Policy Memorandum #22

Water Pollution Management Program for Maintenance Facilities

IMHM-PWE                                                                                                1 August 2012


MEMORANDUM FOR SEE DISTRIBUTION

SUBJECT:  United States Army Garrison Humphreys Policy Letter #22, Water Pollution Management Program for Maintenance Facilities


1. The proponent for this policy is the Directorate of Public Works.

2. This policy is effective immediately.  It remains in effect until rescinded or superseded. 

3. References.

a. AR 200-1, Environmental Protection and Enhancement, 13 Dec 07, effective date 23 Dec 07.

b. US Forces Korea (USFK) Regulation 201-1, Environmental Governing Standards, 18 Jun 12.

 c. Technical Manual (TM) 38-410, Storage and Handling of Hazardous Materials, 13 Jan 99.

4. Applicability.  This policy applies to:

 a. All USAG-Humphreys Headquarters directorates and organizations, all installation support activities and organizations, and tenant units and organizations within USAG-Humphreys and Area III.

b. All permanently or temporarily assigned active duty military and reserve components at USAG-Humphreys and Area III.

 c. All appropriated and non-appropriated funded US and Local National activities permanently or temporarily tenant on USAG-Humphreys and Area III.

 d. All Army and Air Force Exchange Service (AAFES) and all Defense Commissary Agency (DECA) activities permanently or temporarily tenant on USAG-Humphreys and Area III.

5. Purpose.  The purpose of this policy is to reduce water pollution from ground and aviation maintenance facilities located at USAG-Humphreys and Area III.  This policy establishes guidelines which will help maintain the chemical, physical, and biological integrity of point and non-point water sources by integrating concepts designed to prevent, reduce, and eliminate pollution.

6. Objective.  The objective of this policy is to prevent contaminants, such as petroleum products, cleaning compounds, solvents, and sediments from being discharged onto the land or into adjacent streams.  This policy establishes specific procedures and responsibilities for the operation of ground and aviation maintenance facilities to ensure that only the highest quality of water is being discharged, thereby keeping pollution to an absolute minimum.

7. Responsibilities.

 a. Directorate of Public Works (DPW) Environmental Division will:

  (1)  Conduct semi-annual inspections of maintenance facilities and areas to determine compliance with the environmental rules, regulations, standards, and this policy.

  (2)  Advise and provide guidance in the operation of water pollution abatement equipment (oil/water separators, gate valves, skimmers, etc).

  (3)  Conduct training in proper controls and procedures for abatement.

  (4)  Coordinate the removal, transportation, and disposal of used petroleum, oils, and lubricant (POL) products and hazardous waste.  This may be performed by contract or through in-house assets.

  (5)  Coordinate the maintenance of water pollution abatement equipment to include periodic cleaning and sediment removal from oil/water separators.

 b. Unit Commanders and Organization Supervisors will:

  (1)  Assign a primary and alternate unit or organizational Environmental Officer (EO).

  (2)  Ensure personnel assigned duties as primary and alternate EOs receive training within three months after appointment.

  (3)  Implement this policy and correct identified deficiencies.

  (4)  Provide an EO to accompany the Environmental Division personnel during environmental inspections.

  (5)  Notify the USAG-Humphreys DPW Environmental Division immediately when someone other than the Unit/Organization EO or USAG-Humphreys DPW Environmental Division personnel conducts an environmental inspection of any facility within area of responsibility and operation.  This will include, but not limited to Command Inspections, Local National Governmental Officials, US Forces Korea, Eighth US Army, etc.

 c. Unit and Organizational Primary and Alternate EO will:

  (1)  Report the malfunction any water pollution abatement equipment utilizing DPW, maintenance service order (MSO) procedures.

  (2)  Immediately call 911 to report the release or spill of POL in accordance with the following:

  (a)  A release of 25 gallons or greater of POL product.

  (b)  Any amount of POL that has reached any surface water, to include storm drains, storm ditches, catch basins, streams, rivers, etc or permeates the soil.

  (c)  Any amount of POL that has flowed off-post or occur off the installation.

  (d)  Spills that occur after duty hours, weekends, or holidays.

  (e)  If in doubt, notify and report.

  (3)  Cleanup any spill or release of a non-waterborne release or spill of a POL product as directed by the USAG-Humphreys DPW Environmental Division, Fire Department, or Incident Response Commander of all other releases or spills.

