ENVIRONMENTAL PROTECTION AND ENHANCEMENT

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1 State of Minnesota Minnesota Army National Department of Military Affairs Guard Regulation Adjutant General s Office Saint Paul, MN Effective ENVIRONMENTAL PROTECTION AND ENHANCEMENT Summary. This regulation provides environmental protection and enhancement policy for the Minnesota Army National Guard. Applicability. This regulation applies to all Minnesota Army National Guard Personnel, units and organizations. Suggested Improvements. The proponent of this regulation is the Facility Management Office, Environmental Division (FMO-E). Users are invited to send comments and suggested improvements on DA Form 2028 (Recommended Changes to Publications and Blank Forms) directly to Department of Military Affairs, Facility Management Office, ATTN: MNAG-FMO-E, Highway 115, Little Falls, MN Distribution. A (Army) * An electronic version of this regulation may be found at * This regulation supersedes, dated 15 October 1991 BY DIRECTION OF THE GOVERNOR: OFFICIAL: ///signed/// EUGENE R. ANDREOTTI Major General, MN ANG The Adjutant General JAMA M. DAVIDSON MAJ, SC, MN ARNG Facility Management Officer

2 Table of Contents Chapter 1 Introduction, Goals, and Responsibilities Section I General Information 1-1 Purpose and Scope References Statutory Authority Exceptions Section II Environmental Vision, Policy, and Goals 1-5 Vision MNARNG Environmental Policy Pollution Prevention Natural and Cultural Resources Sustained Compliance Restoration Goals Disclosure Self-Evaluation and Annual Compliance Audit Implement National Environmental Policy Act Section III Responsibilities 1-15 The Adjutant General The Assistant Adjutant General Support Executive Director Chief of Staff Facilities Management Officer The Facilities Management Office Environmental Director Public Affairs Officer Director of Logistics State Army Aviation Officer Director of Plans, Operations, and Training Staff Judge Advocate Camp Ripley and Arden Hills Army Training Site Commander Camp Ripley Environmental Supervisor State Area Command Environmental Section Minnesota State Armory Building Commission i

3 Table of Contents 1-30 The 34 th Division th Troop Command Brigade Level Units Battalion Level Units Company Level Units Environmental Compliance Officer Facility Officer/NCO In-Charge Facility Environmental Coordinator Shop Chief/Maintenance Superintendent Human Resources Officer US Property and Fiscal Officer Minnesota Facilities Management Officer Director of Public Works Facilities Management Officer Safety Officer Environmental Quality Control Committee Camp Ripley Commander Director of Logistics Environmental Education and Training Facility Management Office Design and Construction Section Chapter 2 Water Resources Management Program Section I Programs, Plans, and Procedures 2-1 Cross-Connection Control Plan Wellhead Protection Plan Storm Water Pollution Prevention Plan Wastewater Management Program Water Resource Management Plan Section II Permits, Registrations, and Notifications 2-6 Drinking Water Well Permits Water Appropriations Permit Dredge and Fill Permit National Pollutant Discharge Elimination System (NPDES) Permit National Pollutant Discharge Elimination System Storm Water Permits National Pollutant Discharge Elimination System Municipal Wastewater Treatment Permit for Regular Facilities ii

4 Table of Contents Section III Training, Certifications, and Licenses 2-12 National Pollutant Discharge Elimination System Permit Required Storm Water Training Potable Water Treatment Plant Operator Certification Wastewater Treatment Plant Operator Certification Section IV Inspections, Monitoring, and Surveys 2-15 Drinking (Potable) Water System Monitoring Requirements Wastewater and Storm Water Monitoring Water Conservation Survey Section V Reports and Inventories 2-18 Water Appropriations Reporting National Pollutant Discharge Elimination System Reporting Requirements Chapter 3 Oil and Hazardous Substance Spills Section I Programs, Plans, and Procedures 3-1 Facility Spill Contingency Plan (FSCP) Spill Prevention Control and Countermeasures (SPCC) Plan Section II Training 3-3 FSCP Training SPCC Plan Training Chapter 4 Hazardous Materials Management Section I Plans and Procedures 4-1 Hazard Communication Plan (HCP) Hazardous Material Management Plan Storage Tank Management Plan (STMP) Section II Permits, Registrations, and Notifications 4-4 Lead-Based Paint Abatement Notification Underground Storage Tank (UST) Notifications 4-6 iii

5 Table of Contents Section III Training, Certifications, and Licenses 4-6 Hazard Communication (HAZCOM) Training Hazardous Materials Transportation Training Lead-Based Paint Abatement Certification PCB Awareness Training Storage Tank Operator Training Underground Storage Tank Personnel Certification Section IV Inspections, Monitoring, and Surveys 4-12 Aboveground Storage Tank (AST) Monitoring and Inspections Section V Reports and Inventories 4-13 Emergency Planning and Community Right-to-Know (EPCRA) Reporting Hazardous Materials and Substance Inventory Chapter 5 Hazardous and Solid Waste Management Section I Plans and Procedures 5-1 Hazardous Waste Management Plan Hazardous Waste Disposal Plan RCRA Contingency Plan Integrated Solid Waste Management Plan (ISWMP) Camp Ripley Integrated Solid Waste Management Plan (CR-ISWMP) Military Munitions Recycle Account Section II Permits, Registratons, and Notifications 5-8 Hazardous Waste Management Permit Notification of Regulated Waste Activity Section III Training, Certification, and Licenses 5-10 Hazardous Waste Operations and Emergency Response (HAZWOPER) Training Hazardous Waste Generator Training Section IV Inspection and Monitoring 5-12 Hazardous Waste Generator Inspections iv

