U.S. Army Environmental Stewardship Branch Newsletter Volume 7, Issue 4 Our Mission The Georgia Department of Defense Environmental Stewardship Branch exists to support Commanders and their Mission by reducing environmental liabilities and promoting the US Army Environmental Stewardship Program
Our Vision Commanders maintaining readiness while acquiring the knowledge and resources to make informed decisions that protect and conserve today’s resources for tomorrow’s National Guard Soldiers and Citizens of Georgia.
Goodbye Summer—Hello Fall! ENVIRONMENTAL STEWARDSHIP BRANCH STAFF Dania
Aponte
Environmental and Planning Division Chief
(678) 569-6707
dania.g.aponte.nfg@mail.mil
Richard
Batten
Air & Water Program Coordinator
(678) 569-3970
richard.a.batten.nfg@mail.mil
Randy
Drummond
Director of Environmental Programs
(678) 569-6750
randy.m.drummond.nfg@mail.mil
Stephanie Garmon
Environmental Assessor - Northeastern GA
(678) 569-3776 stephanie.t.garmon.nfg@mail.mil
Frances
Grieme
eMS Program Coordinator/Budget Analyst
(678) 569-6749
frances.h.grieme.nfg@mail.mil
Michael
Holloway
— Deployed —
Towanna Isaacs
Environmental Assessor - NW GA/CNGC/ Central Atlanta/Recycling Coordinator
(678) 569-6752
towanna.s.isaacs.mil@mail.mil
Tangy
Johnson
Environmental Assessor - Ft. Stewart
(678) 569-9267
tangy.s.johnson.nfg@mail.mil
Felicia
Nichols
NEPA & Cultural Program Manager
(678) 569-6755
felicia.a.nichols2.nfg@mail.mil
Kerry
Platt
Hazardous Waste Specialist
(678) 569-6745
kerry.platt2.nfg@mail.mil
Megan
Spells
Environmental Assessor – Tifton/eMS Awareness Coordinator
(678) 569-8458
megan.e.spells.nfg@mail.mil
~Clay National Guard Center- 1000 Halsey Avenue, Building 70, Marietta, GA 30060~ November 2017
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CFMO-ENV Ongoing Projects and Activities
The CFMO-Environmental team has continued to strive towards keeping the Georgia Army National Guard ready and on track with environmental stewardship! You will find some informative articles to broaden your environmental knowledge. See below for interesting updates on the developments that have taken place over the past months and what new things are coming our way.
Air & Water Program: Vehicle Emissions—Page 3 GeMS Program: Annual Briefing—Page 4 Environmental Awards Program: Meet the Honorees—Pages 5 & 6 Recycling Program: There are benefits—Page 7 Product Spotlight: Pine Oil—Page 8 Hazardous Waste: New Regulation—Pages 9 & 10 Cultural Resources: Native American Consultation—Page 11
“So many people along the way, whatever it is you aspire to do, will tell you it can't be done. But all it takes is imagination. You dream. You plan. You reach. There will be obstacles. There will be doubters. There will be mistakes. But with hard work, with belief, with confidence and trust in yourself and those around you, there are no limits.” ~Michael Phelps~
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Air & Water Program
Mobile Air Emissions on Federal Facilities Why are Vehicle Emissions Required? Stationary sources of pollution – industry and commercial operations – are well known contributors to air quality issues. However, a significant amount of pollution is also produced from mobile sources, including gasoline and diesel powered cars and trucks. In the Atlanta metro area alone, there are over 3.5 million vehicles registered. With many of these vehicles being considered “commuters”, it starts to become clear why mobile air pollution can be a serious environmental and public health issue in Georgia. Emission testing is in place to help combat the amount of air pollution produced by mobile sources and help bring our pollutant loads under a defined regulatory limit.
Have you had your vehicle emissions checked? If you’ve registered your vehicle for 2017 in one of the thirteen metro Atlanta counties in Georgia (Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding or Rockdale County), and your vehicle is 1993-2014 model year gasoline-powered car or light duty truck, then your answer is “Yes”. But what you may not know is that according to Clean Air Act (CAA) Section 118(d): “Personal vehicles operated by employees who drive onto Federal facilities must be in compliance with the emission standards for the vehicle inspection and maintenance program area wherein the facility is located”. This requirement applies to any employee who drives their personal vehicle on a federal facility 60 or more days per year, regardless of whether their vehicle is registered in another county or state.