  (4)  Report and coordinate the disposal of hazardous wastes with the USAG- Humphreys DPW Environmental Division.

  (5)  Coordinate the removal of used and waste POL with the USAG Humphreys DPW Environmental Division and HAZMART.

  (6)  Perform unit or organizational maintenance of water pollution abatement equipment to include the following:

  (a)  Clean wash rack, washing pads, and drainage trenches.

  (b)  Dispose of trash in proper, designated trash collection container or dumpster.

  (c)  Remove all sediments from the drainage trenches and coordinate with USAG-Humphreys DPW Environmental Division for disposal at the Contaminated Soil Bioremediation Facility (Land Farm).  DO NOT dispose of any contaminated soil, suspected contaminated soil, or absorbent material in any solid waste disposal receptacle (dumpsters, trashcans, drums, etc).

  (d)  Keep trash and debris from clogging grates and drain pipes.

  (e)  Keep covers on used oil storage containers.

  (f)  Cleanup spilled POL.

  (g)  Keep trash and other debris out of oil/water separators (O/WS).

  (h)  Submit a maintenance service order (MSO) to DPW for any malfunction with installed equipment and fixtures (leaking faucets, unscheduled power outage, etc).

           (i)  Keep dumpster lids closed at all times except when depositing refuse.

  (7)  Conduct monthly and quarterly inspections of maintenance facilities and areas to determine compliance with environmental laws, regulations, standards, and this policy.

  (8)  Ensure environmental training is placed on the unit and organizational training schedule and conducted at least semi-annually.  Coordinate with the USAG- Humphreys DPW Environmental Division for assistance with training preparation as needed. Additionally, it is recommended all inspections be documented on the unit training calendar.

  (9) Manage service of all aboveground storage tanks (AST).  This will include, but is not limited to, ensuring the secondary containment drain valves are always kept closed, except when draining accumulated water after a rain event, submitting MSO for cracks and breaches in the secondary containment system, ensuring fuel is not placed in any tank permanently or temporarily taken out-of-service, etc.
8. Procedures.

 a. General.

  (1)  Vehicle washing and steam cleaning operations will only be performed on wash racks with oil/water separators, or on specially prepared areas approved by the USAG Humphreys DPW Environmental Division at maintenance facilities not equipped with wash racks.

  (2)  Implement controls to prevent spills or releases caused by performing maintenance operations.

  (3)  Immediately cleanup spills of POL and hazardous materials.  Absorbent materials must be applied to all POL products released to the ground within five minutes after release.  Cleanup of the absorbent must be accomplished no later than one hour after release.

  (4)  Properly dispose of used POL and hazardous waste.

  (5)  Maintain a sufficient supply (enough to completely absorb a release of 25 gallons) of absorbent material stocked on-hand within the immediate vicinity of all areas where the threat of spill or release is imminent. Never flush a spill with water.

  (6)  Segregate new absorbent material from used. Mark containers used to store the absorbent materials appropriately (Used Dry Sweep, Clean Dry Sweep, etc).

  (7)  It is recommended that units and organizations use organic types of absorbents that can be treated at the USAG-Humphreys Contaminated Soil Bioremediation Facility (Land Farm). Absorbent pads, brooms, pillows, etc. should be used only in an emergency when no organic absorbent is available. Examples of organic absorbents include clay absorbents (dry sweep), sand, sawdust, etc.

  (8)  Segregate new rags from used rags.  DO NOT dispose of used rags in dumpsters or any other solid waste collection receptacle.

  (9)  All approved exceptions to any part of this policy will be available for inspection and will be presented upon request or displayed in a conspicuous location for anyone entering the facility to read.  No exception to this policy is permanent and expires when the requestor leaves or after one year of the date on the Exception of Policy Approval.

 b.  Wash racks.

  (1)  Pressure washers and steam cleaners will only be used on wash racks with operational oil/water separators.  USAG-Humphreys DPW Environmental Division approves requests for exceptions to this policy in writing provided the requesting unit or organization submits a complete waiver request.  The USAG-Humphreys DPW Environmental Division will issue a temporary permit allowing this activity based on the justification and site-inspection. If a temporary permit is issued, it will be kept on site where the washing or cleaning operations are being performed.  The USAG-Humphreys DPW Environmental Division will terminate washing or cleaning operations immediately if this permit is not on site or discover violations of the permit conditions.