6 Table of Contents Section V Reports, Inventories, and Surveys 5-13 Hazardous Waste Inventory Hazardous Waste Generator Report Hazardous Waste Spill Reporting Reporting Enforcement Actions, Notices of Violations (NOVs), and Inspections Results Chapter 6 Air Program Section I Plans and Procedures 6-1 RISK Management Plan (RMP) Ozone-Depleting Chemical Elimination Plan (ODCEP) Section II Permits, Registrations, and Notifications 6-3 Air Operating Permits Risk Management Plan Registration Section III Training 6-5 Ozone-Depleting Chemical (ODC) Training Risk Management Plan Training Section IV Inspections, Monitoring, and Surveys 6-7 Vehicle Inspection Maintenance Procedures Section V Reports and Inventories 6-8 Notification of Breakdown, Shutdown, and Deviations Annual Emissions Reporting and Air Emissions Monitoring/Inventory Chapter 7 Environmental Noise Management Program 7-1 Environmental Noise Management Procedures Chapter 8 Asbestos Management Section I Programs, Plans, and Procedures 8-1 Asbestos Management Plan Asbestos Project Plan v

7 Table of Contents Section II Permits, Registrations, and Notifications 8-3 Asbestos Removal Permit Section III Training, Certification, and Licenses 8-4 Asbestos Management Accreditation Section IV Inspections, Monitoring, and Surveys 8-5 Asbestos Survey Chapter 9 Radon Reduction Program 9-1 Radon Testing Chapter 10 Pollution Prevention 10-1 Pollution Prevention (P2) Plan Pollution Prevention Training Chapter 11 Environmental Restoration Programs 11-1 Health Assessments The Defense Site Environmental Restoration Tracking System (DSERTS) Report Chapter 12 National Environmental Policy Act (NEPA) Requirements 12-1 Environmental Baseline Survey (EBS) NEPA Review Documentation Chapter 13 Natural and Cultural Resources Management 13-1 Integrated Natural Resources Management Plan (INRMP) Integrated Cultural Resources Management Plan (ICRMP) Wetland Replacement Plan Wetlands Monitoring Annual Report Chapter 14 Integrated Training Area Management (ITAM) 14-1 Integrated Training Area Management (ITAM) Work Plan vi

8 Table of Contents Chapter 15 Pesticide Management Program 15-1 Integrated Pesticide Management Plan (IPMP) Chapter 16 Army Energy Program 16-1 Energy Resources Management Plan (ERMP) Chapter 17 Environmental Compliance Assessment System (ECAS) 17-1 Environmental Compliance Assessment Report (ECAR) and Installation Corrective Action Plan (ICAP Report Internal Compliance Assessment System Installation Status Report (ISR) Minnesota Organizational Readiness Evaluation (MORE) Chapter 18 Environmental Training Program 18-1 Installation/State Environmental Training Plan Chapter 19 Environmental Programs in Foreign Countries 19-1 Foreign Government Environmental Training Chapter 20 Real Property Transactions 20-1 Real Property Transaction Procedures Construction Site Selection Surveys Appendix A Compliance Tables by Category...A-1 Appendix B Compliance Tables by Chapter...B-1 Appendix C Explanation of Terms and Abbreviations...C-1 vii

9 Table of Contents Appendix D References...D-1 viii

10 1 Introduction, Goals, and Responsibilities Section I General Information 1-1 Purpose and Scope a. This regulation prescribes the Minnesota Army National Guard (MNARNG) responsibilities, policies, and procedures to preserve, protect, restore, and enhance the quality of the environment. b. It incorporates applicable federal, state, local, and Army requirements for water resources, air quality, hazardous materials, solid and hazardous waste, noise, spill prevention and response planning, emergency response, environmental restoration, asbestos, radon reduction, natural resources, cultural resources, and other environmental programs adopted by regulating authority. c. Chapter 2 and the following chapters summarize regulatory requirements that include plans and procedures, permits and registrations, training, inspections, monitoring, surveys, and reports. Each chapter follows the same general format and includes: 1) References. Provides the exact federal, state, local, and Army reference for a regulatory requirement. 2) Summary. Short statement summarizing the requirement. applies to the Department of Military Affairs (DMA) or MNARNG. 4) Contents or Procedures. Lists the requirements of the regulation. It may require plans, inventories, training, reports, surveys, and/or procedures for acquiring permits. 5) Responsibilities. Assigns responsibilities within the organization for completing the requirement consistent with Chapter 1. For example, preparing the Hazardous Waste Management Plan is the responsibility of the Hazardous Waste Program Manager in the Facilities Management Office- Environmental. Additional responsibilities and procedures may be defined in the completed plan. d. This regulation and other MNARNG environmental regulations including Minnesota National Guard Regulation (MNGR) Environmental Review, MNGR Waste Management, and MNRG Integrated Spill Management are collectively called the MNARNG Environmental Compliance Program. 3) Applicability. Identifies when, where, and why a requirement 1-1