So what does this all mean? The Clean Air Act section 118(d) applies to military personnel or any civilian employee who drives more than 60 days per year onto a federal facility that is located within the thirteen identified counties. This includes Clay National Guard Center, Dobbins Air Reserve Base, and Fort Gillem. If you meet this criteria, you must have an up-to-date emissions inspection completed on your vehicle, and maintain proof of compliance, no matter where your vehicle is registered. This not only helps to ensure that we are in compliance with federal regulation, but also that we are doing our part in protecting the health of our soldiers and civilians.
For more information, please contact the Air & Water Program Coordinator, Richard Batten, Air & Water Program Coordinator, at richard.a.batten.nfg@mail.mil or (678) 569-3970.
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GA Environmental Management System (GeMS)
GeMS Annual Briefing What is eMS and what does it mean? Environmental Management System – the GAARNG’s management program that integrates environmental concerns into the GAARNG’s actions and activities.
How does GeMS operate? 1. The foundation of GeMS is spelled out in the Environmental Policy Statement. The TAG has signed the policy statement committing to preventing pollution, complying with all environmental laws and regulations, and continually improving. This policy statement has been posted in all facilities and communicated to all Soldiers and civilians. 2. GeMS is sustainability driven. Due to this partnership two significant aspects with objectives and targets have been chosen for tracking. The significant aspects are derived from the mandates in Executive Order 13693—”Planning for Federal Sustainability in the Next Decade.”
Water Use—NEW
Energy Use
OBJECTIVE: Reduce potable water consumption TARGET: Reduce 2% per year through the end of FY2025, relative to FY2007 baseline
OBJECTIVE: Reduce Energy Consumption TARGET: Reduce 2.5% per year through the end of FY2025, relative to FY2015 baseline
Fiscal Year 2016 Energy Reduction Update: Ongoing efforts (projects, awareness campaign, better data) have afforded an 8.8% reduction of energy consumption between 2015 and 2016 [11,082 million BTU(MBTU)]. Between FY2015 and FY2016, the Energy Use Intensity (EUI)— measure of the energy consumed (MBTU) per thousand square feet (kSF) of building space— was reduced by 13% .
The reductions are on target!
= POC: Frances Grieme, eMS Program Coordinator, at frances.h.grieme.nfg@mail.mil or 678-569-6749.
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Environmental Awards Program
Meet the Honorees, read about their efforts in the environmental field, and join us in celebrating the presentation of his Environmental Awards during the Environmental Quality Control Committee (EQCC) meetings during 2017.
SFC James Bramblett with the Dublin FMS
Pictured above: SFC James Bramblett (right), Environmental Officer of the Dublin FMS, Environmental Award Nominee BG Carden (right), Presenter.
displays a certain diligence when maintaining compliance with the environmental stand operating procedures (SOP), plans, and other regulatory requirements as they are explained to him by environmental personnel. Not only does he strive to comply with requirements and accomplish his responsibilities, he also tackles issues with other personnel, confusing information, and time constraints with an appropriate amount of assertiveness and flexibility. When non-compliance issues are noted they are corrected swiftly and rarely do I find repeated issues. SFC Bramblett’s FMS received no finds during the external EPAS, as he consistently corrects issues on site and follow up when information is needed.
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SSG Michael Cromer with the Griffin RC exemplifies all of the qualities a GAARNG Environmental Officer should have. He is thorough and diligent in all that he does and has excellent organizational skills. While the Supply SGT at Newnan, it was apparent that SSG Cromer had a firm grasp of not only the environmental program, but of all of his responsibilities. He is constantly proactive so that issues are addressed immediately and he takes time to go above the minimum requirements to assure that issues do not arise. Recently SSG Cromer was relocated from Newnan to Griffin. After the move, Newnan was left with the Supply Sgt. position vacant. SSG Cromer diligently worked with both facilities for around 3 months to ensure that Newnan retained its excellent condition while also completely reorganizing and getting up to speed on everything at Griffin.
Pictured above: SSG Michael Cromer (right), Environmental Officer of the Griffin RC, Environmental Award Nominee BG Carden (right), Presenter.