  (2)  Garbage, POL, debris, or contaminated materials will not be placed into or introduced into the wash rack (O/WS) system.  Garbage and other solid waste is to be disposed of in a dumpster or other authorized refuse collection receptacle and used POL is to be disposed of at the nearest used POL collection point.

  (3)  Units and organizations will not abuse the wash rack.  Examples of abuse are:

  (a)  Parking vehicles on curbs or back walls,

  (b)  Operating without grates installed,

  (c)  Leaving unused hoses lying on wash rack,

  (d)  Dumping POL into the O/WS, and

  (e)  Operating when the O/WS is in need of maintenance.

  (4)  Vehicle washing operations will cease immediately when maintenance crews or used POL removal contractor arrives to conduct maintenance or remove used POL.

  (5)  Units and organizations are responsible for removing and properly disposing of floating debris in O/WS, sand, and all other sediments from the wash rack drainage trenches.  Coordinate with the USAG-Humphreys DPW Environmental Division for disposal at the Land Farm facility.

  (6) DO NOT use any soaps, detergents, cleaners, cleaning compounds, solvents, etc, unless the product is approved in writing by USAG-Humphreys DPW Environmental Division.  Written approval from USAG-Humphreys DPW Environmental Division will be maintained on-site during the wash operations.  USAG-Humphreys DPW Environmental Division will immediately stop vehicle or aircraft wash operations if the exception to policy or written approval cannot be presented.

 c. Maintenance Bays.

  (1)  The use of cleaning compounds and solvents is restricted, to indoor usage only, at all maintenance facilities.

  (2)  Caution to prevent POL spills or releases in the bay is essential.  Immediately clean up all spills or releases of any amount (within five minutes after release).  Use of an absorbent material (an organic absorbent such as dry sweep is preferred) to clean up a spill or release.  DO NOT wash spilled POL into floor drains, floor grates, or out of bay doors.

  (3)  No POL product (new or used) will be disposed of in an oil/water separator.

  (4)  Washdown of maintenance bays facilities (including aircraft hangers) is permitted.  DO NOT wash spilled POL into floor drains, floor grates, or out of bay or hanger doors.  DO NOT use any soaps, detergents, cleaners, cleaning compounds, solvents, etc, unless the product is approved in writing by USAG-Humphreys DPW Environmental Division.  Written approval from USAG-Humphreys DPW Environmental Division will be maintained on-site during the wash down operations.  USAG-Humphreys DPW Environmental Division will immediately stop bay or hanger wash down operation if the exception to this policy or written approval cannot be presented and report this violation to the Chain of Command.

  (5)  Washing vehicles (including aircraft) inside maintenance bays and near the maintenance building, regardless of whether the facility is serviced by a functional oil/water separator, is strictly PROHIBITED unless approved in writing by the USAG- Humphreys DPW Environmental Division.  This written approval will be readily available when requested.  If the approval cannot be presented, USAG-Humphreys DPW Environmental Division will immediately stop the washing operation and report this violation to the Chain of Command.

  (6)  Maintain a sufficient supply (enough to completely absorb a release of 25 gallons) of absorbent material stocked on-hand within the immediate vicinity of all areas where the threat of spill or release is imminent. Never flush a spill with water.

  (7)  Segregate new absorbent material from used.  Mark containers used to store the absorbent materials appropriately (Used Dry Sweep, Clean Dry Sweep, etc). Ensure all containers have lids and they are kept closed at all times, with the exception of adding or removing contents.

  (8)  It is recommended that units and organizations use organic types of absorbents that can be treated at the USAG-Humphreys Contaminated Soil Bioremediation Facility (Land Farm). Absorbent pads, brooms, pillows, etc., should be used only in an emergency when no organic absorbent is available. Examples of organic absorbents include clay absorbents (dry sweep), sand, sawdust, etc.

  (9)  Segregate new rags from used rags. DO NOT dispose of used rags in dumpsters or any other solid waste collection receptacle.

 d. POL Storage and Dispensing Areas.

  (1)  Storage or dispensing of POL directly over or in close proximity to storm drains is prohibited. POL dispensing should be a minimum of 25 feet away from any storm drains, ditches, grated trenches, etc.

  (2)  Drip pans are to be used at dispensing areas.  Drip pans will be inspected after rain and serviced regularly to prevent overflow. Spill and release procedures in accordance with paragraph 7c (3) will immediately be executed for any drip pan that overflows.