11 1 Introduction, Goals, and Responsibilities 1-2 References Required and related publications, prescribed and referenced forms, and abbreviations used are provided in Appendix A. 1-3 Statutory Authority Statutory authority for this regulation is derived from Titles 7, 10, 15, 16, 33, and 42 of the United States Code, Titles 10, 29, 33, 40 and 49 of the Code of Federal Regulations and Chapters 83A through 116I of Minnesota Statutes. This MNARNG policy reflects the policies of the Department of the Army as outlined in AR 200-1, AR 200-2, AR 200-3, AR 200-4, AR (draft), and AR , the National Guard Bureau, and the Minnesota Army National Guard. This MNARNG policy is also consistent with local ordinances. 1-4 Exceptions In the interest of national defense, it may be considered inappropriate to execute a policy stated in this regulation or the environmental requirements that this regulation cites for compliance. Forward requests for exceptions through channels to State of Minnesota, DMA, ATTN: MNAG- FMO-E, Highway 115, Little Falls, MN Requests will be reviewed and, if appropriate, forwarded to higher headquarters and regulators for consideration of possible exemption from requirement. Section II Environmental Vision, Policy, and Goals 1-5 Vision The MNARNG vision is to lead the way in protecting and enhancing our natural and cultural resources while maintaining the highest degree of military readiness. 1-6 MNARNG Environmental Policy The MNARNG is committed to environmental stewardship in all actions as an integral part of the National Guard mission. This regulation implements the U.S. Army Environmental Strategy into the 21 st Century. 1-7 Pollution Prevention The MNARNG will focus efforts on pollution prevention (P2) where and when possible to reduce or eliminate pollution at the source. 1-8 Natural and Cultural Resources The MNARNG will conserve and preserve natural and cultural resources so they will be available for present and future generations to use. 1-9 Sustained Compliance The MNARNG will give priority to sustained compliance with all applicable environmental laws Restoration The MNARNG will continue to restore previously contaminated sites deemed as a threat to human health and the environment Goals a. The MNARNG will integrate innovative environmental solutions into processes and systems so that they become a way of life, in order to prevent pollution, achieve or exceed regulatory compliance, minimize procedural burdens, reduce costs, 1-2

12 1 Introduction, Goals, and Responsibilities conserve resources, enhance safety, and increase time available for the soldier s mission. b. The MNARNG will utilize effective partnerships both within and outside the organization to develop innovative solutions, to obtain command, soldier and regulator buy in, and to promote success. c. The MNARNG will measure success by customer satisfaction on how well compliance and beyond is integrated into processes Disclosure The MNARNG will disclose to its employees and to the public, incidents relating to its operations that cause environmental harm or pose health or safety hazards and will not take any action against employees who report any condition that creates a danger to the environment or poses health or safety hazards Self-Evaluation and Annual Compliance Audit The MNARNG will conduct environmental compliance audits of progress in implementing MNARNG environmental policy and make these documents available to appropriate regulatory agencies and to the public Implement National Environmental Policy Act The MNARNG will implement the National Environmental Policy Act (NEPA) by: a. Monitoring and controlling environmental projects and activities. b. Integrating activities to protect and conserve environmental, natural, and cultural resources into planning and executing the mission. c. Utilizing the Minnesota Environmental Quality Board (EQB) approved DMA Alternate Environmental Review Process to complete environmental review documents. Section III Responsibilities 1-15 The Adjutant General The Adjutant General (TAG) will: a. Establish and maintain a comprehensive MNARNG environmental program to comply with all aspects of DOD, DA, and National Guard Bureau (NGB) environmental policies and programs. b. Provide command emphasis on environmental compliance assuring that the MNARNG complies with all applicable federal, state, and local environmental laws and regulations The Assistant Adjutant General Support The Assistant Adjutant General Support (AAG-Support) will: a. Serve as chair and member of Environmental Quality Control Committee (EQCC). b. Establish organizational structures to implement the MNARNG Environmental Program. c. Monitor the MNARNG environmental program and identify resources to accomplish it. 1-3

13 1 Introduction, Goals, and Responsibilities d. Integrate environmental goals into the MNARNG Strategic Plan and resource them Executive Director The Executive Director (EXDIR) will: a. Serve as Alternate Chair and member of the EQCC. b. Obtain and prioritize state provided resources (funds and people) to implement environmental programs. c. Approve the Environmental Program Requirements (EPR) Report submitted to NGB which requests federal funds and justifies and prioritizes MNARNG environmental personnel and projects. d. Approve Installation Status Report (ISR) Part II Environmental submitted to NGB. Report depicts the status of the MNARNG environmental program. e. Review NEPA documents for all MNARNG real property actions and military construction (MILCON) projects Chief of Staff The Chief of Staff (CoS) will: a. Serve as member of EQCC. b. Obtain and prioritize federally funded resources to implement the environmental program. c. Ensure environmental policy and programs are integrated into the Organization Facilities Management Officer The Facilities Management Officer (FMO) will: a. Serve as a member of the EQCC. b. Conduct duties as appointed federal fund manager for Environmental and Integrated Training Area Management (ITAM) Program funds. c. Approve the Federal Environmental Operating Budget and execute the federal and state environmental program. d. Represent the Environmental Program at the MN Program Budget Advisory Committee (PBAC). e. Ensure construction projects meet current environmental standards; and establish a plan/schedule for bringing existing facilities into compliance. f. Ensure that NEPA requirements are complied with for all real property transactions and all facility construction, maintenance, and repair projects. Ensure that appropriate considerations for the environment are included in all of these actions. g. Obtain and renew appropriate environmental licenses and permits for MNARNG facilities and activities. Hold signature authority as landowner for the DMA when required on environmental licenses and permits. h. Operate and maintain the Camp Ripley wastewater treatment plant, solid waste transfer facility, demolition debris landfill, soil land spread site, and drinking water plant in accordance with permits utilizing operators appropriately trained and certified. 1-4