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Environmental Awards Program, Cont’d
SGT Joseph Spenard with the Atlanta CSMS, Confederate Avenue has been proactive in meeting the requirements of a Small Quantity Generator (SQG) and is quick to correct issues as they are found on site. He consistently completes the waste tracker with accuracy and has been flexible in working to meet new requirements and to make adjustments to meet the current requirements. As an Environmental Officer (EO), this is a part of his job responsibility. The commendable part is that he does this with little to no prompting on the part of CFMO – ENV. We can trust that his work will be completed to the best Pictured above: SGT Joseph Spenard (Left) Environmental of his ability without our having to spend excessive man-hours to Officer of the Atlanta Confederate Avenue, CSMS, Award Nominee verify the completion, accuracy and honesty put into his work to Environmental COL Simmons (right), Presenter. be compliant. These statements relating to his efforts to manage, process and track CSMS waste is a mark of an Environmental Officer especially accomplished in the area of waste compliance. *****************************************************************************************
For more information regarding the process, criteria, and submission forms go to the Environmental SharePoint page http://ngga-portal.ng.ds.army.mil/sites/CFMO/env/default.aspx. You might know of someone deserving to be the next nominee to receive an Environmental Award! For more information or if you have questions, please contact: Frances Grieme, Environmental Awards Lead, at frances.h.grieme.nfg@mail.mil or (678) 569-6749.
“Excellence is never an accident; it is the result of high intention, sincere effort, intelligent direction, skillful execution and the vision to see obstacles as opportunities.” ~Anonymous~
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Recycling Program Recycling Benefits With all the talk of recycling and how it benefits the earth, sometimes we only look at the big picture - meaning “we are saving the earth” - but what does that really mean for the GAARNG? It is better for the GAARNG to recognize how recycling benefits the installation as a whole. As of now CNGC has a small recycling program but with the continuous efforts of everyone here at Clay and the readiness centers across the state we can grow the program to possibly achieve the benefits of a Qualified Recycling Program (QRP). Country-wide I have seen and heard of several successful recycling programs that have given back to the welfare of the soldiers and their families. The technical term for the recycling program is known as the Qualified Recycling Program or QRP. The military across all branches are successfully taking “going green” to a whole new level with the efforts of this program. A QRP, which was authorized by the National Guard Bureau in 2010, is a self-sustaining program in which it conducts direct sales of recyclable materials to the public and retains the proceeds to support recycling and environmental efforts state-wide. It also achieves the goal of diverting its reusable material from the landfill waste stream, it reduces the volume of waste produce, lessens the impacts on natural resources, and returns revenue to the organization that is used to make the QRP self-sustaining. With a program such as this we want to look at the benefits of the program and what could be or should be done with the funds from the sales of the program. After all QRP operating costs are covered, revenue may be used to support other activities in accordance with law. This includes pollution prevention, energy conservation and occupational safety programs. Under Title 10 U.S. Code, Section 2577 all Commodity sales proceeds can only be used for three purposes, in the following priority order: a. “…to cover the costs of operations, maintenance, and overhead for processing recyclable materials at the installation (including the cost of any equipment purchased for recycling purposes). “ –and if a balance remains, then: b. “Not more than 50% of that balance may be used at the installation for projects for pollution abatement, energy conservation, and occupational safety and health activities. A project may not be carried out under the preceding sentence for an amount greater than 50% of the amount established by law as the maximum amount for a minor construction project.” c. “The remaining balance available to a military installation may be transferred to the non-appropriated morale and welfare account of the installation to be used for any morale or welfare activity.” With these purposes being the primary focus of the QRP, the process of recycling is helping the military become more sustainable and going green, while abiding by Executive Orders mandated by our Commander and Chief. As military, and all of you who support the military, let’s try to strive to uphold our end by participating in recycling efforts.
POC: Towanna Isaacs, Recycling Coordinator, at towanna,.s.isaacs, mil@mail.mil or (678) 569-6752.