  (3)  Any spill or release must be cleaned up immediately. Cleaning a spill is accomplished by the use of an absorbent material (an organic absorbent is preferred).  Spills must be reported in accordance with the procedures outlined in paragraph 7c (3).

  (4)  Maintain a sufficient supply (enough to completely absorb a release of 25-gallons) of absorbent material stocked on-hand within the immediate vicinity of all areas where the threat of spill or release is imminent.  Never flush a spill with water.

  (5)  Segregate new absorbent material from used.  Mark containers used to store the absorbent materials appropriately (i.e. Used Dry Sweep, Clean Dry Sweep, etc.). Ensure all containers have lids and they are kept closed at all times, with the exception of adding or removing contents. 

  (6)  It is recommended that units and organizations use organic types of absorbents that can be treated at the USAG-Humphreys Contaminated Soil Bioremediation Facility (Land Farm). Absorbent pads, brooms, pillows, etc. should be used only in an emergency when no organic absorbent is available. Examples of organic absorbents include clay absorbents (dry sweep), sand, sawdust, etc.

e. Line.

  (1)  Vehicles will have adequate drip pans to collect leaking POL materials.  Drip pans may be self-fabricated or procured.  All drip pans are to be inspected and emptied after every rain event. Collected product will be transferred to the used POL facilities before drip pans fill and overflow.  Implement spill and release procedures in accordance with paragraph 7c (3) in the event a drip pan with a POL and water mixture overflows.
 
  (2)  Any spill or release must be cleaned up immediately.  Cleanup of a spill is accomplished using an absorbent material (organic absorbent preferred).  Spills must be reported in accordance with the procedures outlined in paragraph 7c (3).

  (3)  Maintain a sufficient supply (enough to completely absorb a release of 25-gallons) of absorbent material stocked on-hand within the immediate vicinity of all areas where the threat of spill or release is imminent. Never flush a spill with water.

  (4)  Segregate new absorbent material from used. Mark containers used to store the absorbent materials appropriately (i.e. Used Dry Sweep, Clean Dry Sweep, etc.). Ensure all containers have lids and they are kept closed at all times, with the exception of adding or removing contents. 

  (5)  It is recommended that units and organizations use organic types of absorbents that can be treated at the USAG-Humphreys Contaminated Soil Bioremediation Facility (Land Farm). Absorbent pads, brooms, pillows, etc. should be used only in an emergency when no organic absorbent is available. Examples of organic absorbents include clay absorbents (dry sweep), sand, sawdust, etc.

  (6)  Segregate new rags from used rags. DO NOT dispose of used rags in dumpsters or any other solid waste collection receptacle.

  (7)  No maintenance, other than preventative maintenance checks and services (PMCS), will be performed on the line. 

  (8)  DO NOT drain oil of any kind, antifreeze, or any other POL related fluid on the line.  Perform these operations in the maintenance bay.  No exception to this policy will be approved.

  (9)  Washing vehicles on the line is strictly PROHIBITED.  No exception to this policy will be approved.

 f. Cleaning Compounds and Solvents.

  (1)  Cleaning compounds and solvents are restricted to indoor use only.

  (2)  Do not place any used solvent or cleaning compound in any O/W separator or in any used oil tank, drum, pod, or any other container for collecting used oil, contaminated fuel, or waste antifreeze.  Comingling of these various products could cause serious safety, health, and environmental reactions.

  (3)  DO NOT use any soaps, detergents, cleaners, cleaning compounds, solvents, etc., unless the product is approved in writing by USAG-Humphreys DPW Environmental Division.  Written approval from USAG Humphreys DPW Environmental Division will be maintained on-site during the wash operations.  USAG-Humphreys DPW Environmental Division will immediately stop vehicle or aircraft wash operations immediately if the exception to policy or written approval cannot be presented.

 g. Hazardous Waste Accumulation Points (HWAP) and Used POL Storage Facilities.  All Units/Organizations on USAG-Humphreys will participate in the Curbside Waste Pickup Program.

  (1)  Used POL, contaminated fuel, and all other liquid hazardous and nonhazardous wastes will be collected in five gallon pre-marked containers provided by the HAZMART and USAG-Humphreys DPW Environmental Division.  No other type or size of container is authorized for routine collection.  Units and Organizations are responsible for the serviceability, accountability, and upkeep of the containers provided. Contact HAZMART at 753-7710, if container condition is considered unserviceable.