14 1 Introduction, Goals, and Responsibilities i. Acquire and maintain drinkingwater well construction and/or modification permits. j. Incorporate necessary water appropriation permit requirements into construction and maintenance projects as required. k. Obtain dredge and fill permits before construction activities are performed in waters of the United States. l. Direct the MNARNG Facilities Energy Program. m. Provide State purchasing and contracting support for environmental program. n. Provide and maintain the Camp Ripley Hazardous Material and Spill Response Team. o. Direct the State Employee Occupational Health Program. The Program will: 1. Provide State employees Occupational Safety and Health Act (OSHA) Employee Right-to-Know training and maintain their records. 2. Manage State employee medical surveillance program and records. 3. Provide Material Safety Sheets for materials purchased by the State Supply System. 4. Conduct indoor air monitoring at State facilities. 5. Maintain hazardous material/hazardous substance inventory. 6. Prescribe proper hazardous chemical storage facilities and storage guidance. 7. Provide State employees proper personal protective equipment (PPE). p. Co-approve the ITAM Program workplan and budget. q. Provide personnel and equipment to implement the Land Rehabilitation and Maintenance (LRAM) Program on training sites. Seek reimbursement from ITAM program for all expenses. r. Maintain the State employee environmental training and safety calendar. s. Develop and maintain the facility cross-connection control program. t. Establish and maintain the MNARNG asbestos management program. u. Ensure training and certification required by law is provided to appropriate personnel for: 1. Emergency response to discharges of petroleum oil and lubricant (POL), hazardous waste (HW), or regulated materials. 2. Pesticide selection and application. 3. Operation and maintenance of wastewater monitoring, treatment, and disposal facilities. 4. Operation and maintenance of drinking water facilities. 5. Repair or removal of asbestos materials. 1-5

15 1 Introduction, Goals, and Responsibilities v. Prepare water conservation surveys. w. Contract all lead-based paint abatement to only licensed certified firms for completion. x. Oversee underground storage tank (UST) personnel certification. y. Prepare and maintain an Asbestos Management Plan (AMP) for each facility requiring one. z. Utilize only trained and certified asbestos abatement workers and supervisors for asbestos abatement aa. Require in contract documents the preparation and implementation of asbestos project plans by contractors as required. bb. Notify and obtain or require that the project contractor provide proper notification to Department of Health and obtain permit for asbestos abatement cc. Require that contractor provided asbestos workers have received the appropriate level of training and are certified. dd. Co-approve the ITAM work plan with the POTO. ee. Prepare, implement, and maintain the Energy Resources Management Plan (ERMP). ff. Coordinate and complete the construction site selection survey. gg. Incorporate local NPDES storm water permit requirements into new facility design plans and specifications as part of the construction package. hh. Contract for any changes to existing UST Systems or installation of new systems with a licensed tank installer The Facilities Management Office Environmental Director The Facilities Management Office Environmental Director (FMO-E) will: a. Serve as Executive Secretary and member of EQCC. b. Act as the Environmental Coordinator for the Adjutant General in accordance with (IAW) paragraph 1-27(a)(3), AR 200-1, and serve as technical advisor to the Adjutant General, MNARNG, and DMA concerning environmental programs, policies, and requirements. c. Prepare and Maintain the Environmental Program Requirements Report submitted to NGB. d. Prepare, manage, and execute federal and state environmental program budgets. e. Manage applicable chapters and appendices of the Master Cooperative Agreement. f. Coordinate and administer the MNARNG Environmental Program as defined by NGB to include: foundation, compliance, restoration, P2, and conservation. g. Direct and manage the Compliance Program that includes: air quality, hazardous waste, solid waste, storage tank, wastewater, water quality, contingency planning/pol, and toxic substances control. h. Direct and manage the NEPA and the State Environmental review processes. 1-6

16 1 Introduction, Goals, and Responsibilities i. Direct and manage the Restoration Program to cleanup past practices of the Department. j. Direct and manage the P2 Program, which includes recycling and solid waste reduction, hazardous materials management, and toxic release/ waste reduction. k. Provide guidance for management of hazardous materials. 1. Maintain the hazardous material/hazardous substance inventory. 2. Prescribe proper hazardous chemical storage facilities and storage management. l. Negotiate environmental requirements and resolve conflicts with federal, state, and local regulators. m. Coordinate, manage, and implement environmental projects. n. Coordinate the environmental compliance-training program. o. Develop and offer training for Facility Environmental Coordinators (FECs). p. Assess and report the environmental quality and compliance of the MNARNG by: 1) Preparing the Environmental Quality Report (EQR) submitted quarterly to NGB, 2) Preparing the annual Installation Status Report (ISR) Part II submitted annually to NGB, System (ICAS) required by Department of Army and NGB. q. Coordinate and conduct the MNARNG Environmental Awareness Program. r. Prepare environmental reports submitted to Higher Headquarters and regulators. s. Prepare and maintain the Camp Ripley Wellhead Protection Plan. t. Prepare and maintain storm water P2 plans where required. u. Prepare and maintain the Camp Ripley Wastewater Management Plan (WWMP). v. Prepare and maintain the Camp Ripley Water Resources Management Plan (WRMP). w. Obtain and maintain the Camp Ripley water appropriation permit. x. Obtain and maintain required National Pollutant Discharge Elimination System (NPDES) permits. y. Obtain and maintain NPDES storm water permits for MNARNG facilities. z. Prepare and maintain Camp Ripley Wastewater Treatment Plant (WWTP) NPDES permit. aa. Prepare and maintain Camp Ripley WWTP Industrial By Product (Land Application) Permit. bb. Prepare and provide storm water training curriculum for facilities required to implement training. cc. Prepare water appropriations reports. 3) Conducting the annual Internal Compliance Assessment 1-7