“Here is your country. Cherish these natural wonders, cherish the natural resources, cherish the history and romance as a sacred heritage, for your children and your children's children. Do not let selfish men or greedy interests skin your country of its beauty, its riches or its romance.” ~~Theodore Roosevelt~~
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Compliance Program Product Spotlight: Pine Oil In the short time that I have been with CFMO as an Environmental Assessor I have noticed one thing that all facilities have in common, Pine Oil. All the facilities have large amounts of Pine Oil in cleaning closets, in storage rooms and sometimes in flammable storage. So, what is Pine Oil? Pine Oil is an essential oil that is obtained from stumps, needles, twigs and cones of a variety of pine species. The concentration varies from cleaner to cleaner from 19% to 60%. As of 2006, there were 88 active pine oil registrations. Pine oil is used for general cleaning, disinfectant, sanitizer, microbicide, virucide, and insecticide. Pine oil has been shown effective against brevibacterium ammoniagenes, candida albicans, enterobacteraerogenes, escherichia coli, gram-negative enteric bacteria, household germs, gram-negative household germs such as those causing salmonellosis, herpes simplex types 1 and 2, influenza type A, influenza virus type A/Brazil, influenza virus type A2/Japan, intestinal bacteria, klebsiella pneumoniae, odor-causing bacteria, mold, mildew, pseudomonas aeruginosa, salmonella choleraesuis, salmonella typhi, salmonella typhosa, serratia marcescens, shigella sonnei, staphylococcus aureus, streptococcus faecalis, streptococcus pyogenes, trichophyton mentagrophytes. (EPA Reregistration Eligibility Decision for Pine Oil Case 3113 September 2006) A pine oil cleaner with a 60% concentration has a health hazard of 1 and a fire hazard of 2. What does that mean? Pine oil can be slightly hazardous to your health, so don’t drink it and it could be a mild skin irritant. Pine oil has a flashpoint above 100 degrees Fahrenheit; so where can you store Pine oil? If you have room in your flammable storage locker it can go here and if not store with like materials. Avoid storing with oxidizing agents. If you are uncertain about segregation of materials we have a great tool— Table (2-1) in your Hazardous Waste Management Plan. Do not discharge into lakes, streams, ponds, or public waterways. When your container is empty you can throw the empty container in the trash. POC: Stephanie Garmon, Environmental Assessor, at stephanie.t.garmon.nfg@mail.mil or (678) 569-3776.
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Hazardous Waste Program Environmental Protection Agency (EPA) 2016 Hazardous Waste Generator Improvement Rules The new rule, which was finalized by the EPA in October 2016 was officially adopted by the Georgia Environmental Protection Division (GAEPD) on September 28, 2017. EPA noticed ambiguities, inconsistencies, gaps and a lack of flexibility in the regulation during its enforcement over the last 36 years. Once the need for change was recognized, it took a little over a year to have the new rule drafted. Hundreds of comments were received once the draft was made available. The new rule incorporates over 60 changes to the regulation. This article offers a brief review of these changes. GAARNG CFM – E is currently working to incorporate these changes in our written guidance to promote a better understanding the changes and how they will be incorporated in our existing program. Allows a very small quantity generator (VSQG) (previously known in the federal regulations as "conditionally
exempt small quantity generators"- CESQGs) or a small quantity generator (SQG) to maintain its existing generator category in the case of an event in which the VSQG or SQG generates a quantity of hazardous waste in a calendar month that would otherwise bump the facility to the next generator status – this is called an episodic event. It’s important to note that several conditions apply to an episodic event. One condition is the notification 30 day prior to a planned episodic event or notification 72 hours after an unplanned episodic event. Allows very small quantity generators (VSQGs) to send hazardous waste to a large quantity generator (LQG) that
is under the control of the same person and consolidate it there before sending it on to management at a RCRAdesignated facility. Once again, this depends on meeting several conditions under the regulation. Requires periodic re-notification for SQGs every four years (SQGs only notify once under the current system). Revises the regulations for labeling and marking of containers and tanks to clearly indicate the hazards of the
hazardous waste contained inside. Clarifies inconsistent guidance on which generator category applies when a generator generates both acute and
non-acute hazardous waste in a calendar month, revises the regulations for completing the RCRA biennial report. Moves a number of the generator regulations that are currently located in other parts of the hazardous waste
standards into 40 CFR part 262 to replace the current lists of cross references, additionally it corrects inadvertent errors in the regulations, obsolete programs, and unclear citations.