  (2)  Solid HW may be collected in any type of compatible container and placed in the HWAP for removal.

  (3)  HAZMART will be notified at 753-7710 at least three days prior to any scheduled maintenance event (e.g., quarterly maintenance cycles, FTX recovery, etc.) to coordinate for additional containers in support of the anticipated increase in the quantities of POL products generated.  The Unit/Organization will not take it upon themselves to use any container not provided by the HAZMART, unless in possession of written permission from the USAG-Humphreys DPW Environmental Division.  A Notice of Violation will be forwarded to the highest Unit/Organization Chain-of-Command and the Garrison Commander for failure to comply with this paragraph.

  (4)  For any unscheduled maintenance event, HAZMART will provide additional containers as needed. HAZMART will respond within 30 minutes after receiving the additional support request, but no longer than one hour 30 minutes after the support request. If an emergency occurs after duty hours, on weekends, or holidays, the EO will contact emergency services (911, Fire Department) and the USAG-Humphreys DPW Environmental Division.

(5)  Unit EO will conduct the weekly HWAP inspection.  Unit or organization is responsible for ensuring the inspection is conducted and corrections are made of deficient areas identified by the inspection.  The weekly HWAP inspection will be conducted regardless of whether EO is on leave, sick, on a FTX, US or Korean, or training holidays, etc. Inspection records must be maintained for four years.

  (6)  Site specific spill contingency plans will be maintained at each HWAP.

  (7)  The unit/organization is responsible for the serviceability and upkeep of the HWAP collection covered secondary containment pallet (clamshell) provided by USAG- Humphreys DPW Environmental Division and HAZMART.  Damaged or unserviceable containers will be reported immediately to the HAZMART at 753-7710.

 (8)  Personnel handling HW must have immediate access to another person by visual or voice contact or to an internal alarm/emergency communication device.

(9)  Ensure HWAP has bilingual signs that read “Danger Unauthorized Personnel Keep Out” posted and visible from any approach to the HWAP and legible from at least 25 feet and unintentional or unauthorized entrance prevented?

h. Compressed Gas Cylinders.

  (1)  Compressed gas from cylinders will not be used without reducing the pressure through a regulator that is designed for that purpose. 

 (2)  Cylinder valves will be opened slowly to prevent a sudden discharge of gas.

  (3)  Compressed gas will not be used to dust off clothing or other objects.

  (4)  For safety purposes, all cylinders will always be considered full and corresponding care exercised.


  (5)  Full and empty cylinders will be stored separately and marked as “FULL” or “EMPTY” appropriately.

  (6)  Nonflammable gas cylinders will be stored a minimum of 35’ from flammable gas cylinders.

  (7)  Cylinders will never be lifted by grasping the valve or valve protection cap.

  (8)  Cylinders will never be used near heat sources where temperatures in excess of 130o F may be encountered.

  (9)  Cylinders will be protected from dampness, and filled cylinders must be protected against excessive rise in temperatures from direct rays from the sun and other heat sources.

  (10)  Smoking is prohibited within 50 feet of compressed gas storage areas.  “NO SMOKING” signs will be posted and visible from each accessible side of the storage area.

  (11)  Cylinders with valves must be stored with the valve protector cap securely in place.

  (12)  Cylinders must be strapped or chained securely to a stationary object to prevent tilting or leaning.

9. Request for Waiver.  Waivers from any part of this policy may be granted by the USAG-Humphreys DPW Environmental Division.  All requests for waiver must be signed by the Unit Commander or Organization Supervisor and submitted with all supporting documentation to the USAG-Humphreys DPW Environmental Division for final approval.  Written waivers approved by the USAG-Humphreys DPW Environmental Division will be maintained on-site during the applicable operations.

10.  Enforcement.  Failure to comply with the provisions of this policy could result in:

a. Adverse UCMJ for active duty military members or adverse administrative action for civilian employees.

b. Removal of water faucets or disconnection from water utility.

11.  Point of contact is the DPW Chief, Environmental Division, 753-7964.

 

                                                                             DARIN S. CONKRIGHT
                                                                             COL, SF
                                                                             Commanding

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Date created: 11/19/2010 3:45:20 PM
Date last updated: 1/16/2013 2:16:03 PM