17 1 Introduction, Goals, and Responsibilities dd. Submit storm water NPDES permit reports for each facility required to submit a report. ee. Prepare the Facility Spill Contingency Plan (FSCP) template to be completed for each facility and for unit training actions and publish it in MNGR ff. Prepare and maintain the Camp Ripley Spill Prevention Control and Countermeasure (SPCC) Plan. gg. Develop and provide annual FSCP training for FECs. hh. Provide FECs at Camp Ripley appropriate training IAW applicable Camp Ripley SPCC Plan requirements. ii. Develop and maintain the MNARNG Hazardous Material Inventory (HM) database that will keep facility hazardous material lists. jj. Prepare and maintain the Storage Tank Management Plan (STMP). kk. Submit UST notifications to Minnesota Pollution Control Agency (MPCA). ll. Develop and provide appropriate storage tank operator training for facility officer in charge (OIC)/FEC and tank operators. mm. Develop monitoring and inspection procedures for each aboveground storage tank (AST) system requiring it. nn. Develop and maintain the MNARNG Hazardous Waste Management Plan (HWMP). The plan will be included within MNGR oo. Develop and maintain the MNARNG Hazardous Waste Disposal Plan (HWDP). pp. Prepare and maintain the resource Conservation and Recovery Act (RCRA) Contingency Plan, when required. qq. Develop and maintain the MNARNG Integrated Solid Waste Management Plan (ISWMP). rr. Develop and maintain the Camp Ripley ISWMP. ss. Provide disposal guidance for any munitions, which according to DOD policy and the Military Munitions Rule are classified as hazardous waste. tt. Coordinate with the Staff Judge Advocate (SJA) and prepare response to regulator. uu. Report enforcement actions, notices of violation and inspection results to Higher Headquarters within 24 hours of receipt from regulator. vv. Submit all hazardous waste spill reports for the MNARNG. ww. Submit annually the generator report for each hazardous waste generating facility to the appropriate regulatory agency. xx. Provide specific hazardous waste inventory guidance for the FEC in MNGR 200-3, Integrated Hazardous Waste Management. yy. Provide specific inspection guidance for the FEC in MNGR 200-3, Integrated Hazardous Waste Management. zz. Develop and provide hazardous waste generator training. aaa. Provide appropriate training to personal on the Camp Ripley Hazardous Waste Operations and Emergency Response (HAZWOPER) team. 1-8

18 1 Introduction, Goals, and Responsibilities bbb. Prepare and submit the Notification of Regulated Waste Activity for each facility requiring one. ccc. Acquire the hazardous waste permit for the facility (if required). ddd. Plan, administer, direct, coordinate, and manage the recycle program and the MN Recycle Account. eee. Prepare and submit the Camp Ripley Annual Air Emissions Inventory/Report to the MPCA. fff. Establish a notification process within the MNARNG and provide notification to regulators as necessary. ggg. Track developments in the MPCA Air Program to ensure compliance with any new program. hhh. Develop and provide Risk Management Plan (RMP) training when necessary. iii. Register required RMPs. jjj. Develop and maintain the Camp Ripley Air Registration Permit. kkk. Develop and maintain the Ozone Depleting Chemical Elimination Plan (ODCEP). lll. Prepare, submit, and maintain any required RMPs. mmm. Conduct and maintain an asbestos survey for each facility requiring one. nnn. Conduct radon testing and notify appropriate staff. ooo. Develop and provide training on MNARNG P2 Plan for personnel as appropriate. ppp. Prepare and maintain the MNARNG P2 Plan. qqq. Report cleanup operations to the Army using the appropriate databases. rrr. Perform public health assessments for any MNARNG sites listed or proposed for the National Priorities List (NPL). sss. Publish Department NEPA and EQB implementation guidance in MNGR ttt. Prepare, before Department actions, necessary environmental review documents including NEPA Checklists, Records of Decision (RODs), Environmental Assessments (EAs), Findings of No Significant Impact (FONSI), and Environmental Impact Statements (EISs). uuu. Prepare an Environmental Baseline Survey (EBS) before the purchase of or disposal of MNARNG and DMA properties. vvv. Coordinate the NEPA review of each Integrated Cultural Resources Management Plan (ICRMP). www. Maintain Minnesota Organizational Readiness Evaluation (MORE) environmental findings within the Environmental Compliance Assessment System (ECAS) database. xxx. Prepare the MNARNG ISR Environmental. yyy. Establish the ICAS team, conduct the ICAS and prepare Installation Corrective Action Plan (ICAP) and Environmental Compliance Assessment Reports (ECARs). zzz. Prepare and submit the MNARNG ICAP and ECARs for NGB conducted ECAS of MNARNG. 1-9

19 1 Introduction, Goals, and Responsibilities aaaa. Coordinate, prepare and maintain the State Environmental Training Program/Plan. bbbb. Develop the environmental portion of the construction site selection survey Public Affairs Officer The Public Affairs Officer (PAO) will: a. Serve or appoint a representative to serve as a member of the EQCC. b. Serve as the initial point of contact for dissemination of information and receipt of public comment. c. Work in coordination with FMO-E to prepare and disseminate media releases and to conduct public involvement activities. d. Receive comment on all DMA NEPA documents provided to the public for comment Director of Logistics The Director of Logistics (DOL) will: a. Serve as a member of the EQCC. b. Ensure primary and alternate FECs are appointed and trained for facilities the Directorate manages. c. Coordinate proposed logistical plans and equipment maintenance plans with FMO-E for integration of environmental requirements and preparation of appropriate NEPA documentation. d. Approve NEPA documents for Directorate activities and incorporate appropriate considerations for the environment into plans, fieldings, and projects. e. Act as the point of contact for all matters involving the transportation of hazardous substances, hazardous wastes, and recyclable materials; coordinate compliance with applicable regulations. f. Maintain and provide supplies and equipment necessary for waste disposal, waste minimization, and spill response. g. Obtain and maintain proper authorizations for federal environmental equipment. h. Maintain the Federal Hazardous Material Authorized Use List (AUL). i. Transport very small quantity generator (VSQG) waste streams. j. Operate permitted VSQG collection site. Collect, store, recontainerize, and transport hazardous material/waste from site. k. Operate small quantity generator (SQG) transfer facility. Collect and transport hazardous material/waste from site. l. Provide proper PPE for federal employees. m. Review requests for hazardous materials purchases and procure non-hazardous materials when feasible and prudent. n. Provide material safety data sheets (MSDSs) for materials purchased by the federal supply system. o. Gather and provide FMO-E supply and maintenance activity information and data necessary for preparation of Camp Ripley Emergency Planning and Community Right-to-Know (EPCRA) disclosure report. 1-10

