Show slide 73
c. Each unit should have properly trained individuals to carry out these tasks.  A common problem with deployed troops, they do not know how to clean up a spill.  We have become very dependent on calling the fire departments to respond.  They very likely will not be there or not part of their mission to respond to spills in theater.  It is the commander’s responsibility to ensure the company staff are properly trained. It also good to train “teams” that are cross trained in these tasks

NOTE:	Conduct a check on learning and summarize the learning activity.	

9.	Learning Step / Activity 9. Train for Spill Prevention and Response
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	5 mins
		Media:	Computer Based Instruction (CBI)

	
NOTE:  Show slide 74
	a.  Spill response and prevention.  Often conducting site assessments the spill response equipment is as indicated in this photo.  If it has been used, it was not replaced.  If it is available, is often buried behind something else.  Responding to spills and preventing skills can reduce our liabilities and ensure force health protection for our troops.  

NOTE:  Show slide 75
	b.  We’re going to be talking about spill plans, and every unit should have a spill plan.  
	How to protect yourself if this spill does occur?  
	What the acronym REACT means?  
-Remove the source of the spill if possible
-Envelop the spill with absorbent materials or dirt by building a berm 
-Absorb the spilled fluids
-Containerize the spilled material and soil
-Transmit a report of the spill thru your command chain

NOTE:  Show slide 76
	c.  In the unit spill plan, it should state what equipment is necessary to have on hand to react to a spill, who is responsible for reacting to a spill, the emergency points of contact with the spill occurs , and who to report the spill to and what forms the to be filled out.  

NOTE:  Show slide 77
   d. During a spill or a spill response the primary thing is to protect yourself and those troops around you.  If you do not have the training to react to a spill then move out of the area.  Any minor spill of POL products can be cleaned up by Soldiers.  A minor spill is usually designated as 5 gallons or less (each installation is different) unless it is an acute hazardous waste. 

NOTE: Conduct a check on learning and summarize the learning activity.

NOTE:  Show slide 78 

NOTE:	Conduct a check on learning and summarize the learning activity.	

10.	Learning Step / Activity 10. Conduct inspections in accordance with the environmental checklist
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	10 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 79
a.  In preparation for your assessment, you should identify if there are any local supplements or command guidance to the self-assessment; check higher headquarters for similar aids specific to a unit’s location; obtain a copy of the last command inspection from higher headquarters; develop a self-assessment schedule and brief your Soldiers and the commander.  The next few pictures depict
	things you might find during the inspection.  We’ll refer to them as the GOOD, the BAD and the UGLY.

NOTE:  Show slide 80
b.  What you see that is good about this photo?  The product is labeled as diesel, in a fire extinguisher is nearby.  Where you see that as bad or ugly about this photo? Soil staining, the support for the nozzle, the fuel bladder is not labeled itself, the close proximity of an ignition source - lights, no vehicle barriers, the support stand for the fuel bladder.  

NOTE:  Show slide 81
c.  The good – four drums are in secondary containment.  
The bad, ugly – compressed gas cylinders are on their sides, no secondary containment for five gallon cans, one gallon cans and for the 55 gallon drums.  
NOTE:  Show slide 82
d.  The good – the tank has a vent . The bad, ugly – secondary containment is too small, tank is not labeled, five gallon cans of possible incompatible materials with the tank, no vehicle barriers, vehicles parked closely to the tank, no signage.

NOTE:  Show slide 83
   e.  The good – signage, secondary containment, covered, secured by a fence, drums are labeled.  The bad, ugly – no fire extinguisher observed, signs are written only in English, bungs are missing from 3 of 4 drums, staining in rack (poor housekeeping).

NOTE:  Show slide 84
   f.  The good – signage in two languages, secondary containment, segregation, fire extinguisher, covered drum fill ports.  The bad, ugly – next to a building where potential workers may be on the other side of the wall.   

NOTE:  Show slide 85
   g.  The good – covered from the heat, stormwater, secondary containment, vehicle barriers, enclosed in a fenced area.  The bad, ugly – potential ignition source on the other side of the short t-walls,  hose running through the containment area, no fire extinguisher.

NOTE:  Show slide 86
   h.  The good – overhead cover for drums, over packed drums, drums are on pallets, the area is fenced, phone numbers and MSDS required is posted.  The bad, ugly – no fire extinguishers observed, is this a hazardous material drop off point or a hazardous waste drop off point? (conflicting signs)  

NOTE:  Show slide 87
   i.  These are areas where you will often find environmental problems. 

NOTE:  Show slide 88
   j.  This action plan can be done after your inspection to fix problem areas.

NOTE:	Conduct a check on learning and summarize the learning activity.	

11.	Learning Step / Activity 11. Report any areas of significant non-compliance to chain of command with appropriate COA
		Method of Instruction:	Conference / Discussion
		Instructor to Student Ratio:	1:20
		Time of Instruction:	5 mins
		Media:	Computer Based Instruction (CBI)

NOTE:  Show slide 89
 a.	List areas of significant non-compliance with regulatory requirements that can not be readily  corrected at the company level and assistance is needed
 b.	Advise the chain of command of these areas with recommended COAs

NOTE:	Conduct a check on learning and summarize the learning activity.	

SECTION IV.	SUMMARY
Method of Instruction:    Conference / Discussion	
Instructor to Student Ratio is:    1:20	
Time of Instruction:   5 mins	
Media:    Computer Based Instruction (CBI)	
Check on Learning	
Determine if the students have learned the material presented by soliciting student questions and explanations.  Ask the students questions and correct misunderstandings.
	
Review / Summarize Lesson	
NOTE:  Show slide 90  
a.  Repeat the TLO for the lesson.

NOTE:  Show slide 91  
b.  Instructor must fill in this information prior to class for the installation.

NOTE:  Show slide 92  
c.  Contact DEI for more information.

NOTE:  Show slide 93  
d.  Answer any questions that the students may have on the material taught.

SECTION V.	STUDENT EVALUATION
Testing Requirements	NOTE: Describe how the student must demonstrate accomplishment of the TLO.  Refer student to the Student Evaluation Plan.	
		
Feedback Requirements	NOTE: Feedback is essential to effective learning.  Schedule and provide feedback on the evaluation and any information to help answer students' questions about the test.  Provide remedial training as needed.	

Appendix A - Viewgraph Masters

VIEWGRAPHS FOR LESSON 1:  052E5221 version 1

See attached PPTs

Appendix B - Test(s) and Test Solution(s)  (N/A)

Appendix C - Practical Exercises and Solutions  (N/A)

Appendix D - Student Handouts  (N/A)