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Hazardous Waste Program, Cont’d New Emergency Response Requirements ASQGs and LQGs must document that they have attempted to make arrangements with local emergency responders and keep such documentation in the facility's operating record. New and existing LQG must submit "quick reference guides" with key information regarding waste managed at their site to local responders. Each GaARNG site’s specific local emergency responders and Local Emergency Planning Committee (LEPC) need to be identified to ensure compliance with this requirement. A LEPC is a committee appointed by the State Emergency Response Commission (SERC) and is required by the EPAs Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA).
Clarification and Additional Waste Determination Requirements Hazardous waste determinations for each solid waste must be made at the point of waste generation. That determination relies on accurate identification of the materials contained in the solid waste. Specific records that are required to support a generator’s hazardous waste determinations have been identified in new Code of Federal Regulations (CFR) §262.11(f). State inspectors have the authority to review these records for accuracy. Although EPA strongly recommends a best management practice of documenting non-hazardous waste stream determinations, generators are not required to document this. Inspectors have the existing authority to require a generator to perform a waste determination during an inspection to substantiate the classification as non-hazardous if no documentation exists.
Conditions for Exemption vs. Independent Requirements These conditions deal with the satellite accumulation of waste. The specific requirements of a SAA, such as training, days waste may remain in a SAA, preparedness and spill prevention, and labeling (or marking), must be met or the facility will not be exempt from obtaining a storage permit. Essentially, this means an inspector who finds waste in a SAA exceeding that site’s generator status storage time limits (90/180/270) could result in being charged with operating a non-exempt storage facility in addition to being a generator. Independent requirements refer to how the determination of generator status was made, ensuring hazardous waste is shipped on a manifest, and generally most generator recordkeeping Failure to meet an independent requirement will likely result in some form of enforcement action for violating that particular requirement (e.g., a notice of violation, civil or criminal penalty, or injunctive relief under RCRA Section 3008). If you have any questions, need assistance with your facility’s environmental program, or are interested in discussing current or future activities performed at your facility please contact Ms. Megan Spells, GaARNG’s Compliance Manager, at megan.e.spells.nfg@mail.mil , or Kerry Platt, GaARNG’s Hazardous Waste Manager, at Kerry.platt2.nfg@mail.mil for additional information.
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Cultural Resources
Federally recognized Native American Tribes are considered “domestic dependent nations” by the U.S. federal government. As such, they exercise the authority to govern themselves within the borders of the United States. The Georgia Army National Guard (GAARNG) is mandated by federal law, regulation and policy to consult with federally recognized Native American Tribes, who have ancestral ties to lands in Georgia, on proposed projects that may potentially affect properties or resources of religious and/or cultural significance to the tribes. Those federal laws, regulations and policy are:
National Historic Preservation Action (NHPA) Native American Graves Protection and Repatriation Act (NAGPRA) Archaeological Resources Protection Act (ARPA) American Indian Religious Freedom Act (AIRFA) National Environmental Policy Act (NEPA) Executive Order 13007 – Indian Sacred Sites Consultation and Coordination with Indian Tribal Governments Executive Order 13175 – Consultation and Coordination with Indian Tribal Governments Army Regulation (AR) 200-1 Department of Defense American Indian and Alaska Native Policy
Government to Government Native American Consultation is an on-going part of the GAARNG’s Environmental Cultural Resources Management Program. The GAARNG participates in yearly consultation meetings to discuss proposed projects, our current inventory of cultural resources and how we manage those resources, along with issues and concerns of the tribes. Consultation can also occur on a project by project basis as needed. The GAARNG hosted the first official consultation meeting in September 2002. Over the years, neighboring ARNG states have joined efforts to share the meeting cost and responsibilities. Each state ARNG takes a turn planning and hosting the meeting in their state. This year’s consultation meeting was scheduled for September 11-14 in Atlanta, Georgia. Unfortunately, the meeting was cancelled due to dangerous weather conditions caused by Hurricane Irma. As a result, the contract must be renegotiated. We are currently working to modify the contract and reschedule the meeting.
POC: Felicia Nichols, Cultural Resources Manager, at felicia.a.nichols2.nfg@mail.mil or (678) 569-6755.