20 1 Introduction, Goals, and Responsibilities p. Establish and maintain those portions of the Hazardous Materials Management Plan (HMMP) and necessary operational activities for hazardous material (HM) procured through the federal supply system. q. Implement and maintain hazardous materials transportation training program. r. Utilize only certified personnel to service equipment containing ozonedepleting chemicals State Army Aviation Officer The State Army Aviation Officer (SAAO) will: a. Serve as a member of the EQCC. b. Ensure primary and alternate FEC are appointed for facilities the Directorate manages. c. Coordinate proposed aviation programs, plans, land transactions and equipment fielding with FMO-E for integration of environmental requirements and preparation of NEPA documentation. d. Approve NEPA documents for Directorate activities and incorporate appropriate considerations for the environment into plans, fieldings, and projects. e. Conduct indoor air monitoring. f. As Chair of the State Safety Committee, coordinate the activities of the Federal Occupational Health Program. The program will: 1. Prescribe federal employees PPE 2. Provide federal employees OSHA employee Right-to-Know training and maintain records. 3. Conduct air monitoring for all facilities. 4. Manage the federal employee medical surveillance program and maintain records. g. Develop and maintain the MNARNG Hazard Communication Plan (HCP) for federal employees and purchasing system. h. Develop, implement, and maintain hazard communication (HAZCOM) training program for all federal employees of the MNARNG Director Of Plans, Operations, and Training The Director of Plans, Operations, and Training (POTO) will: a. Serve or appoint a representative to serve as member of the EQCC. b. Appoint or perform the duties of an ECO for the Directorate. c. Ensure primary and alternate FECs are appointed for facilities the Directorate manages. d. Coordinate proposed new or different military training plans, real property transactions, equipment fielding, local training area proposals, and innovative training projects with FMO-E for integration of environmental requirements and preparation of NEPA documentation. e. Forward local training area (LTA) and Range lease request packages to FMO-E for integration of environmental requirements and preparation of NEPA documentation. 1-11

21 1 Introduction, Goals, and Responsibilities f. Approve NEPA documents for Directorate activities and incorporate appropriate considerations for the environment into plans, fieldings, and projects. g. Review all draft MNARNG EAs/EISs for operational security (OPSEC) considerations prior to distribution for public comment. h. Co-approve the ITAM Program workplan and budget. i. Maintain the environmental training calendar for military and federal employees. j. Maintain required environmental training records for soldiers. k. Co-approve the ITAM work plan with FMO-Z Staff Judge Advocate The Staff Judge Advocate (SJA) will: a. Serve or appoint a representative to serve as member of the EQCC. b. Coordinate the representation of TAG and the State of Minnesota with the State Attorney General or the local U.S. Attorney before courts, administrative tribunals, and regulatory bodies. c. Serve as Department legal counsel Camp Ripley and Arden Hills Army Training Site Commander The Camp Ripley Commander (CRC-Z) will: c. Appoint primary and alternate FECs for facilities the Command manages. d. Appoint CRC-EN Environmental Supervisor as Department Integrated Pest Management Coordinator (PMC). e. Appoint CRC-EN Environmental Supervisor as Department Cultural Resource Manager. f. Obtain and renew cultural and natural resource special use permits. g. Coordinate proposed changes to training plans, land transactions, and ranges with FMO-E for integration of environmental requirements and preparation of NEPA documentation. h. Approve NEPA documents for the Commands activities and incorporate appropriate considerations for the environment into training site plans, actions, fieldings, and projects. i. Coordinate, administer and Co-approve the ITAM Program workplan and budget. j. Provide environmental training to troops utilizing Camp Ripley and AHATS. k. Establish and implement monitoring and inspection procedures at Camp Ripley POL Tank Farm. l. Gather and provide FMO-E required training area information and data necessary for preparation of Camp Ripley EPCRA disclosure report. m. Implement DOD policy on the EPA Military Munitions Rule. a. Serve as a member of the EQCC. b. Appoint or perform the duties of an ECO for the Installation Support Unit. 1-12

22 1 Introduction, Goals, and Responsibilities 1-27 Camp Ripley Environmental Supervisor The Camp Ripley Environmental Office Supervisor (CRC-EN) will: a. Serve as a member of the EQCC. b. Manage the MNARNG Conservation Program that includes Natural Resources, Cultural Resources, Wetlands, Environmental Noise, and Pest Management. c. Manage the ITAM program. d. Act as the MNARNG Pest Management Coordinator. e. Act as the MNARNG Cultural Resource Manager (CRM). f. Manage Geographical Information System (GIS) Staff. g. Prepare and execute the Conservation and ITAM budgets and work plans h. Coordinate and conduct the Camp Ripley Environmental Awareness Program. i. Negotiate conservation requirements with federal, state, and local regulators. j. Review and comment on proposed MNARNG programs, plans, real property transactions, and equipment fielding for Conservation and ITAM compliance as part of the NEPA review process. k. Submit to FMO-E appropriate information for quarterly preparation of EPR Report and the Environmental Quality Report (EQR) and the annual ISR Part II. l. Prepare and maintain the MNARNG Environmental Noise Management Program (ENMP). m. Prepare and maintain the MNARNG Integrated Pest Management Plan (IPMP). n. Prepare any required wetland monitoring annual reports. o. Prepare and maintain any required Wetland Replacement Plans. p. Prepare and maintain the Department wide ICRMP and a ICRMP for each Department training site requiring one. q. Prepare and maintain the Integrated Natural Resources Management Plan (INRMP) for each Department training site requiring one State Area Command Environmental Section The STARC Environmental Section Chief will: a. Serve as member of the EQCC. b. Coordinate and offer environmental training for Environmental Compliance Officers (ECO). c. Assess environmental compliance of MNARNG units as part of the MORE. d. Resolve environmental compliance issues identified by MORE. e. Support FMO-E environmental requirements. f. Develop the unit environmental checklist and evaluate units as part of MORE. 1-13

23 1 Introduction, Goals, and Responsibilities g. Develop and maintain a U.S. Army in Foreign nations reference library and provide environmental training to MNARNG units to ensure understanding and compliance with relevant Final Governing Standards (FGS) or Overseas Environmental Baseline Guidance Document (OEBGD) standards Minnesota State Armory Building Commission The Executive Director, Minnesota State Armory Building Commission (MSABC) will: a. Coordinate proposed real property transactions, building construction and facility leases with FMO-E for integration of environmental requirements and preparation of Environmental Baseline Surveys and NEPA documentation. b. Integrate NEPA requirements and incorporate appropriate considerations for the environment into MSABC actions and projects The 34 th Division The 34 th Division Commander will: a. Appoint a representative to serve as a member of the EQCC. b. Ensure subordinate Commanders appoint and train Environmental Compliance Officers (ECOs). c. Ensure primary and alternate FECs are appointed for facilities the Command manages. d. Coordinate proposed local training areas, and new or different training actions thru the Adjutant General s Office to FMO-E for integration of environmental requirements and preparation of NEPA documentation. e. Integrate NEPA requirements and incorporate appropriate considerations for the environment into training plans. f. Report any regulatory enforcement action, notice of violation receipt or regulatory inspection to FMO-E within 24 hours of receipt. g. Ensure their personnel receive relevant FGS and OEBGD training prior to deployment into another country th Troop Command The 84 th Troop Command Commander will: a. Serve or appoint a representative to serve as a member of the EQCC. b. Appoint or perform the duties of an ECO for the Command. c. Ensure subordinate Commanders appoint and train ECOs. d. Ensure primary and alternate FECs are appointed and trained for facilities the Command manages. e. Coordinate proposed programs, plans, and real property transactions thru the Adjutant General s Office to FMO-E for integration of environmental requirements and preparation of NEPA documentation. f. Integrate NEPA requirements and incorporate appropriate considerations for the environment into projects. g. Report any regulatory enforcement action, notice of violation receipt or regulatory inspection to FMO-E within 24 hours of receipt. h. Ensure their personnel receive relevant FGS and OEBGD training 1-14

24 1 Introduction, Goals, and Responsibilities prior to deployment into another country Brigade Level Units Brigade Commanders will: a. Appoint or perform the duties of an ECO for the Command. b. Ensure subordinate Commanders appoint and train ECOs for each unit. c. Ensure primary and alternate FECs are appointed and trained for facilities the Command manages. d. Report any regulatory enforcement action, notice of violation receipt or regulatory inspection to FMO-E within 24 hours of receipt. e. Ensure their personnel receive relevant FGS and OEBGD training prior to deployment into another country Battalion Level Units Battalion Commanders will: a. Appoint or perform the duties of ECO for the Command. b. Ensure subordinate Commanders appoint and train ECOs for each unit. c. Ensure primary and alternate FECs are appointed and trained for facilities the Command manages. d. Forward non-lease LTA and range request packages (e.g., refueling sites) to FMO-E for integration of environmental requirements and preparation of NEPA documentation. e. Report any regulatory enforcement action, notice of violation receipt or regulatory inspection to FMO-E within 24 hours of receipt. f. Ensure their personnel receive relevant FGS and OEBGD training prior to deployment into another country Company Level Units Company Commanders will: a. Appoint an ECO for the unit. b. Coordinate proposed programs, plans, and land transactions thru the Adjutant General s Office to FMO-E for integration of environmental requirements and preparation of NEPA documentation. c. Integrate NEPA requirements and incorporate appropriate considerations for the environment into actions and training. d. Report any regulatory enforcement action, notice of violation receipt or regulatory inspection to FMO-E within 24 hours of receipt. e. Ensure their personnel receive relevant FGS and OEBGD training prior to deployment into another country Environmental Compliance Officer Environmental Compliance Officers (ECOs) will: a. Work directly for the commander and/or director and be responsible for integrating the MNARNG Environmental Compliance Program into the planning and execution of the command s basic mission. b. Advise unit Commander and NCOs on implementing environmental compliance activities into planning and training by providing knowledge of general MNARNG environmental 1-15

25 1 Introduction, Goals, and Responsibilities rules, regulations and policies, and obtaining information as needed. c. Perform unit environmental self-assessment and risk assessment. d. Conduct soldier environmental awareness training for the unit. e. Focus on the impact of unit activities to the environment. f. Maintain the hazardous material/hazardous substance inventory. g. Attend ECO training course within six months of appointment. h. Ensure compliance with all federal, state, regional, and local laws and regulations, particularly for those MNARNG sites where hazardous materials and wastes are generated, stored, handled, treated, or disposed. i. Provide transportation spill training to the unit Facility Officer/NCO In-Charge The Facility Officer / NCO-in Charge will: a. Act as or appoint a primary and alternate FEC for the facility. The FEC will be a fulltime federal employee of the MNARNG. b. Ensure compliance with all federal, state, regional, and local laws and regulations, particularly with regard to those MNARNG sites where hazardous materials and wastes are generated, stored, handled, treated, or disposed. c. Escort and provide representatives of regulatory agencies appropriate access to the facility or activity to monitor compliance with applicable regulatory standards. d. Report directly to FMO-E and to Higher Headquarters within 24 hours, any inspection of the facility by a regulatory agency. e. Report any regulatory enforcement action, notice of violation receipt or regulatory inspection to FMO-E within 24 hours of receipt Facility Environmental Coordinator The Facility Environmental Coordinator (FEC) will: a. Maintain the facility hazardous material/hazardous substance inventory and authorized usage list. b. Coordinate and implement environmental programs for the facility IAW MNGR 200-2, 200-3, , and as directed by FMO-E. c. Ensure facility compliance with all federal, state, regional, and local laws and regulations, particularly with regard to those MNARNG sites where hazardous materials and wastes are generated, stored, handled, treated, or disposed. d. Escort representatives of regulatory agencies and provide appropriate access to the facility or activity to monitor compliance with applicable regulatory standards. e. Prepare and sign appropriate facility environmental forms and reports required by MNARNG regulation. f. Enforce the requirements of the NPDES permit at the facility. 1-16

26 1 Introduction, Goals, and Responsibilities g. Implement storm water training as required. h. Complete and implement the FSCP at the facility. i. Implement the SPCC Plan at the facility. j. Provide annual FSCP implementation training to personnel at the facility. k. Provide SPCC Plan training as appropriate for implementation at the facility. l. Establish and implement AST monitoring and inspection procedures for ASTs at the facility. m. Report any regulatory enforcement action, notice of violation receipt or regulatory inspection to FMO-E within 24 hours of receipt. n. Attend hazardous waste generator training within six months of appointment and refresher training annually. o. Comply with the facility hazardous generator license and notify FMO-E when activities at the facility change from those described in the permit. p. (At a facility with air control equipment) notify FMO-E of any breakdowns, shutdowns or deviations within 24 hours of the deviation Shop Chief/Maintenance Superintendent Shop Chiefs/Maintenance Superintendents will: a. Appoint a primary and alternate FEC for the facility. The FEC will be a full time federal employee of the MNARNG. b. Ensure compliance with all federal, state, regional, and local laws and regulations, particularly with regard to those MNARNG sites where hazardous materials and wastes are generated, stored, handled, treated, or disposed. c. Escort representatives of regulatory agencies and provide appropriate access to the facility or activity to monitor compliance with applicable regulatory standards. d. Report any inspection of the facility by a regulatory agency directly to FMO-E and to Higher Headquarters within 24 hours Human Resources Officer The Human Resources Officer (HRO) will: a. Serve as a member of the EQCC. b. Budget for and fund required environmental training to include FEC and ECO. c. Maintain the permanent environmental training records for federal employees US Property and Fiscal Officer Minnesota The US Property and Fiscal Officer - Minnesota (USP&FO-MN) will: a. Serve as member of EQCC. b. Provide federal purchasing and contracting support. c. Prepare the Federal-State Cooperative Agreement, Appendix 2. d. Provide federal accounting/ tracking support for federal environmental funds. 1-17

27 1 Introduction, Goals, and Responsibilities e. Establish and maintain the MN Recycle Account with DFAS-IN and provide records of funds entering and leaving account Facilities Management Officer Director of Public Works The Facilities Management Officer Director of Public Works (FMO-DPW) will: a. Develop and maintain the crossconnection control program. b. Maintain records required by potable water appropriations permit and provide copies to FMO-E. c. Incorporate necessary water appropriation permit. d. Ensure that the WWTP operator is licensed before being allowed to manage the treatment plant. e. Ensure that waste water treatment plant operators are trained and certified. f. Coordinate monitoring of Camp Ripley Drinking Water with Minnesota Department of Health (MDH) as required and submit copies of results to FMO-E. g. Monitor Camp Ripley WWTP effluent as required by permit and provide copy of results to FMO-E monthly. h. Monitor Area 22 wash rack effluent as required by permit and provide copy of results to FMO-E. i. Maintain a water appropriations log for each Camp Ripley well. j. Submit the NPDES report for the Camp Ripley WWTP and provide copy to FMO-E. k. Submit NPDES report for the Area 22 wash rack and provide a copy to FMO-E. l. Notify FMO-E of lead-based paint removal projects and notify and coordinate with appropriate regulators and personnel prior to lead-based paint removal activities. m. Organize and maintain the Camp Ripley HAZWOPER Team. n. Utilize only certified personnel to service equipment containing ozonedepleting chemicals. o. Execute LRAM projects to its capability Facilities Management Officer Safety Officer The Facilities Management Officer Safety Officer (FMO Safety Officer) will: a. Develop and maintain the MNARNG HCP for state employees and purchasing system. b. Develop, implement, and maintain an Employee-Right-To-Know training program for al state employees of the DMA Environmental Quality Control Committee The MNARNG Environmental Quality Control Committee (EQCC) is established for purposes of paragraph 15-11, AR The EQCC will consist of a Chairperson, Assistant Chairperson, Executive Secretary, and members. EQCC appointments and responsibilities are as follows: a. The AAG-Support will serve as Chair and is responsible for convening the EQCC. 1-18

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